140 The Agricultural Holdings (^England) Act, 1875. 
under ''the same contract of tenancy " (§ 4). It follows, there- 
fore, that there may be two separate " holdings " by the same 
tenant under the same landlord if the land is held for a different 
term or under a different contract. Hence it will be necessary 
in such cases to give separate notices in respect of each holding, 
whenever notices are necessary under the Act. Another defini- 
tion which may be given here is that of the term, " contract af 
tenancy," which throughout the Act means not only a letting of 
land under any instrument, " for a term of years, or for lives, or 
for lives and years," but also a letting from year to year, or at 
will (§ 4). 
Three classes of improvements are recognised (§ 5) as en- 
titling a tenant to compensation. They must all have been 
" executed " after February 14, 1876 ; and the compensation, if 
any, due in respect of them will only be paid at the end of the 
tenancy, whether such tenancy is determined by effluxion of 
time, by the act of either landlord or tenant, or by any other 
cause. 
As to First-Class Improvements. — These are thirteen in num- 
ber, and come under the head of permanent improvements, for 
which the highest scale of compensation is awarded. They are 
ranged in alphabetical order, thus : — 
1. Drainage of land. 
2. Erection or enlargement of 
buildings. 
3. Laying down permanent pas- 
ture. 
' 4. Making and planting osier beds. 
5. Making water-meadows, or 
works of irrigation. 
6. Making gardens. 
7. Making or improving roads or 
bridges. 
8. Making or improving water- 
courses, ponds, wells, or re- 
servoirs, or works for supply 
of water for agricultural or 
domestic purposes. 
9. Making fences. 
10. Planting hops. 
11. Planting orchards. 
12. lieclaiming waste land. 
13. Warping land. 
The wording of § 6 is of great importance. It runs thus : — 
" An improvement shall not in any case be deemed, for the 
purposes of this Act, to continue unexhausted beyond the respec- 
tive times" applicable to each class of improvement, namely, 
twenty, seven, and two years. These periods, therefore, merely 
represent the maximum limit of time during which compensa- 
tion can be claimed. It will be for the valuers in each case to 
say, with ntference to each improvement, whether within the 
specified limits of time the improvement is or is not exhausted. 
In Committee on the Bill, Sir T. D. Acland and others showed 
tliat the value and permanence of the improvements specified in 
eru li class must often differ, tlioiigh they are classed together, 
and that they cannot be put all on a level. It was not possible 
in the Act to distinguish between each improvement, or assign 
