 At the present time and for several centuries past the title has been obtained only by an express grant from the Sovereign effected by letters patent; but a certain number of cities possess the title by very ancient prescriptive right.There is no necessary connexion between the title of a city and the seat of a bishopric, and the creation of a new see neither constitutes the town concerned a city nor gives it any claim to the grant of letters patent creating it a city.In 1928, Plymouth submitted an application for city status.