The Cure of Sheej:) Scab. 
161 
husbandry practised in the neighbourhood ? ’ One must bear in 
mind the change of circumstances in the neighbourhood, and the 
mode of cultivation of land now adopted there. One must look and 
see what was going on in the neighbourhood, and not exclude the 
consideration which came within one’s own extra-judicial knowledge 
that the wants of the Metropolis and the neighbourhood were con- 
stantly extending and necessitated the increase of market-gardens. 
Then there was the consideration that in the neighbourhood of this 
farm there were other market-gardens, and also other farms con- 
ducted on the principle which the defendant had adopted to his 
own advantage, namely, combining the farm proper with the market- 
garden proper. Ills Lordship could not see that this was not using 
the laud ‘ according to the best rules of husbandry practised in the 
neighbourhood.’ Construing the case according to the usages of 
mankind and the words of the lease, he saw no reason why the 
defendant should not erect such glasshouses as he thought fit. The 
defendant, in his Lordship’s opinion, was entitled to use the ground 
as a market garden, and if so, he was entitled to cover it with glass- 
houses, and derive advantage from it in that way. If that was 
expressly sanctioned by the lease, it could not be ‘ waste ’ ; the tenant 
could not commit waste as against his landlord, if his landlord had 
by special contract given him leave to do so. Was what had been 
done ‘ waste 1 ’ Perhaps technically it was ; but supposing it was, 
it did not follow that the plaintiff could recover damages for it, or 
obtain an injunction to prevent it. Was there any injury to the 
inheritance ? The evidence showed that to be an absurdity ; and 
that so far from the erection of these houses being an injury to the 
inheritance, it would be of advantage to the farm, the ground being 
in the neighbourhood of London. 
“There was another point, as to the application of the Agricul- 
tural Holdings Act, 1883 ; but in the view which his Lordship took 
of the case it was not necessary to consider what the meaning of the 
Act was ; but the Act appeared to go a long w'ay towards getting 
rid of the old common-law doctrine of ‘waste.’ Without deciding 
the point, his Lordship felt inclined to hold that these houses were 
‘improvements’ within the Act, that is to say ‘improvements’ for 
which a tenant might get compensation, but further than that he 
did not think it necessary to go.” 
S. B. L. Druce. 
THE CURE OF SHEEP SCAR 
In relating the history of the eradication of sheep sc.ab in Aus- 
tralia, I may observe that my personal experience in the matter 
dates back to 1864. At the outset it may be well to remark that 
the idea that scab was eradicated in Australia by the slaugljter of 
the' scabbed sheep is entirely erroneous. As a matter of fact, scab 
VOL. III. T. S. — 9 M 
