92 Contemporary Agricultural Law. 



the limit of 'SI. placed by the Act of 1910 as the maximum 

 value under Schedule A of any house in respect of which the 

 relief may be obtained is extended by the Act of 1914 to 121. 



II. — Decisions op the Courts. 



1. Labour. There have in 1914, as in past years, been 

 numerous decisions under the Workmen's Compensation Act, 

 1906, bvit few of these relate to agricultural labour. In the 

 Irish case of Carindiiff v. Gilmore (1914. W.C. and Ins. Rep., 

 247; 7 B.W.C.C., 981) a girl was employed on a threshing machine 

 in handing the sheaves to be placed in the machine. She was 

 sitting on top of the machine, and on rising her right hand and 

 arm were caught in the machine and crushed. It appeared that 

 her employer had come out and handed up to her and two other 

 persons employed on the machine certain refreshments to be 

 consumed by them while on the top of the machine. For the 

 purpose of shelter the girl, while taking the refreshment, 

 crossed over from the side of the machine on which she had 

 been working to the opposite side of the opening and sat upon 

 some sheaves. It was in rising up from this position that the 

 accident occurred. The Court held that the accident arose " out 

 of and in the course " of the employment, and the girl -was 

 therefore entitled to compensation for the injury sustained. 



Evans v. Holloway (1914, W.C. and Ins. Rep., 75; 7 B.W.C.C, 

 248) illustrates the danger of permitting an employee to give lifts 

 to his fellows. The workman was driving his employer's cart 

 home after finishing his work. On the way he was hailed by 

 a fellow employee and asked for a lift home. He stopped 

 the cart and began to alter a seat to accommodate the fellow 

 employee. While doing so the horse started, he fell out of the 

 back of the cart, and subsequently died of his injuries. It was 

 proved that the habit of giving a lift to fellow employees in 

 these circumstances was known to and recognised by the 

 employer. It was held that the accident arose " out of and in 

 the course " of the employment, and the employer was therefore 

 liable to pay compensation to the man's widow. In McConnell 

 V. Galhraith (1914, W.C. and Ins. Rep., 90 ; 7 B.W.C.C, 968) 

 it was held that a rabbit trapper who had agreed to do the 

 trapping of rabbits on certain lands at a fixed payment per 

 couple, and was injured in the course of his employment, was 

 an independent contractor, and not a workman who could claim 

 compensation from his employer. Ing v. Higgs (1914, W.C. and 

 Ins. Rep., 84 ; 110 L.T., 442 ; 7 B.W.C.C, 65) raised the ques- 

 tion of prejudice to the employer by want of notice of the 

 injury. The workman was employed in a hop garden in Kent, 

 and when using a beetle for driving stakes into the ground on 

 February 7 he strained his heart. He went on working for his 



