The designation "misprision, and no murder", can be traced to the "Leges Henrici Primi" of 1115, which designated abortion "quasi homicide". Here, we find the penalties for abortion were varying lengths of penance, indicating it was dealt with by ecclesiastical courts, while homicide, being a breach of the King's peace, was dealt with in secular courts. Penalties for abortion varied depending on whether the fetus was formed or unformed, that is before or after quickening, and were only imposed on women who had aborted the product of "fornication" (illicit sex), a distinction previously made by the Venerable Bede.