179 
Contemporary Agricultural Laui. 
the person actually carrying, nor was the company the “ person 
in charge ” within the Order. No offence had therefore been 
committed by the railway company. 
Catchpole v. Minster (30 Times L.R., 111) was a case of a 
different character. The action was brought by the plaintiff, 
a farmer in Sussex, against a taxicab proprietor to recover 
damages for injury done to three sheep belonging to the 
plaintiff owing to the alleged negligent driving of the 
defendant’s taxicab. On November 6, 1912, at 5.30 p.m. the 
plaintiff’s drover was going along a high road in charge of 100 
sheep. He was accompanied by a dog which was behind the 
flock while he was walking in front. It was dark, and the 
sheep were kept as much as possible on the near side of the 
road. According to the plaintiff’s case the defendant’s motor 
cab, which was travelling in the same direction at a rapid pace 
and on the wrong side of the road, ran into the sheep and 
injured three to such an extent that they had to be killed. 
The plaintiff was non-suited by the county court judge on the 
ground that the accident was solely due to the negligence of 
the plaintiff’s drover in taking a flock of sheep along the high 
road at night without carrying a light. The Divisional Court 
ordered a new trial on the ground that the decision of the 
county court judge was wrong. It was held to be an erroneous 
view that a person driving sheep on a high road without a 
light was guilty of negligence and had therefore committed a 
breach of duty. 
3. Landlord and Tenant. The relations of landlord and 
tenant were the subject of several decisions in 1913. Re 
Bonnett and Fowler (82 L.J.K.B., 713 ; 1913, 2 K.B., 537) is a 
very important case under Section 11 of the Agricultural 
Holdings Act, 1908, which gives a tenant a right to compen- 
sation for disturbance if ( a ) his tenancy has been determined 
or a renewal thereof is refused “ without good and sufficient 
cause, and for reasons inconsistent with good estate manage- 
ment,” or (5) if it is proved that an increase of rent is 
demanded, and that such increase was demanded by reason 
of an increase in the value of the holding due to improvements 
which have been executed by or at the cost of the tenant and 
the demand results in the tenant quitting the holding. The 
tenant Bonnett received notice to quit for the sole reason as 
found by the arbitrator that he refused to pay an increased 
rent of 10s. an acre demanded of him, and the holding had 
been relet by the landlord to a new tenant at the increased 
rent demanded of Bonnett. It was also found by the arbitrator 
that Bonnett had, during his tenancy, improved the condition of 
the land by continuous high cultivation and had also made 
certain small improvements at his own cost for which he 
