The Gibbet Law may have been a last vestige of the Anglo-Saxon custom of infangtheof, which allowed landowners to enforce summary justice on thieves within the boundaries of their estates. Samuel Midgley in his "Halifax and its Gibbet-Law Placed in a True Light", published in 1761, states that the law dates from a time "not in the memory of man to the contrary". It may have been the consequence of rights granted by King Henry III to John de Warenne (1231–1304), Lord of the Manor of Wakefield. Such baronial jurisdiction was by no means unusual in medieval England and was described in the 11th-century legal text entitled "De Baronibus, qui suas habent curias et consuetudines" (Concerning the barons who have their courts of law and customs). Neither was the decapitation of convicted felons unique to Halifax; the earls of Chester amongst others also exercised the right to "behead any malefactor or thief, who was apprehended in the action, or against whom it was made apparent by sufficient witness, or confession, before four inhabitants of the place", recorded as the Custom of Cheshire.