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The partition by a complex [wavy] line at present automatically frees a device from the restriction on quartering and so this device is legitimate, although certainly suggestive of the intent to quarter. It is the more disturbing since a number of Continental jurisdictions regularly quarter with one or both of the partition lines being a complex line such as wavy or embattled. (LoAR 25 Jan 87, p. 13)
As long ago as July, 1980, it was ruled that the use of ordinaries cut off by the quartered division would create the presumption of quartering and thus compel return of a device. (LoAR Aug 87, p. 11)
Introduction and Index to Precedents of Alisoun MacCoul of Elphane