The Agricultural Holdings (England) Act, 1875. 149 
It would tend greatly to prevent disputes and litigation if the 
landlord arranged to supervise the work done through his agent 
•or otherwise, and the tenant's statement of outlay, accompanied 
by proper vouchers, were then signed by the landlord or agent. 
No question could then be raised upon claims made at the end 
of the occupation as to whether the money had been " properly 
laid out." One limitation upon the tenant's power to make second- 
•class improvements independently of the landlord's opinion or 
sanction has just been mentioned. If the tenant has either 
given or received notice to quit, he is forbidden to make any 
of the six improvements unless he receives the landlord's written 
consent (§ 12). Thus no tenant under notice will be able to 
commit the landlord to an expenditure which will mainly fall 
upon the latter, and which will certainly set up a troublesome 
•claim, and perhaps end in expensive litigation. A tenant under 
notice can liave no right to farm for his successor, and compel 
■liis landlord to contribute possibly six-sevenths of the money ; 
for that is what the right to make improvements of the second 
class at such a time would practically come to. 
Claims for improvements of the second class are to be assessed 
upon one basis only — that laid down by the Act in the case of 
absolute owners. They a"e not affected by the status of the 
landlord. How much, therefore, or how little they have added 
to the letting value of the holding is immaterial ; and in making 
them the tenant is relieved from the necessity of inquiring 
-whether his landlord is a limited or an absolute owner. If the 
Teferees find that the improvement is good for the full term of 
seven years, the claim for a second-class improvement abates 
•every year by one-seventh of the amount " properly laid out " 
upon such improvement, beginning with the year of tenancy in 
•which the outlay is made. The following, therefore, would be 
fthe tenant's claim in the case stated : — 
Sum expended on Second-Class Improvements, during gear of 
Tenancg, 1876-7— £140. 
Compensation 
Year. due. 
1877- 8 £120 
1878- 9 100 
1879- 80 80 
Year. 
Compensation 
due. 
1880- 1 £60 
1881- 2 40 
1882- 3 20 
The amount of compensation due for a second-class improve- 
ment will vary, of course, with what is found to be its " life." 
The rule to ascertain the amount due will be the same as that 
given with respect to first-class improvements. 
-^45 to Third -Class Improvements. — These fall within the 
