In Mahatma, Vol. 5 No. 12, June 1902, p. 116, T. Cussac Talma, an English magician, was reported doing this illusion at the Royal Holborn Theatre in England. A similar report appears in Stanyon's Magic, Vol. 2 No. 10, July 1902, p. 78. These mentions call the illusion “puzzling” and “novel”, suggesting it was new.
Several years later, Houdini (using the pen name Herr N. Osey) reported that T. Cussac Talma was presenting the Costume Trunk at the Palais d'Hippodrome in Antwerp, and that “as far as I know [it] is original with […] Powell” (presumably Frederick Eugene Powell); see Mahatma, Vol. 9 No. 8, Feb. 1906, p. 91.
According to Robert E. Olson, in The New Tops, Vol. 11 No. 11, Nov. 1971, p. 10, the illusion was invented by Arnold De Biere. This attribution is also given by Bev Bergeron in The New Tops, Vol. 27 No. 11, Nov. 1987, p. 21.
In Val Andrew's The Great Carmo, 2008, p. 33, this is contradicted, and Servais Le Roy is stated as its inventor.
Bart Whaley, in his Encyclopedic Dictionary of Magic, 1989, p. 87, gives this analysis, which may explain some of these contradictory claims: “Invented by small-time professional magician T. Cussac Talma and premiered (at least in England) by him in 1902 at the Royal in Holborn, London. He titled it “Robing the Robe”. He was still performing this illusion as late as 1907 in Liverpool. A pet effect of Servais Le Roy by 1905, but using his own method. Also performed by Arnold De Biere (by 1912) who was a prize customer of Le Roy…”
Talma is recorded as having defended his claim to the invention of the Costume Trunk illusion. A heated debate between him and De Vere (whether Charles or his son Camille is not made clear) occurred sometime in the early 1900s. A recounting of the debate was reported by “B. W.” in The World's Fair of June 22, 1940. B. W. judged Talma the winner.
Concerning Houdini's mention of Powell, Frederick Eugene Powell partnered with Le Roy and Imro Fox from 1898 to 1900, which makes another connection with Le Roy and this illusion.