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In page Trover:
"The preoccupation of detinue with the two special cases of stray cattle and lost title-deeds persisted, and the general problem of recovering chattels which had neither been stolen or bailed was only solved with a new form of writ. This was invented by adding a novel preamble to be inserted in the writ ostensurus quare. This preamble alleged that the plaintiff casually lost possession of the chattel, that the defendant had found it, refused to restore it and converted it to his own use. The full development of trover and conversion is seen by 1510.[6] A discussion of more modern cases of a bailee (holder) in possession of a title-deed is found in Columbia Law Review.[7]
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