§ 7. On the Cessation of a Vow (or of Its Obligation) Through Dispensation

420. Definition. Dispensation can be defined: the relaxation of the obligation of a vow, made in the name of God by one having competent jurisdiction. From this definition appears the great difference between dispensation and invalidation. For:

1. Dispensation is made in the name of God, whereas invalidation is made in the name of the one invalidating.

2. Dispensation supposes jurisdiction exercised in the name of God; invalidation, however, requires no jurisdiction, but requires dominative power either over the will of the person vowing or over the thing promised by vow. Hence a woman having dominative power can indeed invalidate the vows of subjects, but can never dispense, as being without ecclesiastical jurisdiction.

3. A just cause is required for a valid dispensation, because dispensation is exercised in the name of God. But the just God cannot approve a dispensation granted without sufficient cause; for valid invalidation, however, no cause is required, as was said above, since anyone can use his dominative power even without cause.

4. The invalidation of a vow can be made against the will of the person vowing himself; but dispensation supposes the consent of him who made the vow, since he imposed upon himself the obligation of the vow. Thus at least if it concerns dispensation from a private vow.

All these things indeed are agreed among all, but it is not so agreed in what precisely the essence of dispensation consists, and whether a legitimate dispensation totally destroys the vow made, or only suspends its obligation.⁴⁴⁵ This indeed seems certain: dispensation is not a mere declaration or interpretation of the non-obligation of a vow. For such a declaration would either be doctrinal, and then it could be made by any prudent man without the power of jurisdiction being necessary, which is false; or it would be authentic, but in the style of the Roman Curia no indication of such an authentic declaration is found. According to modern practice, not only the obligation of the vow but also the vow itself is customarily removed through dispensation.

⁴⁴⁵ Gestaltung einer Ausnahme; cf. Stiegler, Dispensation etc. im Kirchenrecht I, Mainz 1901, 24 and 40.

421. Requisites for dispensing. For dispensing validly two things are required: a just cause and the faculty of dispensing.

1. A just cause is required both for the lawful and for the valid dispensation of a vow, as was already said.

For the one dispensing acts not in his own name (as does the one invalidating), but in the name of God. But a manifest injury would be inflicted upon God if that which had been promised to Him in a vow were not performed without sufficient reason or were removed through a frivolous dispensation. Hence both the one dispensing and the one dispensed sin by employing a dispensation without sufficient cause. The Angelic Doctor,⁴⁴⁶ however, notes that the one dispensed can and ought to acquiesce in the judgment of the dispensing superior concerning the sufficiency of the cause of dispensation (and not in his own judgment), because he himself does not act in the place of God, but the superior does. If, however, the cause of dispensation were evidently insufficient, the subject dispensed could not lawfully use the dispensation thus granted.⁴⁴⁷

What causes are sufficient for dispensing? Innocent III⁴⁴⁸ admonishes that three things are to be attended to in the dispensation of vows: 1. what is lawful according to equity; 2. what is becoming according to uprightness; 3. what is expedient according to utility. In ancient times dispensation (at least in greater vows) was not customarily granted except for public causes and the common good; but in our days all vows are dispensed even for a private cause and good. All causes for dispensing can be reduced to two classes, namely, to the utility of the Church or community and to the utility or necessity of the person vowing. Thus, e.g., a dispensation from a public vow of chastity and other religious vows is granted if a member of some religious institute, because of a dissolute life, causes scandal to the whole community. A dispensation is granted if the person vowing is in grave danger of transgressing the vow; if he suffers a great and unforeseen difficulty in observing the vow; if he is troubled by great scruples because of the vow made; if the vow was made without perfect deliberation or liberty, namely, precipitately or under the influence of fear, even light fear.⁴⁴⁹ Generally speaking, a superior ought not to be too tormented by scruples concerning the sufficiency of a cause for dispensing. For if a subject greatly insists upon obtaining a dispensation and cannot be turned away from petitioning for a dispensation, he is ordinarily already in grave danger of transgressing the vow, and therefore a sufficient cause for dispensing is present. Hence, according to the present discipline, even the Sacred Congregation of Religious grants religious a dispensation from vows if they seriously declare that they are incapable of living any longer in such an institute.

⁴⁴⁶ S. theol. 2, 2, q. 88, a. 12 ad 2.

⁴⁴⁷ St. Alphonsus, Theol. mor. l. 3, n. 251.

⁴⁴⁸ C. 5, X 3, 34.

⁴⁴⁹ St. Alphonsus, l.c., nn. 252-253.

422. 2. The faculty of dispensing from vows certainly belongs to the Church; this is established both from Sacred Scripture and from the perpetual practice of the Church.

Christ, speaking to Peter, said: "I will give to thee the keys of the kingdom of heaven. And whatsoever thou shalt loose upon earth, it shall be loosed also in heaven."⁴⁵⁰ Since these words are general, they must be understood concerning every bond which man can contract toward God. And in truth, just as in the name of God the Church can remit sins and the punishments of sins, although God has a strict right of exacting satisfaction and punishment for sins, so a fortiori the faculty of remitting for just causes an obligation arising from a vow belongs to the Church. This faculty of dispensing has also always been in use in the Church from the most ancient times. In the first centuries there did not indeed occur so many dispensations from vows, but the Holy Fathers knew them, which were sometimes called absolution or oikonomia.⁴⁵¹ But it would be rash and indeed heretical to assert that the Church for so many centuries had usurped for itself a power which does not belong to it.

In the Church this faculty of dispensing is exercised by: 1. the Supreme Pontiff with respect to all the Christian faithful; 2. the local Ordinary and the superior of an exempt clerical religious institute⁴⁵² with respect to their own subjects, yet with dependence upon the Supreme Pontiff and with certain limitations; 3. all who have legitimate delegation. Since the faculty of dispensing supposes not the power of orders but ecclesiastical jurisdiction, whoever is capable of ecclesiastical jurisdiction can also (at least by delegation) exercise the faculty of dispensing.

⁴⁵⁰ Matt. 16:19.

⁴⁵¹ Cf. Stiegler, l.c., 3ff.

⁴⁵² Code of Canon Law, c. 1313.

423. The Supreme Pontiff, having the most ample jurisdiction, also has the most ample faculty of dispensing from vows. Hence St. Thomas⁴⁵³ says: "Because the Supreme Pontiff acts fully in the place of Christ in the whole Church, he has the plenitude of the power of dispensing in all dispensable vows." Therefore the Angelic Doctor seems to suppose that not all vows are dispensable. And in truth there is a difficulty concerning how the Pope can dispense 1. from solemn vows; 2. from vows made for the utility of a third person.

Solemn religious vows consist in a certain consecration and are probably of divine law, as was said above in n. 391. For this reason, in the thirteenth century, the doctors (thinking that a thing once consecrated could no longer be desecrated if it remained intact) denied to the Supreme Pontiff the faculty of dispensing from solemn vows. Indeed, Innocent III himself,⁴⁵⁴ speaking of the dispensation of vows of this kind, wrote: "Nor should the abbot think that he can dispense with some monk concerning the possession of property; because the renunciation of property and the custody of chastity are so annexed to the monastic rule that not even the Supreme Pontiff can grant permission against it." St. Thomas,⁴⁵⁵ St. Raymond,⁴⁵⁶ St. Bonaventure,⁴⁵⁷ Blessed Albert the Great,⁴⁵⁸ and many others defend this opinion. Nevertheless, it is certain that the Supreme Pontiffs have often granted permission that religious of either sex, after solemn profession had been made, might lawfully and validly enter marriage. Indeed, Leo XIII⁴⁵⁹ gave a general faculty of dispensing with the dying who, notwithstanding solemn vows, attempted marriage; this faculty the Code of Canon Law, cc. 1043-1045, has further enlarged. But it is rash to assert that so many Supreme Pontiffs arrogated to themselves some power of dispensing which in no way belongs to them. Even before the times of St. Thomas and St. Bonaventure, certain Supreme Pontiffs are said to have permitted marriage to solemnly professed religious; e.g., Celestine III permitted the nun Constance, daughter of Roger of Sicily, to marry Emperor Henry VI; Benedict IX is said to have made a similar concession to Casimir, King of Poland, and Ramiro, King of Aragon.⁴⁶⁰

Vows made in favor of some third person (whether physical or moral), e.g., a vow of giving alms to a determined person, not even the Supreme Pontiff can of himself dispense if that person has accepted the promise confirmed by the vow and is not subject to the dominative power of the Pope. The reason is that through such a dispensation the strict acquired right of the third party, and consequently natural law itself, would be injured. In the following cases, however, the Pope and his delegate can dispense even from vows made for the utility of a third party:

1. if that third party has freely renounced his right. This is evident of itself, since then no injury of a right is now present.

2. if that third party is a religious person or an ecclesiastical institute. For the Supreme Pontiff has full administration of ecclesiastical goods and consequently can, for sufficient reasons, dispose of the rights of all religious (professed) and ecclesiastical institutes.

3. if the promise was gratuitous and not yet accepted by that third person. For then there intervenes only the obligation of a vow and not of justice. But the Pope can dispense from the obligation of a vow. Hence, e.g., if someone vowed to give a stipend for one hundred Masses to be said for the relief of the dead, the Pope or his delegate can dispense from a vow of this kind, since acceptance of the vow cannot be made by the dead. The same applies if someone vowed to give one hundred marks to undetermined poor persons.⁴⁶¹

4. if the promise was gratuitous and principally in honor of God and only secondarily for the utility of a third person. Thus at least according to an opinion both intrinsically and extrinsically probable. The reason is that then the utility of one's neighbor is something secondary and accidental, which ought to follow the condition of the principal thing, namely, the vow, which is dispensable.⁴⁶²

From the things thus far said, it appears clearly that in practice scarcely any vow exists from which the Pope cannot grant a dispensation for a just cause.

⁴⁵³ S. theol. 2, 2, q. 88, a. 12 ad 3.

⁴⁵⁴ C. 6, X 3, 35.

⁴⁵⁵ S. theol., l.c., a. 11.

⁴⁵⁶ Summa l. 1, tit. 8, § 9.

⁴⁵⁷ IV, dist. 38, q. 3.

⁴⁵⁸ In IV, dist. 38, a. 18.

⁴⁵⁹ 20 Feb. 1888.

⁴⁶⁰ These dispensations are rejected as apocryphal by several authors; cf. Billuart, De relig. diss. 4, a. 9.

⁴⁶¹ Cf. Billuart, ib., a. 8, § 6.

⁴⁶² Cf. St. Alphonsus, Theol. mor. l. 3, n. 255.

424. On vows reserved to the Supreme Pontiff. The Supreme Pontiff has reserved to himself the faculty of dispensing from several vows, which are:

1. Almost all public vows.

Such public vows are: a) all solemn vows made in religious orders and in the reception of the subdiaconate. Although the Supreme Pontiff has sometimes dispensed so that priests who had attempted an invalid marriage could convalidate the marriage, e.g., at the time of the English schism and the first French Revolution, nevertheless no example (publicly known) exists in which the Supreme Pontiff granted to a priest of the Latin rite that he could enter a new marriage. b) All simple vows made in religious institutes approved by the Holy See. It makes no difference whether these vows are perpetual or temporary. Hence, e.g., a member of such a religious institute having vows lasting for three or five years can be dispensed from these vows before the time of obligation has elapsed by no one except the Supreme Pontiff or his special delegate.⁴⁶³ But when someone having temporary simple vows (whether in an order in which solemn vows are made or in a religious congregation) is legitimately dismissed from religion by the superiors,⁴⁶⁴ his simple vows cease by that very fact.⁴⁶⁵ But when someone simply professed and having perpetual vows is legitimately dismissed, he is not by that very fact dispensed from his vows, but must still seek a special dispensation from the vows. Thus at least by common law, whatever may be the case concerning privileges granted to some particular institute.⁴⁶⁶

Note. Public vows are sometimes not reserved to the Holy See. For with an indult of secularization, which in religious institutes of diocesan right can also be granted by the local Ordinary, public religious vows cease by that very fact.⁴⁶⁷ Likewise with the dismissal of a religious who has pronounced temporary (but not perpetual) vows,⁴⁶⁸ as was already said.

2. Two private vows, namely: a) of perfect and perpetual chastity; b) of entering an approved religious institute with solemn vows, provided these two vows were made absolutely and after the completion of the eighteenth year of age.⁴⁶⁹

Since reservation, which is considered in canon law an odious matter, is of strict interpretation, these two vows do not fall under reservation unless they are perfect both on the part of the matter and of the manner.

The matter of the vow is considered perfect if precisely that which is reserved in the two vows was promised. Hence there do not fall under reservation: a vow of virginity, a vow of not marrying, a vow of temporary chastity, a vow of receiving holy orders, a vow of entering some religious institute with simple vows only. The reason is that all these vows are neither a vow of perfect chastity nor of entering religion with solemn vows. In practice a doubt not rarely arises whether a member of the faithful made a vow of perfect chastity or only of virginity. Then it must first be investigated whether the person vowing principally intended the celibate life or rather perfect chastity of body and mind. If the former, the vow is not reserved; if the latter, the vow is of perfect chastity and therefore reserved.

The manner of these vows is considered perfect when they were made absolutely and with perfect liberty. Hence reservation is not present:

a) if such a vow was made with a condition concerning a future contingent event, e.g., I vow entrance into the Franciscan religious institute if I recover health. But when a condition concerning a necessary future event, or concerning the past or present, was attached, the vow is only apparently conditional and therefore in truth is absolute once the condition has been verified. Hence, e.g., once the condition has been verified, the following vow is absolute and reserved: I vow perfect chastity if my father perished in this shipwreck.

b) if the vow was disjunctive or penal; e.g., I vow either entrance into religion or the reception of holy orders; if I contract the habit of drunkenness again, I vow entrance into the order of Trappists.

c) if the vow was made under the influence of fear, even light fear;⁴⁷⁰ e.g., a girl vowed entrance among the Poor Clares in order to avoid a marriage into which her parents wished to compel her under light fear.

d) if the person vowing expressly intended to impose upon himself only a light obligation. The reason is evident, since the violation of such a light obligation is a light sin, which cannot be the matter of reservation. Hence, if someone vowed under a light obligation perpetual chastity or entrance into religion, his vow is not reserved.

e) if the person vowing had not yet completed eighteen years of age.

Note. When these two vows have been commuted by legitimate authority into other pious works, the matter thus commuted no longer falls under reservation. Hence, e.g., if a girl, after making a vow of perfect chastity and obtaining a commutation of this vow, is bound to say the Rosary daily, any confessor having the privileges of the Mendicants can now for a reasonable cause dispense from this obligation of saying the Rosary.⁴⁷¹

⁴⁶³ Const. Conditae II; Normae, art. 112.

⁴⁶⁴ The manner of this dismissal was newly determined by the Code of Canon Law, c. 647.

⁴⁶⁵ Code of Canon Law, c. 648.

⁴⁶⁶ Ib., c. 669.

⁴⁶⁷ Ib., cc. 638 and 640.

⁴⁶⁸ Ib., c. 648 and c. 669, § 1.

⁴⁶⁹ Ib., c. 1309.

⁴⁷⁰ Cf. St. Alphonsus, Theol. mor. l. 3, n. 258.

⁴⁷¹ Cf. St. Alphonsus, Theol. mor. l. 3, n. 260.

425. The local Ordinary and other prelates having quasi-episcopal jurisdiction (such as the superiors of an exempt clerical religious institute for their subjects, even those not professed) can not only dispense for a just cause from all other non-reserved vows, but also from the two reserved private vows:

1. when there is an urgent necessity and recourse to the Supreme Pontiff is morally impossible.⁴⁷² Such a case can easily occur when all things are prepared for a marriage which cannot be deferred without great inconvenience, and it is discovered that one of those about to marry is bound by a vow of perfect chastity. Then the local Ordinary can dispense from the vow of chastity.⁴⁷³

2. when it concerns a vow of imperfect chastity (i.e., of not seeking the conjugal debt) made after marriage was contracted. The reason is that such a vow is not of complete chastity, since it cannot oblige one not to render the debt. But if it concerns a vow of perfect chastity, i.e., of neither seeking nor rendering the conjugal debt, a bishop cannot dispense by his own authority unless there is grave danger in delay.⁴⁷⁴ A spouse cannot make such a vow of perfect chastity unless a) with the consent of the other spouse; b) unless the other spouse has lost the right of seeking the debt, e.g., because of adultery committed.

3. when it concerns doubtful vows.

4. when they have special delegated faculties, as is sometimes customary in our times. Therefore a confessor lacking the faculty of dispensing from some vow better seeks this faculty through the diocesan bishop, who can almost always grant it.

Note. The local Ordinary can dispense from vows not only with his own subjects but also with travelers.⁴⁷⁵ But if he grants a dispensation by virtue of special faculties, attention is to be paid to the clauses which may exclude travelers from the dispensations to be granted.

⁴⁷² Cf. St. Alphonsus, l.c., n. 258.

⁴⁷³ Cf. ib., l. 6, n. 987, and Code of Canon Law, c. 1045.

⁴⁷⁴ Cf. St. Alphonsus, Theol. mor. l. 6, n. 986.

⁴⁷⁵ Code of Canon Law, c. 1313.

426. Regular confessors having the privileges of the Mendicants can dispense, either within or outside confession, from all vows. Reserved vows (cf. above, n. 424) are excepted, and moreover those made principally for the utility of a third party and accepted by him. Thus the most common opinion.⁴⁷⁶

This opinion is founded upon several privileges granted by the Supreme Pontiffs. Thus, e.g., Julius II granted to the regulars of St. Savior and the Olivetan monks "that those appointed to hear the confessions of secular persons may absolve them from each and every sin ... and commute vows made by them for the time being, in each and every case reserved to local Ordinaries, even by synodal or provincial constitutions, into other works of piety, and moreover dispense the same persons vowing from them."⁴⁷⁷ The same faculty was granted by the same Pontiff to other canons regular through the Constitution Inter ceteros; Leo X granted the same to the Camaldolese hermits.⁴⁷⁸ But because other Pontiffs, such as Benedict XIII⁴⁷⁹ and Leo XII,⁴⁸⁰ speak only of the faculty of commuting vows, certain authors (Billuart, Concina, Mocheggiani) deny to regular confessors the faculty of dispensing from vows. Let Concina be heard, who most vehemently of all asserts: "The opinion which grants to regulars the privilege of dispensing from all vows not reserved to the Supreme Pontiff is false."⁴⁸¹ Concina indeed concedes that very many authors teach the contrary, but too confidently adds: "Among so many authors I have found no one who seriously discusses the controversy; but one trusts in the authority of another, and as one bird follows other birds, some follow others; and finally all defend themselves by their multitude, as though multitude could patronize error." Certainly the multitude of authors alone cannot make error become truth, but it is rather rash to assert that among so many and such great authors no one seriously discussed the controversy. The common opinion teaching that regular confessors enjoy the faculty of dispensing from all vows, except vows both reserved and made principally for the utility of a third party, seems safe in practice. For Sixtus IV,⁴⁸² Julius II,⁴⁸³ Innocent VIII,⁴⁸⁴ and other Supreme Pontiffs simply grant this faculty of dispensing. These indults afterwards became "privileges confirmed by bull," since they were confirmed by the Supreme Pontiffs in special form or from certain knowledge. In such form, e.g., Gregory XIII⁴⁸⁵ confirmed all the privileges of the Franciscans. But if other Pontiffs grant regulars the faculty of commuting vows, it is in no way lawful to conclude from this that they denied or revoked the faculty of dispensing. For the word dispensing is not employed in one sense either in the old Corpus iuris or by older and modern canonists, as I proved elsewhere.⁴⁸⁶ Moreover, St. Alphonsus⁴⁸⁷ teaches without any hesitation that regular confessors can dispense from non-reserved vows. But in practice a confessor can always follow the opinions of St. Alphonsus which have not been expressly revoked by the Apostolic See.

G. Oesterle, O.S.B.,⁴⁸⁸ discusses this matter excellently and learnedly, and also vigorously rejects the opinion of the adversaries. Moreover, this controversy is of almost no practical value, since ordinarily in practice it is expedient not to dispense totally, i.e., to relax, but to commute the vow into an easier work. But all teach that regular confessors can commute non-reserved vows.

⁴⁷⁶ St. Alphonsus, Theol. mor. l. 3, n. 257; Ferraris, Prompta Bibl., s.v. "vow," III, 77; Reiffenstuel, Ius can. l. 3, tit. 34, n. 39; Noldin, De praeceptis n. 237; Vermeersch, De relig. inst. n. 519 and Periodica V, 57ff.

⁴⁷⁷ Const. Etsi ad universos.

⁴⁷⁸ Const. Etsi a summo.

⁴⁷⁹ Const. Pretiosus.

⁴⁸⁰ Const. Plura inter.

⁴⁸¹ Theol. christ. l. 4, In Decal., diss. 3, c. 11, n. 16.

⁴⁸² In the indults both for the Minims, dated 27 May 1474, and for the Benedictines, dated 8 June 1476.

⁴⁸³ Cf. the text cited above.

⁴⁸⁴ In the indult for the Franciscans, 1487.

⁴⁸⁵ Const. Ex benigna, 21 March 1578.

⁴⁸⁶ Commersches Jahrbuch XXII, 605ff.

⁴⁸⁷ Theol. mor. l. 3, n. 257.

⁴⁸⁸ In Theologie und Glaube 1911, 389ff.

427. Whether regular confessors in a case of urgent necessity can dispense from a vow of perfect chastity with a view to contracting marriage was disputed by authors. But now, in a case in which all things are already prepared for the marriage and the marriage cannot be deferred without probable danger of grave evil until a dispensation is obtained from the local Ordinary, not only a regular confessor but any confessor (as also the pastor and the priest assisting at the marriage) can dispense from the vow of perfect chastity and other vows impeding marriage, provided that it concerns an occult case.⁴⁸⁹

Regular confessors can partially dispense from a vow of chastity, after marriage has already been contracted, so that the conjugal debt may be sought, when the other spouse made such a vow before marriage. But if such a marriage should be dissolved by the death of the other spouse or in another manner, the vow thus dispensed revives in the one who made it. Indeed, if one thus dispensed, during the marriage, were to commit a grave sin against chastity, e.g., pollution, adultery, etc., there would be a grave violation of the vow, and therefore not only the sin of lust itself but also the violation of the vow would have to be declared in confession.⁴⁹⁰

Pastors and other ordinary confessors have no power of dispensing from vows except a) from particular indults, or b) during a jubilee, or c) in the case indicated in the preceding number, namely, with a view to contracting marriage.

⁴⁸⁹ Code of Canon Law, c. 1045.

⁴⁹⁰ Cf. St. Alphonsus, l.c., and l. 3, n. 258.

428. Concerning the exercise of the faculty of dispensing, the following things are to be noted:

1. It is lawful to use this faculty both within and outside the tribunal of confession, unless, however, the contrary is expressly determined.

It is very fitting, however, that a dispensation ordinarily not be granted except in the confessional; hence special faculties of dispensing almost always customarily include this or a similar clause: "for the forum of conscience and in sacramental confession."

2. One who possesses a faculty of dispensing of this kind can also use it with himself, since it is an act of voluntary jurisdiction,⁴⁹¹ unless, however, it is prescribed that the dispensation be given in the tribunal of confession.

For no one can appear before himself in the tribunal of penance. In practice it is always better to seek the dispensation of a vow from another who has the power, since no one ought to be judge in his own cause and one is easily deceived concerning the sufficiency of the cause necessary for dispensation.

3. One who can dispense from vows can also dispense from sworn vows.

The reason is that an oath, as something accessory to the vow in this case, is dissolved with the dissolution of the vow.⁴⁹² But a promissory oath by itself alone is never reserved.⁴⁹³ This formula: "I promise, vow, and swear," is considered to contain only an oath and not a vow.

4. Bishops can dispense also from the vows of travelers, as was already said above in n. 425. Regular confessors likewise can dispense from the vows of travelers, because they act by delegation of the Roman Pontiff, to whom no member of the faithful is a traveler.⁴⁹⁴

5. In every dispensation that saying of Innocent III already cited above is to be attended to: "What is lawful according to equity, what is becoming according to uprightness, and what is expedient according to utility"; or, a vow is to be dispensed only when the honor of God is preserved and provision is made for the spiritual utility of the person vowing. The sufficient causes of dispensation were already discussed above in n. 421.

6. It is rarely expedient to remove the whole obligation of a vow by dispensation--this is expedient almost only with the scrupulous--but it is better to commute the vow, i.e., to impose some more suitable matter. For thus the person vowing does not lose the whole merit of the vow and acquires the new merit of obedience.

⁴⁹¹ Cf. ib., l. 3, n. 256.

⁴⁹² Cf. below, n. 454.

⁴⁹³ Hence St. Alphonsus (l.c., n. 250) teaches that an oath of perfect chastity or of entering religion, unless it includes a vow at the same time, is not reserved.

⁴⁹⁴ Thus Lehmkuhl, Theol. mor. I, n. 620.