A service turned into money which was paid because an- ciently the tenants used to wash the lord's sheep. When applicable it is not affected by the testator's intention; 28 Atl. Rep. (N. J.) 587. It is qually applicable to convey- ances by deed and limitations by will; 4 Kent #217. If applied to real estate, it en- larges the estate for life into an inherit- ance, and makes the tenant for life a tenant in fee; it makes the tenant for life of personalty an absolute owner; 4 Kent 227. SHELLEY'S CASE, RULE IN. "When the ancestor, by any gift or con- veyance, taketh an estate of freehold, and in the same gift or conveyance an estate is limited, either mediately or immediately, to his heirs in fee or in tail, the heirs are words of limitation of the estate, and not words of purchase." 1 Co. 104.