for  life  and  then  to  the  heirs  of  his  body,  their  heirs  and  assigns,  the
added  words  were  ineffectual  to  obviate  the  rule  in  Shelley's  Case,
"Heirs  of  the  body,"  being  usable  only  to  create  an  estate  in  tail,  could
not  be  descriptive  of  coexistent  persons  who  on  the  death  of  the  donee
for  life  could  then  answer  as  the  heirs  of  his  body,  and  whose  estate
would  be  defined  by  the  added  words  "their  heirs  and  assigns"  as  a  re-  ^
mainder  in  fee  simple.  The  application  of  the  rule  in  Shelley's  Case  to
this  last  supposed  deed  (Wright  v.  Pearson,  1  Ed.  119,  Measure  v.  Gee,^
5  B.  &  Aid.  910)  is  entirely  consistent  with  the  rule  in  Archer's  Case
where  primogeniture  prevails.  Bayley  v.  Morris,  4  Ves.  Jr.  788;  Ev-
ans V.  Evans  [1892]  2  Ch.  173.  But  in  Illinois,  and  in  this  country
generally,  where  the  surviving  children  as  tenants  in  common  stand  for
the  surviving  eldest  son,  "heirs"  may  have  different  meanings,  just  as-
under English  law  the  singular  form  "heir"  might  have  different  mean-
ings. If  there  is  no  context,  "heirs"  must  be  held  to  indicate  the  in-
definite succession  by  inheritance,  and  Shelley's  Case  applies.  But  a
context  may  demonstrate  that  "heirs"  was  a  description  of  purchasers
who  should  constitute  a  new  stock  of  descent.  iEtna  Life  Ins.  Co.  v»
Hoppin,  249  111.  406,  94  N.  E.  669,  whefe  Archer's  Case  was  relied  on.
And  see,  also,  De  Vaughn  v.  Hutchinson,  165  U.  S.  566,  17  Sup.  Ct,
461,  41  L.  Ed.  827 ;  De  Vaughn  v.  De  Vaughn,  3  App.  D.  C.  50;  Daniel
V.  Whartenby,  17  Wall.  639,  21  L.  Ed.  661 ;  Dott  v.  Willson,  1  Bay  (S.
