Papal Bull of 1208, The acts of the Parliament of Scotland, Vol. 1, 1844, p. 391 et seq.

'A papal bull issued to the Bishop of Monary in 1208 appointed him arbiter in a cause between the monks of Melrose and the Earl of Dunbar, and the parties agreed to assign a colleague to the bishop in the arbitration.' (Walker, David M., A Legal History of Scotland, 1990, p. 372)