The Agricultural Holdings {England) Act, 1883. 39 
" 2. That the award proceeds wholly or in part upon an im- 
proper application of, or upon the omission properly to apply, 
the special provisions of §§ 3, 4, or 5 of this Act. 
" 3. That compensation has been awarded for improvements, 
acts or things, breaches of covenants or agreements, or for 
committing or permitting waste, in respect of which the party 
claiming was not entitled to compensation. 
" 4. That compensation has not been awarded for improve- 
ments, acts or things, breaches of covenants or agreements, or 
for committing or permitting waste, in respect of which the 
party claiming was entitled to compensation." (§ 23.) 
The Judge must hear and determine the appeal, and may 
remit the case to be re-heard in whole or in part by the 
referees or umpire. His decision on the facts will be final, 
but at the request of either party he is bound to state a special 
case -on a question of law for decision by the High Court of 
Justice. That is the utmost limit to which the case can be 
carried, for the judgment of the High Court so invoked will be 
final, and the County Court Judge is to act thereon (§ 23). 
Substantially, these are the provisions in the Act of 1875, but, 
with a view to discourage litigation, the limit of appeal is raised 
from 50/. to lOOZ. Remembering that a claim of lOOZ. or 
under may now raise the question whether an agreement is to 
stand which was deliberately entered into by the parties, but 
has since been repudiated by one of them and set aside, it may 
be, by a single referee, this restriction on the right of appeal 
is a serious one. A very limited period is given for ap- 
pealing, namely, seven days after delivery of the award. It 
would seem by reference to the earlier sections that this must 
mean delivery to either party. The referees or umpire should 
inform both parties when the award is ready for delivery, but 
no obligation rests on them to do so. Both parties, therefore, 
must be on the watch, or either may find thatliis right of appeal 
has gone. If, as under the County Court orders of 1876, an 
appellant must file a copy of the award within four days after 
its delivery, together with a concise statement in writing of his 
grounds of appeal, the time for appeal will be still further limited. 
From the grounds of appeal stated in § 23, it seems that the 
whole case will be heard de novo in the County Court, with any 
evidence which either party may think fit to produce for or 
against the claim. 
As the parties may agree respecting the compensation, it will 
be well that such agreement should be in writing, and should 
set forth not only the amount but the mode and time of payment. 
Money so agreed, or awarded, or ordered on appeal, must be 
paid, with the costs, within fourteen days after the time fixed. 
