The 1852 Constitution was passed by the British Parliament on the advice of the Governor of New Zealand, George Grey. It established democratic and representative government by providing for six Provincial Councils and a House of Representatives to be elected by adult men who qualified by holding or leasing property of specific value. Although the property value was sufficiently low for most householders to qualify, almost all Màori were excluded because they predominantly held their land in common. In 1867 this deficiency was remedied by creating four Màori electoral districts, for which the franchise was open to all Màori men of 21 years or older who resided in those districts. This was possibly the first example of the right to vote without a property requirement, and set a precedent for universal suffrage.