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If children were left empty-handed in the will, they could sue for breach of the pietas duty. However, it was sufficient to leave a quarter of the intestacy portion to protect the will against annulment to the extent of the entire intestacy portion. Imperial rescripts also gave a quarter against gifts made in order to leave an empty inheritance. Justinian's reform constitution in C. 3.28.30 can be explained by this "quarrel-excluding fourth".
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