31 Helmholz 2004, p. 400. 32 Sheehan 1963, pp. 186–87. 33 Woolgar 2011. 34 Richter 1967, p. 249. 35 Woolgar 2011, pp. 54–55. 36 Barrow 1998, p. 152. huwpryce English ecclesiastical law treated oral wills as fully equivalent to written testaments in virtually every respect.’31 Thus, while a subsequent written record might be made of the will, this was not essential.32 Let me turn, finally, to episcopal wills. As with the adoption of the canonical will in general, conformity with an evolving English practice occurred more quickly in south than in north Wales. The subject has been greatly illuminated by Christopher Woolgar’s volume on the wills of medieval English and Welsh bishops, which includes a catalogue of the surviving documents and prints texts of selected wills and associated material.33 According to his hostile biographer, after David fitz Gerald, Bishop of St Davids, died in 1176 officials of King Henry II of England seized more than 200 marks of silver from a chest in the cathedral church. These had been deposited there by the bishop without the knowledge of the canons, who, because he had died intestate, were unable to have the money returned for the use of the cathedral church by either the king or the archbishop of Canterbury, which implies that David could have made a will in order to prevent such depredations.34 However, it is only from the early thirteenth century that we have intermittent records of bishops of St Davids making wills, the earliest being Iorwerth or Gervase, who died in 1229.35 In addition, episcopal statutes issued for the chapter of St Davids in 1259 declared that from time immemorial it had been the custom for executors of the bishops and canons of the church to receive the income (obventiones) of the deceased for a year following his death and to dispose of the revenues (proventus) of their prebends according to the wishes of the deceased. In addition, each canon was obliged to bequeath a silk cape to the church, if he had not already given one in his lifetime.36 In the south-eastern bishopric of Llandaff, the earliest bishop known to have made a will was William de Radnor, who died in 1266, though, as 435
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