These notes are based on the Home Office documents of the National Archives listed at the end.
The general principle is that the Sovereign is the Fount of Honor. For official purposes, only titles granted or recognized by the Sovereign exist.
The basic reason why the sovereign might not wish to authorize British subjects to bear foreign titles is the "divided loyalty" argument, expressed by Queen Elizabeth I in the famous Arundell of Wardour case in 1597. Thomas Arundell had distinguished himself in the service of the Emperor at the capture of Esztergom (Hungary) in 1595, and was made count of the Holy Roman Empire. The Queen disapproved, and famously said (William Camden: The historie of the life and reigne of that famous princesse Elizabeth, 1634, p. 174):
Curiously, 17th century writers considered that the highest and lowest dignities being universal, a king was recognized as king everywhere, and also a knight: "though a Knight receive his Dignity of a Foreign Prince, he is so to be stiled in all Legal Proceedings within England .. and Knights in all Foreign Countries have ever place and precedency according to their Seniority of being Knighted" (John Logan, Analogia honorum, 1677, p. 111-112); "A Knight of any foreign Nation, shall be so named in all our Courts of Pleas, (for the highest and lowest dignities are universal) 26 Edward 4 39 Edward 3" (William Sanderson, A compleat history of the lives and reigns of, Mary Queen of Scotland, and of her son and successor, James the Sixth, King of Scotland, p. 213-214).
The practice of granting Royal Licences to bear foreign titles goes back at least to the 17th century at least, the earliest known instance being 1644 (see a list of all licences granted between 1644 and 1923).
The matter of foreign titles and decorations received by British subjects became more important in the 19th century, in particular in the aftermath of the Napoleonic Wars, during which many British subjects rendered services abroad and were distinguished by titles and decorations. From 1812, specific and stringent rules were established for foreign orders and medals, to be administered by the Foreign Office. As for titles, they were referred to the Home Office who forwarded the applications to the sovereign for approval, with or without recommendations.
The general principle was enunciated by Garter king of arms in 1836:
It is difficult to determine on what basis the petitions were handled. After the batch of foreign titles related to the Napoleonic wars, there are only three applications that were approved between 1832 and 1882: Rothschild, Goldsmid da Palmeira, and Worms. The first was one of the five Rothschild brothers: his son became a baronet in 1847 and his grandson the first Jewish peer in 1885. Isaac Lyon Goldsmid was the first Jewish baronet in 1841, in recognition of his charitable work. Solomon Worms, who owned vast tea plantations in Ceylon, was nephew of Nathan Rothschild; his son became baron in 1895. It is striking that all three men were from the world of Jewish banking.
Short of a complete search through the registered correspondence of the Home Office, it is difficult to have a precise account of all the cases presented, but a register, in the Foreign Office archives contains all the applications received by the F.O. between 1822 and 1875, and referred to the H.O. (I have supplemented the list with entries from the NA's catalogue). Those that were turned down follow:
The following applications between 1893 and 1930 were turned down or not recommended:
According to later HO documents, for 30 years or so prior to 1892, the practice in dealing with these applications was for the Home Office not to inquire into the reason why a Foreign Monarch chose to grant a title to an Englishman but to issue a licence on production of evidence of British nationality and of documents establishing the applicant's right to the title. The Home Office had no principles laid down to guide it in discriminating between such applications, and felt a good deal of difficulty about undertaking to examine the merits of individual cases. In the absence of a compilation of the records, it is difficult to say, but it may well be that few applications were turned down during that period.
In 1893 Sir E. Pemberton (legal assistant under-secretary at the Home Office) suggested that, in order to avoid the difficulty of a Home Office inquiry into each case, the Home Office and Foreign Office should, with the Queen's approval, draw up a code of regulations which might be applied to all petitions for licences but it was considered undesirable to make a fresh departure on the case under review (Baron de Kusel, Italian title, Licence granted).
In September, 1893, the matter was again considered on the case of
Lowenstein (Baron, Portugal), which was seen as particularly worthy
of refusal (the British ambassador to Portgual claiming that titles
in that country went to the highest bidder). The Queen then approved the following
rule
drawn up by Mr. Asquith :-
This rule was confirmed by king Edward VII in 1901 and by King George V in 1911. According to A. J. Eagleston, for the rare occurences "the reason for which the title was originally given must have weight". Sometimes the exceptions were decided by the sovereign without any reasons given to the Home Office (baron Boxall, baron de Forest, although H.O. eventually found out the circumstances of the former grant). When H.O. gave a favorable recommendation, it was usually on account of services rendered and the antiquity of the title.
The matter of papal titles came up with increasing frequency in the early 20th century. In 1864, recognition of a papal title of count held by a Maltese was refused on the grounds that "it would be undesirable to afford any encouragement to the conferring of foreign titles on any of the residents in Malta." After 1870, the Pope's status in international law was more dubious, and the UK took the line that he was not a sovereign. When the matter was considered at length in 1912, George V took that view: "The King quite agrees that the application should be refused, not of course on the Roman Catholic point, but because the Pope not being an independent Sovereign has no power to confer Titles and Orders ... The Duke of Cumberland or King Manuel of Portugal might just as well claim the right to do so" (this last bit may not be a direct quote).
The general rise in anti-German feeling during World War I, which
eventually forced the Royal Family to relinquish the use of its German
titles, also affected the use of foreign titles in Britain. In
July 1916, a question was raised on this point in the Commons (from the
Times of Jul 14, 1916,
p. 10):
The problem, in this instance, is that the title of "baron" had been included in the certificate of naturalization. Home Office had no clear rule for inclusion of foreign titles upon naturalization, a request sometimes made by the applicant. After the Erlanger case, the Secretary of State Herbert Samuel decided in July 1916 that, henceforth, naturalisation of an alien with a foreign title whould be made conditional on his abandonment of the title, unless he obtains official recognition by Royal licence. This took the form of an undertaking "that the applicant on her naturalization will cease to use the title of --- and will not resume the use unless and until she obtains a Royal Licence authorising her to do so". At first this was only asked of bearers of titles conferred by enemy countries (Germany and Austria), while titles from other countries were simply ignored; but it was extended by 1922 to all titles.
Home Office officials were uncomfortable with the procedure, however.
Although Home Secretary Samuel thought it would be possible to revoke
a naturalization if the recipient violated his undertaking and resumed
the use of his title without royal license, officials expressed misgivings.
Grounds for canceling a certificate were fraud and misrepresentation:
how could there be fraud or misrepresentation about an intention? Breach
of contract (which is what violation of the undertaking was closest to)
was not the same thing as fraud.
Home Office recognized that "there is nothing in law to prevent the
use of foreign titles either by
natural born or naturalized British subjects if they have in fact a
right to such titles": all that could be done was to inform them that
there could be no official recognition without Royal Licence, but use
of the title for "general" or "social" purposes could not be
prohibited, and it was doubtful that such use could be grounds for
revoking the naturalization certificate. In 1924 arose a case
where the requirement was mistakenly forgotten, and the lady (a
baroness) protested that her title did not appear on her
certificate.
After the armistice (but while Britain was still technically at war with Germany), the Lord Chamberlain contacted the Home Office about the case of two ladies licenced to bear German titles who were asking for an invitation to a royal garden party with their titles. The problem had been raised in 1915 when baron Nugent (an Austrian title) applied for a Royal Licence: it was then decided not to do anything about enemy titles, and the Licence was granted. In the meantime, in 1917, the Royal Family had relinquished its titles. In June 1919, the Home Secretary opined that it was undesirable to receive the ladies at Court under their German titles.
After a list of such titles was drawn, the King was asked for his pleasure, and he decided that the Licences should be revoked, but that the holders should be first given an opportunity to relinquish them voluntarily. Some holders resisted, but in the end they all relented, and a warrant was issued on Jan 17, 1920 revoking the licences, ostensibly at the request of the holders (note that one of them, the former count von Gurowski, unsuccessfully applied to resume his title later in the 1920s: HO 45/12943).
Civil servants at the Home Office were nevertheless troubled by the general question of foreign titles, and the fact that they did not have a complete listing. Throughout the 1920s, a major effort was undertaken to establish as complete a list of Royal Licences as possible. The greatest difficulties were encountered when trying to secure the College of Arms' cooperation (as for Ulster king of arms, he proved utterly worthless). Finally, in May 1930, a complete list had been drawn, and it was printed and distributed to the Lord Chamberlain's office and to various other officials.
Curiously, the proximate cause of the warrant of 1932, which put an end to the acceptance of foreign titles in the UK, was the Lateran Treaty of 1929. This treaty between Italy on one hand, the Holy See on the other, deprived the British government from the pretext that the Pope was not a sovereign power. No matter how small the Vatican City State, it was now necessary to accept that the Pope could confer titles.
The Home Office suggested that this was an opportunity to settle the matter of foreign titles once and for all. Changing the policy necessarily raised the question of how to handle existing licence holders: with a complete list in hand for the first time, they could be deal with comprehensively. Arthur Eagleston wrote a lengthy memo outlining why licences should not be granted anymore. Beside the "divided loyalty" argument, there were practical considerations: foreign titles might be confused with British titles (indeed, such confusion was part of their attraction), determining rules of descent was difficult, recording successions and deciding disputed claims was not practicable (the heralds being in charge of recording the licences).
The suggestion was made to the king, and he agreed in May 1930 that no further licences would be granted, and asked for some way to deal with existing licences. In July 1930, the king made his decision: the use of foreign titles by British Subjects was abolished and that no further recommendations for Royal Licences were to be submitted to him. In the case of the existing holders of Royal Licences, the use of the title was allowed during the lives of the present holders, their heirs, and their heir's heir, provided such heir's heir was alive at the time.
It initially was decided to proceed as in 1920 with the "enemy" titles. All
holders of the 14 existing licences were contacted and informed of the
pending decision, so that they might raise any objections and be given
an opportunity to acquiesce in advance to the inevitable. The
correspondance lasted a very long time (it took a while to find all the
holders of the Bentinck title), and many difficulties were
raised. In the end, the warrant issued on April 27, 1932.
It purely and simply withdrew the royal licences, only allowing the use
of the title to current holders, their heir (if any was born) and their
heir's heir (if any was born). Thus, some individuals were
literally grandfathered in.
Since 1932, no more licences have been issued; as for naturalization applicants, their solicitor was informed that "if your client becomes a British subject, his (her) foreign title will not receive official recognition in this country and that in accordance with the established practice it will be omitted from the certificate, if granted. I am to request that your client, or you on his (her) behalf, will specifically acknowledge his (her) acceptance of this position." A variant of this formula is still in use by the Home Office today.
What follows is the schedule from the Warrant of April 27, 1932 listing the authorized titles; to which I have added birth and death dates from the usual sources (Burke, Debrett, The Times, etc). As far as I can tell, authorized holders of foreign titles still alive include, at most, seven individuals:
| Present Holder (1) |
Dignity (2) |
Title (3) |
Date of
Warrant (4) |
Son of Holder (5) | Grandson
of
Holder (6) |
|---|---|---|---|---|---|
| William Frederick Charles Henry Bentinck [1880-1959] |
Count of the Holy Roman Empire | Count Bentinck | 22nd April, 1886 | ||
| Charles
Henry
Bentinck [1879-1955] |
"
|
Count Charles Bentinck | " | ||
| Arthur
William
Douglas Bentinck [1887-1962] |
" | Count Arthur Bentinck | " | ||
| Norah Ida Emily Bentinck [†1939] | Countess of the Holy Roman Empire | Countess Robert Bentinck | " | ||
| Henrietta Eliza Cathcart Bentinck [†1934] | " | Countess Henry Bentinck | " | ||
| Victoria Mary Frederica Mechtild Bentinck [1863-1949] |
" | Countess Victoria Bentinck | " | ||
| Ursula Victoria Henrietta Bentinck [1884-?] |
" | Countess Ursula Bentinck | " | ||
| Naomi Mechtild Henrietta Bentinck [1887-1959] |
" | Countess Naomi Bentinck | " | ||
| Brydgytte Blanche Bentinck [b. 1916] |
" | Countess Brydgytte Bentinck | " | ||
| Henry Noel
Bentinck [1919-97] |
Count of the Holy Roman Empire | Count Henry Bentinck | " | ||
| Sophy
Mechtild
Mary Bentinck [b. 1924] |
Countess of the Holy Roman Empire | Countess Sophy Bentinck | " | ||
| Isabelle
Adrienne Bentinck [b. 1925] |
" | Countess Isabelle Bentinck | " | ||
| Walter Guy Bentinck [1864-1957] | Baron of the Kingdom of the Netherlands | Baron Bentinck | 12th September, 1911. | Wolter Thomas Bernard Ramsay Bentinck [† 1959] | |
| Henry Robert Visart de Bury | Count of Austria | Count de Bury, and de Bocarme | 19th November, 1910 | ||
| Richard
Frederick John Donough Le Poer Trench, Earl of
Clancarty [1891-1971] |
Marquis of the Kingdom of the Netherlands | Marquis of Heusden | 16th August, 1824. | ||
| Thomas Francis Fremantle, Lord Cottesloe [1862-1956] |
Baron of Austria | Baron Fremantle | 22nd January, 1822. | John
Walgrave Halford
Fremantle [1900-94] |
John Tapling Fremantle [b. 1927] |
| Sir Robert William Charlier Dillon, Baronet [1914-82] | Baron of the Holy Roman Empire | Baron Dillon | 24th April, 1800. | ||
| Thomas
Edward
Dimsdale [1911-?] |
Baron in Russia | Baron Dimsdale | 29th July, 1813 | ||
| Elbert Adrian William de Hochepied Larpent [† 1945] | Baron and Magnat of Hungary | Baron de Hochepied | 27th September, 1819. | ||
| Oliver George Paul Louis Gordon de Reuter | Baron in Saxe-Coburg and Gotha | Baron de Reuter | 6th November, 1891. | ||
| Lionel Walter, Lord Rothschild [†1937] | Baron of Austria | Baron de Rothschild | 16th June, 1838. | ||
| John Frederick Foley de Rutzen [†1944] | Baron of the Kingdom of Poland | Baron de Rutzen | 23rd May, 1918 | ||
| Geoffrey Fitzherbert de
Teissier [1888-?] |
Baron of the Kingdom of France | Baron de Teissier | 16th September 1905 | Ivor Geoffrey Dykes de Teissier | |
| Arthur Charles Wellesley, Duke of Wellington [† 1934] | Count in Portugal | Conde de Vimiera | 18th October 1811 | Arthur Charles Wellesley, Marquess Douro [† 1941] | Henry
Valerian
George Wellesley, Earl of Mornington [† 1943] |
| Sir John Francis Charles de Salis, K.C.M.G. [1864-1939] |
Count of the Holy Roman Empire | Count de Salis | 4th April 1809 | ||
| John
Eugene de Salis
[1891-1949] |
" | Count John de Salis | " | ||
| Anthony Denis Rodolph de Salis [1897-1952] | " | Count Anthony de Salis | " | ||
| Helen
Clare de Salis [Mrs
Archibald Ian Douglas Fletcher] |
Countess of the Holy Roman Empire | Countess Helen de Salis | " | ||
| Joan
Mary de Salis [Mrs Gerald
Armstrong Payn] |
" | Countess Joan de Salis | " |
||
| Charles John de Salis
[b. 1930] |
Count of the Holy Roman Empire | Count Charles de Salis | " |
||
| Peter Francis de Salis [1902-82] | " | Count Peter de Salis | " |