The Agricuttural Holdings {England) Act, 18»3. 25 
his claim. As the landlord is primarily liable for any com- 
pensation, it is only right that he should know of and assent 
to any arrangement which may hereafter serve as a basis of 
claim against him. On the other hand, it is fair that there 
should be a recognition of the new tenant's continuing property 
in improvements, not, indeed, made by him, but purchased by 
him. Of course, as to them he stands in his predecessor's 
shoes, and can only obtain compensation for these improvements 
on proof of their value to the incoming tenant, and to the extent 
of that value. There is no express provision requiring the 
landlord to consent in the case contemplated by the section ; 
but it is submitted that this consent must be withheld, if at all, 
upon reasonable grounds, and could not be properly withheld 
upon a decision arrived at by valuers under the procedure sec- 
tions. The landlord, however, would have a clear right of 
refusing his consent to any compensation merely agreed upon 
between the outgoing and incoming tenants. 
Compensation under the Act to be Exclusive (§ 57). — A tenant 
is not allowed the option given him by the Act of 1875 of 
claiming compensation under it, or by custom or otherwise. If 
he is entitled to compensation under the Act in respect of 
improvement, § 57 bars his remedy to recover under any other 
title for that improvement. It follows that, in respect of im- 
provements for which he is not entitled to claim compensation 
under this Act, he may recover under statute, custom, or agree- 
ment, so that a tenant may, by possibility, be able to recover 
compensation in two or three ways. It will be important, 
however, for him to remember that he may be deprived of his 
right to compensation altogether, unless, when entitled under, 
the Act, he gives the requisite notice of claim two months 
before quitting his holding. 
Restriction on Improvements by Tenant about to Quit (§ 59). — 
The general elFect of this restriction has already been mentioned. 
Lessees are not entitled to compensation for anv improvements, 
except manures, within one year before their leases expire : a 
yearly tenant is under lite restriction, and for the same period, 
" or at any time alter he has given or received final notice to 
quit." A " final " notice to quit is somewhat vague ; it must 
mean any notice until waiver or withdrawal, so that a yearly 
tenant will make at his peril any improvement other than 
Xos. 22 and 23, after receiving notice, because he cannot know 
whether the notice will be waived or withdrawn. 
There are two exceptions to the rule here laid down : — 
(a) W hen a tenant from year to year has begun an improvement 
during the last jear of his tenancv, and, afterwards receiving 
notice, quits his holding at the expiration of that year. This 
exception, it would seem, can hardly apply in practice except iu 
