640 TJie Agricultural Holdings Act. 
especially interesting. They were the outcome of the work of two- 
scientific men who were amongst the earliest workers at the first 
disease in which a micro-organism was constantly found as the 
causal agent of a specific malady. From the discovery of the bacillus 
of anthrax a new era in the study of contagious and transmissible 
diseases may be said to date. 
The work in this section throughout the Congress was intensely 
practical, and much of it affords promise of better times to come for 
stock-owners, dairy farmers, and others. Indeed, one cannot but be 
impressed by the fact that work which, carried out in connection with 
the health of the human community, has lowered the death-rate so 
enormously during the last few decades, should, when applied to the 
breeding, rearing, and storing of cattle, be equally successful ; and 
that the diminished death-rate or disease-rate must necessarily be 
followed by a corresponding increase in the value and food-produc- 
ing power of cattle. 
G. Sims Woodhead. 
THE AGRICULTURAL HOLDLXGS ACT. 
Note upon a case relating to the power given to a landlord by this 
Act to obtain a charge upon a farm for the amoitnt p)<^id to the 
tenant for compensation.^ 
The Agricultural Holdings Act provides, by section 29, that "a 
landlord on paying to the tenant the amount due to him in respect 
of compensation under the Act, shall be entitled to obtain from the 
County Court a charge on the holding, or any part thereof, to the 
amount of the sum so paid," and that " the Court shall, on pi'oof of 
the payment, and on being satisfied of the observance in good faith 
by the parties of the conditions imposed by the Act, make an order 
charging the holding, or any part thereof, with repayment of the 
amount paid, with such interest, and by such instalments, an4 with 
such directions for giving effect to the charge as the Court thinks 
fit." The question at issue in the case now under consideration was 
whether, under this section, the executors of a landlord who was 
tenant for life of the farm, and who had died after the amount pay- 
able to an outgoing tenant for compensation had been fixed, could 
obtain a charge on the farm for that amount, they having paid 
it to the outgoing tenant. After considerable difference of 
opinion amongst the judges before whom the case was successively 
tried, the Court of Appeal decided that the executors could obtain 
' Goughy. Govgh, reported in the Times ot April 15 and June 29, 1891r 
and in the Weekly Reporter, vol. xxxix. pp. 494 and 593. 
