The Agricultural Holdings (^England) Act, 1883. 41 
improvements have, by his unconditional consent, or under 
agreement, been executed by the tenant, for then the outlay is 
included in the compensation, or substituted compensation, 
which the landlord may charge. The subjects of charge which 
appear to be authorised by § 29, are : — 
(a) Permanent improvements if executed by the tenant, and 
included in his compensation under the Act, This charge can 
only be made after payment to the tenant. 
(6) Drainage (1) when executed by the tenant, and included in 
his compensation, and paid for by the landlord ; (2) when 
executed by the landlord, after notice from the tenant, under 
the powers in § 4, in -which case the money must have been 
actually expended. 
(c) Temporary improvements included in the tenant's com- 
pensation, and paid for by the landlord. 
The order of charge will be in favour of the landlord, his 
executors, administrators, and assigns, who will receive " repay- 
ment of the amount paid or expended, with such interest, and by 
such instalments, and with such directions for giving effect to 
the charge, as the Court thinks fit." 
As in 1875, a landlord must furnish the County Court with 
proof of the payment or expenditure ; he must also satisfy it that 
he is acting in good faith, and that there is no collusion with 
the tenant for the purpose of burdening the estate with a com- 
pensation not represented by any equivalent increase in annual 
value. In the case of limited owners the Court may be expected 
to require specific evidence in order to clear up any doubts of 
this description, especially where compensation has been settled 
between the parties without calling in a referee or referees. 
Some protection, indeed, is afforded to persons entitled in rever- 
sion or remainder. It will be remembered that landlords must 
always notify the referees or umpire of an intention to charge 
the holding, and thereupon the award must state " the time at 
which, for the purposes of such charge, each improvement, act, 
or thing, in respect of which compensation is awarded, is to be 
deemed to be exhausted " (§ 19). The object of this salutary 
requirement is explained in § 29, which says that where a land- 
lord is not the absolute owner, the payment of instalments and 
interest under any charge shall cease at the time when, accord- 
ing to the award, an improvement will become exhausted. If 
there has been no award, i.e. if the compensation has been 
agreed upon, the Court in its discretion will require evi- 
dence as to the period of exhaustion. It follows that, in the 
case of limited owners, an order cannot charge the holding 
generally with a sum the whole of which is repayable at a given 
period, but must create a separate charge for each improvement, 
