The Statute of Uses was not intended to apply to the following classes of uses:

(a) Active uses;

(b) Contingent uses;

(c) Uses in personal property, including estates in real property less than freeholds;

(d) Uses for the use of married women. Furthermore by a decision of the common law judges the purpose of the statute to abolish passive uses was entirely frustrated, and the final effect of the statute was to increase, rather than diminish the scope of the use. This decision of the common law judges was to the effect that a use could not be limited upon a use. This rule can be explained as follows: If A grants land to B for the use of C, for the use of D, the statute operates and transfers the title from B to C; then under this decision, the statute has exhausted its force so far as this transaction is concerned, and cannot operate once more to transfer the legal title from C to D. Equity, however, steps in and carries out the intention of the grantor by compelling C to hold the property for the use of D. The only result, therefore, accomplished by the Statute of Uses, in this respect, was the necessity for the addition of three words to the instrument creating the use.4

After the time of the Statute of Uses, uses came to be generally known as trusts.

4 Tyrrel's Case, 2 Dyer, 155 a; Hopkins vs. Hopkins, 1 Ark., 591; Croxall vs. Shererd, 5

Wall, 268; Hutchins vs. Hey-wood, 50 N. H., 491.