The term subpoena is from the Middle English suppena and the Latin phrase sub poena meaning "under penalty". It is also spelled "subpena". The subpoena has its source in English common law and it is now used almost with universal application throughout the English common law world. John Waltham, Bishop of Salisbury, is said to have created the writ of subpoena in the reign of Richard II. However, for civil proceedings in England and Wales, it is now described as a witness summons, as part of reforms to replace Latin terms with Plain English understandable to the layman.