142 Contemporary Agricultural Law. 



held that on the termination of the tenancy the obligation to 

 satisfy the tenant's claim to compensation fell on the purchaser, 

 and not on the vendor. The County Court case of Oshorn 

 V, Herdman (47 L.J., 466) deserves notice. In that case a 

 claim for compensation for disturbance by a tenant under 

 Section 11 of the Agricultural Holdings Act, 1908, was made, 

 and the question was whether the notice to quit had been given 

 " without good and sufficient cause, and for reasons inconsistent 

 with good estate management." It appeared that at the time 

 of giving notice the landlord intended to build bungalows on 

 the land, but he subsequently changed his mind and sold the 

 land. It was held that the landlord's reason for determining 

 the tenancy being to obtain a larger income out of the land 

 was a good and sufficient cause for giving notice and one not 

 inconsistent with good estate management, and that the tenant's 

 claim therefore failed. 



4. Produce. There have again been several cases relating 

 to the sale of milk. In Williams v. Friend (1912, 2 K.B., 

 388 ; 81 L.J.K.B., 756) a dairyman sold to a purchaser cream 

 mixed with a preservative. Nothing was said at the time of 

 sale, but opposite the entrance to the shop a notice was exhibited 

 that all cream sold at the establishment contained a small 

 portion of boron preservative to keep the cream " sweet and 

 wholesome." He was charged under Section 6 of the Sale of 

 Food and Drugs Act, 1875, with having sold " to the prejudice 

 of the purchaser " an article of food which was not of the 

 nature, substance, and quality of the article demanded by him. 

 It having been found that the purchaser had seen and read the 

 notice, it was held that the sale was not a sale " to the prejudice 

 of the purchaser," and that for the purposes of Section 6, 

 the fact that the added matter was found to be injurious to 

 health was immaterial. It was, however, pointed out that 

 proceedings may be taken under Section 3 of the same Act if 

 reliance is intended to be placed upon the unwholesome char- 

 acter of an ingredient added to food. In Preston v. Redfern 

 (10 L.G.R., 717 ; 76 J. P., 351) proceedings were also taken 

 under Section 6 of the same Act against a vendor of milk 

 where the public analyst had certified that a sample of milk 

 purchased from him contained 12 per cent, of added water cal- 

 culated on the standard prescribed by the Board of Agriculture 

 in the Sale of Milk Regulations, 1901 (viz. 8'5 per cent, of milk 

 solids other than milk fat). The vendor called no evidence in 

 contradiction of the certificate, but contended that the deficiency 

 in milk solids was due to causes other than the addition of 

 water. The Justices applied their own knowledge and were of 

 opinion that the deficiency in the standard prescribed might 

 be due to causes other than the abstraction of solids or the 



