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Actually, the order of the voices really doesn't matter. I do make sure that the final entry, regardless of the number of voices, is always in the tonic key, but I think that's more a matter of my own preference.
Two very well-known examples start in the middle voices. The third movement of Bach's fourth Brandenburg is a fugue that starts in the tenor voice (viola) and the first movement of the double violin concerto (BWV 1043) starts in the alto (second violins).
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