In a recent note, Sir John Baker reports confirmation of the existence of the “Outer Temple,” a tenth inn of chancery in early 15th century England. J.H. Baker, Note, The Inn of the Outer Temple, 124 L.Q. Rev. 384 (2008). In 1973, Professor A.W.B. Simpson reported a 1425 reference to the “Outer Temple,” but found insufficient evidence to determine whether this name referred to an institution or a mere address, though he favored the idea of an institution. A.W.B. Simpson, The Outer Temple as a Legal Inn, 89 L.Q. Rev. 32 (1973). Professor Baker later favored the address theory. J.H. Baker, “The Inner, Middle and Outer Temple,” in J.H. Baker, The Common Law Tradition: Lawyers, Books, and the Law 29 (2000), reprinted in J.H. Baker, An Inner Temple Miscellany 24 (2004). Professor Baker now reports that Professor Jonathan Rose has recently discovered, in the King’s Bench plea rolls, another 15th century reference to the “Outer Temple,” confirming that this name refers to a society of lawyers. Professor Baker concludes that this society was likely the tenth inn of chancery referred to by Sir John Fortescue in De Laudibus Legum Angliae.Image credit: Sir John Fortescue
Update: Professor Rose offers the following clarification: Outer Temple was an Inn of Court like the Middle and Inner Temples and Lincoln and Grays, not an Inn of Chancery. That it was an Inn of Court, although no longer in operation like the others, makes the finding much more significant than had it been another Inn of Chancery.