The Agricultural Holdings {England) Act, 1883. 15 
takes 599Z. 17s. 6rf., because the tenant's outlay of 2s. 6c?. 
has merely developed what was latent in the soil, and he 
has enjoyed the improved yearly value of the land during his 
tenancy, which is the substantial advantage to which he really 
looked in making the improvement. Applying the principle 
here set forth to manures, " an outgoing tenant would only be 
entitled to the equivalent of the coat of the manure left in the 
land ; that is, the sum by spending which in manure the 
incoming tenant might be supposed able to do as well for him- 
self. This sum would be the maximum, because if the result 
attained were more, it must be due to the capabilities of the 
soil. On the other hand_, if it were less, that would be through 
the outgoer's want of judgment, and he would suffer accordingly. 
This relieves the valuers from ever having to consider what a 
farm was worth to rent either at the beginning or at the end of 
the tenancy, and gets rid of many of the difficulties, though it 
has not removed them all." 
We may now pass from the general scheme of compensation 
under the new law, and consider some of its more important details. 
As to Improvements executed before the Commencement of the 
Act (§ 2). — Though, as a rule, compensation cannot be claimed 
for improvements executed before January 1, two exceptions 
occur in which the Act is retrospective. These exceptions are 
in favour of (a) tenants who within ten years before January 1 
manured their holdings, or made any of the six other temporary 
improvements in Schedule I., and yet have acquired no right to 
compensation in respect of them under agreement, custom, or 
the Act of 1875 ; and (6) tenants who within the same period, 
having in like manner no right to compensation, executed per- 
manent improvements or drainage-works. 
In case (a), claims may be made irrespective of the landlord ; 
a new contract of tenancy is, in fact, fastened upon him, which 
neither party contemplated when the tenancy began, and under 
which claims may be made going back for ten years, however 
clear the bargain to the contrary. It looks an ugly blot on the 
Act, for it allows a tenant to go back from his word, or even 
his bond. In the circumstances specified, the tenant's right to 
compensation is absolute. The landlord's protection is that 
there must be proof of value to an incoming tenant. He may 
also escape from this unforeseen liability if he can show that 
the farm was let under its value, conditionally on the making of 
the improvements claimed for, because, in making the award, 
there is to be taken into account, in reduction of the tenant's 
claim, " any benefit which the landlord has given or allowed to 
the tenant in consideration of the tenant executing the improve- 
ment " (§ 6). It is to be assumed, however, that clear proof 
