This was originally interpreted as the foundation of the King's Bench, with the Court of Common Pleas not coming into existence until the granting of Magna Carta, which mandated in Section 17 that common pleas (cases between subject and subject, as opposed to cases involving the king) be heard in "some fixed place". This ensured that rather than the source of justice moving from place to place as the king did, there would be a fixed location that claimants and defendants could travel to that would address their problems. The later theory was that Henry II's decree created the Court of Common Pleas, not the King's Bench, and that the King's Bench instead split from the Common Pleas at some later time. In the 20th century, with better access to historical documents, legal historians have come to a different conclusion. Rather than the Common Pleas being created out of the "curia regis" directly, it instead arose out of the Exchequer of Pleas, another body split from the "curia regis". By the beginning of the 13th century, a split began; chronicles from 1201 identify the "bench" and "exchequer" as distinct bodies, and records of Barons of the Exchequer and Justices of the Common Pleas show a distinct lack of overlap.