Forty-shilling freeholders were those who had the parliamentary franchise to vote by virtue of possessing freehold property, or lands held directly of the king, of an annual rent of at least forty shillings (i.e. £2 or 3 marks), clear of all charges. The qualification to vote using the ownership and value of property, and the creation of a group of forty-shilling freeholders, was practiced in many jurisdictions such as England, Scotland, Ireland, the United States of America, Australia, and Canada. Montfort's Parliament During the Second Barons' War, Simon de Montfort, 6th Earl of Leicester instigated the English parliament of 1265, without royal approval. Simon de Montfort's army had met and defeated the royal forces at the Battle of Lewes on May 14, 1264. Montfort sent out representatives to each county and to a select list of boroughs, asking each to send two representatives, and insisted the representatives be elected. Henry III rejected the new Parliament and resumed his war against Montfort, who was killed later that year at the Battle of Evesham, but the idea of electing Knights of the Shire as representatives of the counties, and burgesses from the boroughs, became a permanent feature. In 1430, legislation limited the franchise to only those who owned the freehold of land that brought in an annual rent of at least 40 shillings (forty-shilling freeholders). For comparison: In the mid 1340s, a knight received a daily pay of two shillings while on campaign, an ordinary man-at-arms the half of it, a foot archer was paid two or three pence (12 pennies to the shilling and 20 shillings to the pound). A war-horse could value from five to 100 pounds. The legislation did not specify the gender of the property owner, however the franchise became restricted to males by custom. In subsequent centuries, until the 1832 Great Reform Act specified 'male persons', a few women were able to vote in parliamentary elections through property ownership, although this was rare.