The almost total denial of property rights to a married woman under the common-law system was modified in equity by the doctrine of separate estate. Originally this was given effect by conveying to trustees property of which a married woman was made the beneficiary.14 Though it remained customary to convey the property to trustees, it became also permissible to make the conveyance directly to the married woman for her separate use. A court of equity would then compel her husband to hold the legal estate, which he took by virtue of the common-law rules, in trust for his wife for her separate use. As to property held to the separate use of a married woman, courts of equity gave her a limited power of contracting and charging it. In order that a contract should bind the separate estate, it was necessary that it should have been made with reference to the separate estate or that either from express language or otherwise the courts should find a purpose to charge the separate estate.15 In order to protect married woman from improvident dispositions of their separate property, it became usual in settlements of property on married women to add a clause restraining them from "anticipation." The effect of this clause was to deprive the woman of power to alienate or charge the property.16 The restraint might be confined to the principal or it might extend also to the income.17