138 Contemporary Agricultural Law. 



time of any transfer on sale of the fee simple or of any interest 

 in the land which took place at any time within twenty years 

 before April 30, 1909, shall apply to the case of any transfer 

 on sale of the fee simple or of any interest in the land which 

 took place between April 29, 1909, and the date of the com- 

 mencement of the Act (April 29, 1910), or took place after the 

 commencement of the Act in pursuance of any contract made 

 befoi'e the commencement of the Act, 



Some important bills afTecting agriculture, such as the bill 

 for amending the Agricultural Holdings Act, 1908, in respect 

 of notice to quit, and the Milk and Dairies Bill, have been 

 introduced into Parliament, but it is uncertain at present if 

 they will be passed into law. 



11. — Decisions op the Courts. 



1. Labour. It must again be stated that decisions under 

 the Workmen's Compensation Act, 1906, have been very 

 numerous, but now, as in former years, employers of labour 

 in agriculture appear to have been fortunate in requiring the 

 assistance of the Courts in dealing with claims by their work- 

 men less frequently than employers of other classes of labour. 

 It will only be necessary to notice a few of these decisions 

 which may be applicable in cases of claims by agricultural 

 labourers for compensation under the Act. In the Irish case 

 of Greene v. Shaic (1912, W.C.C., 25), a herd was employed to 

 look after cattle upon two farms, and usually rode a bicycle in 

 going from one farm to the other. One evening when he had 

 mounted his bicycle for the purpose of visiting one of the 

 farms to see the cattle, a young sheep dog, his own property, 

 ran in his way, with the result that he was thrown from the 

 bicycle and fatally injured. It was held that the accident 

 occurred " in the course of," but did not arise " out of the 

 employment " of the workman, and therefore his representatives 

 were not entitled to compensation under the Act. In Parker 

 V. Hamhrook (1912, W.C.C, 369) the vexed question of the 

 liability for accident suffered hy a servant who has disregarded 

 his master's instructions, given for his own protection, was 

 considered. The workman was ordered to dig for flints on 

 certain land at Drellingore Farm for his master, who was a 

 farmer and traction engine proprietor, and agreed to pay in 

 proportion to the quantity of flints raised. The workman was 

 forl)idden to work in a particular part of the pit which was 

 known to be dangerous. Notwithstanding his orders he worked 

 on the day in question in this part as it was richer in flints than 

 other parts, and also more sheltered from rain. He was over- 

 whelmed by a fall of earth from the side of the pit and killed. 

 It was held that since his working in the forbidden part of the 



