The seisin and fee simple enjoyed as a result of possession would also be lost because each successive possessor must enjoy the rights directly associated with possession. According to this analysis, the last possessor only in any succession would enjoy the entitlements. If the Crown dispossessed an indigenous people, its title arising from possession would be the best claim. This was the effect of Holdsworth's analysis of land law. That is, possession of itself gives rise to no title which survives dispossession.
Possession is protected against subsequent possession by a prima facie right of entry.
The proposition that possession of itself gives rise to a right in the plaintiff to recover possession, if lost, is supported by principle. In losing possession, a plaintiff has lost the rights associated with possession, including the right to defend possession as well as an estate in the land. But nothing has upset the presumption that the plaintiff's possession, and therefore his or her fee simple, was lawfully acquired and hence good against all the world. Without evidence to the contrary, nothing has displaced the presumption arising from proof of the plaintiff's possession that he or she had lawful title amounting to a fee simple. In sum, English land law, in 1879 and now, conferred an estate in fee simple on a person in possession of land enforceable against all the world except a person with a better claim.