Contemporary  Agricultural  Law. 
127 
a claim  for  the  purprse,  to  repayment  of  the  amount  of  the 
duty  on  the  excess  not  exceeding  one-eighth  part  of  the  duty 
on  an  amount  equal  to  the  annual  value.  For  the  purposes  of 
this  section  the  term  “maintenance”  includes  the  replacement 
of  farmhouses,  farm  buildings,  cottages,  fences,  and  other 
works  where  the  replacement  is  necessary  to  maintain  the 
existing  rent.  The  section  applies  to  any  land  (inclusive  of 
farmhouses  and  other  buildings,  if  any)  the  assessment  on 
which  is  for  the  purpose  of  collection  reduced  under  Section 
35  of  the  Finance  Act,  1894. 
II. — Decisions  of  the  Courts. 
1.  Labour.  There  have  been  during  the  past  year,  as  in 
former  years,  a la'ge  number  of  decisions  on  the  Workmen’s 
Compensation  Act  of  1906.  It  would  be  impossible  in  the 
space  allotted  to  this  article  to  deal  with  these,  and  in  many 
cases  they  do  not  appear  to  have  any  particular  bearing  on  the 
risks  incident  to  agricultural  labour  which  fortunately  are  con- 
siderably less  than  in  many  other  forms  of  employment.  The 
case  of  Clover  Clayton  <k  Co.  v.  Hughes  (1910,  A.C.  242  ; 79 
L.J.K.B.,  470)  should,  however,  be  noted  as  it  shows  the  risk 
an  employer  may  run  who  employs  a labourer  suffering  from 
a disease  which  may  prove  fatal  owing  to  a strain  arising  out 
of  his  ordinary  work.  The  workman  in  this  case  was  suffering 
from  an  aneurism  in  an  advanced  stage,  the  condition  of  which 
was  such  that  he  might  have  died  at  any  moment,  even  in  the 
course  of  his  sleep.  He  died  while  at  work  from  rupture  of 
the  aneurism  which  was  brought  about  by  his  screwing  up 
a nut  in  the  course  of  his  ordinary  work  which  involved  no 
exceptional  exertion.  The  House  of  Lords  held  (though  two 
noble  lords  dissented  from  the  decision)  that  the  man  died 
from  an  “ accident  arising  out  of  his  employment  ” and  that 
his  employers  were  liable  to  pay  compensation  to  his  widow. 
This  case  shows  the  wide  construction  which  the  Courts  a(-e 
disposed  to  give  to  the  word  “accident.” 
Anderson  v.  Balfour  (1910,  2 Tr.R..  297)  is  an  Irish  case 
under  the  same  Act  which  also  may  be  noted.  There  a game- 
keeper,  while  engaged  in  the  discharge  of  his  duties,  was 
attacked  and  beaten  by  poachers  as  the  result  of  which  he 
was  injured.  It  was  held  that  he  had  been  injured  by 
“ accident  ” within  the  meaning  of  the  Workmen’s  Compen- 
sation Act,  1906,  and  was  therefore  entitled  to  compensation. 
2.  Stock.  The  first  case  to  be  mentioned  is  that  of  Lowery 
v.  Walker  (27  T.L.R.,  83),  the  decision  on  which,  in  the  Court 
of  Appeal,  was  noted  in  the  last  number  of  this  Journal  at  page 
145.  That  Court  held  that  the  defendant,  who  occupied  a field 
in  which  he  placed  a savage  horse  and  over  which  there  was  no 
