Henry III had a reputation of ruling by fiat – making royal proclamations on the spur of the moment. These were troublesome to both the secular and the church courts of the day, and efforts were made to curtail and limit this practice. During the long reign of Henry III, the donation of land to the Church became increasingly common. A feudal tenant would typically practice collusion with the Church in order to defeat a claim by his overlord for feudal services, by donating the land to a religious foundation on condition of it granting him a fresh tenancy of that land. The "Great Charter" of 1217 contained the first direct provision against this practice:  Several cases are recorded where the King specifically forbade the tenant from alienating a church or land held in perpetuity by the Crown, and thus presumably the equivalent of mortmain. These cases are dated 1164, 1221 and 1227. After 1217, there was a forfeiture of the land to the overlord in a case of unauthorized alienation in mortmain. However, Henry III showed conspicuous favour to the Church and left the proclamations of 1215 and 1217 made by King John largely unenforced. The proscription was reintroduced, and made more forcible, by Henry III's son, Edward I, by the Statutes of Mortmain in 1279 and 1290. However, all of these attempts at proscription were ineffective. Land could instead be left to the Church by the development of the new device of the "cestui que use". Henry VII expended much energy in the courts trying to break the legal grip of "uses" by Church corporations. The Statute of Uses, passed three centuries after the Statutes of Mortmain, would attempt – with only partial success – to end the practice of the "cestui que use". Henry VIII would resolve the problem of Church lands once and for all, in 1535, by dissolving the monasteries and confiscating all Church lands.