 But this deathbed marriage did not prevent his primary title from being inherited by his younger brother Thomas Lyon-Bowes, 11th Earl of Strathmore and Kinghorne.The Scottish courts agreed that by marrying Mary, John had been legitimized under Scottish law, but since both parties (notably the father) were domiciled in England, English law would prevail.And Scottish law required Scottish domicile of the parents for the son to have been legitimated.