Contemporary Agricultural Law. 
175 
The Bankruptcy and Deeds of Arrangement Act, 1913 
(3 and 4 Geo. 5 c. 34), by Section 18, restricts a landlord’s 
power of distress in case of bankruptcy of a tenant so that the 
distress if levied after the commencement of the bankruptcy 
shall not be available for rent payable in respect of any period 
subsequent to the date when the distress was levied. 
II. — Decisions of the Courts. 
1. Labour. Decisions under the Workmen’s Compensation 
Act, 1906, have again been very numerous, but few of them 
have any bearing on labour in agriculture. Knight v. Bucknill 
(1913, W.C. Rep., 175) is an important case on the liability of 
an employer for an injury by accident to a casual labourer. A 
jobbing gardener was employed to cut down some trees at a 
daily wage of 3s. 6d. Subsequently he was employed to cut 
down other trees, and in the interval he was engaged in 
re-laying a lawn. After being employed for about five weeks, 
during which he worked every weekday except when the 
weather was too bad, he met with an accident while lopping 
branches from a tree. It was held that his employment was 
“ of a casual nature ” and that he was not a “ workman ” within 
the meaning of Section 13 of the Workmen’s Compensation 
Act, 1906, which excludes from the definition of “workman” 
“ a person whose employment is of a casual nature and who is 
employed otherwise than for the purposes of the employer’s 
trade or business.” The employer was therefore not liable to 
pay compensation under the Act. It is to be noticed, however, 
that the result would have been different if the employment 
had been for the purpose of the employer’s trade or business 
(e.g. if the employer had been a timber merchant) even though 
it was of casual nature. In Edwards v. Wingham Agricul- 
tural Implement Co. (82 L.J.K.B., 998 ; 1913, 3 K B. 596) 
a workman was employed as engine driver to work his 
employers’ threshing machines at 6<A an hour. It was also 
his duty to go about a district allotted to him and look 
after the interests of his employers therein and was 
supplied with a bicycle for going to and from his work 
as well as for going from one part of his district to another. 
He ceased work each day at 6 p.m., and when on a distant 
job was not expected to return to his employers’ works. 
On September 25, 1912, he had been engaged in working 
one of the employers’ threshing machines and ceased work 
at 6 p.m. In the course of returning home on the bicycle 
he met with an accident, being run over by a steam lorry, 
and he sustained injuries which caused his death. His 
dependants claimed compensation. It was held that they 
were not entitled as the accident did not happen in the course 
