Thomas of Galloway was earl of Atholl by 7 Jan. 1210 (<em>RRS</em>, ii, no. 489). Henry only witnessed one royal charter, <em>RRS</em>, ii, no. 403 (5 Sept., 1198 × 1203, prob. 1198). Malcolm's last attestations of royal charters date to 1178×95 (<em>RRS</em>, ii, no. 278), 1187×90, perhaps 1187 (_RRS_, ii, no. 273), 1183×1195 (_RRS_, ii, no. 274) and 1175×90 (_RRS_, ii, no. 271). Malcolm was still alive in 1189, as he witnessed a charter of Bishop John of Dunkeld dated 1189×1203 (_Dunf. Reg._, no. 126). Barrow says Henry began term circa 1198 but he could have become earl any time after 1189.
in (free, pure and/or perpetual) alms; of me and my heirs