On 14 April 1937, Attorney General Sir Donald Somervell submitted to Home Secretary Sir John Simon a memorandum summarizing the views of Lord Advocate T. M. Cooper, Parliamentary Counsel Sir Granville Ram, and himself: We incline to the view that on his abdication the Duke of Windsor could not have claimed the right to be described as a Royal Highness. In other words, no reasonable objection could have been taken if the King had decided that his exclusion from the lineal succession excluded him from the right to this title as conferred by the existing Letters Patent. The question however has to be considered on the basis of the fact that, for reasons which are readily understandable, he with the express approval of His Majesty enjoys this title and has been referred to as a Royal Highness on a formal occasion and in formal documents. In the light of precedent it seems clear that the wife of a Royal Highness enjoys the same title unless some appropriate express step can be and is taken to deprive her of it. We came to the conclusion that the wife could not claim this right on any legal basis. The right to use this style or title, in our view, is within the prerogative of His Majesty and he has the power to regulate it by Letters Patent generally or in particular circumstances.