182 
Contemporary A grieultural Law. 
parties and a natural consequence of tlie landlord’s action and 
not too remote. The tenants were, therefore, held entitled to 
recover both the 533Z. and the 10H. 
The right of a tenant to deduct landlord’s income tax from 
his rent arose in Re Sturmey Motors , Lim. (82 L.J., Cli., 68 ; 
1913, 1 Ch., 16). It was there held that a tenant is entitled to 
deduct sums paid by him in respect of such income tax from 
his rent, although since the payment he has made a payment of 
rent without making any deduction. It is not necessary to 
make the deduction from the next payment of rent which falls 
due. 
Tuff v. Drapers Go. (82 L.J.K.B., 174 ; 1913, 1 K.B., 40) 
related to the payment of tithe rent charge. It will be remem- 
bered that the Tithe Act, 1891, imposed the liability for tithe 
rent charge exclusively on the landlord, and enacted in Section 1, 
Sub-section 1, that “any contract made between an occupier 
and owner of lands for payment of the tithe rent charge by the 
occupier shall be void."’ A tenant by his lease, in addition to 
the rent, agreed to pay “ such further and other sums of money 
as they (the landlords) shall from time to time expend for the 
insurance of the said premises from loss or damage by fire as 
hereinafter mentioned, and for all tithe or tithe rent charge or 
modus or other payment in lieu of tithe.” It was held by the 
Court of Appeal (Buckley, L. J., dissenting) that Section 1, Sub- 
section 1, of the Tithe Act, 1891, is not limited to a contract 
between an occupier and owner of land for payment of the 
tithe rent charge by the occupier to the tithe owner, but extends 
also to a contract between an occupier and owner of lands for 
payment by the former to the latter of such sums as the latter 
shall expend in payment of tithe rent charge to the tithe 
owner. The landlords, therefore, in the present case were 
disentitled to recover from the tenant a sum of 99Z. paid by 
them in respect of tithe rent charge. 
In Re De la Warr's {Earl) Gooden Beach Estate (82 L.J., 
Ch., 174 ; 1913, 1 Ch., 142) it was decided that capital money 
arising under the Settled Land Act, 1882, may not be expended 
in paying compensation to an agricultural tenant from year to 
year under the Agricultural Holdings Act, 1908, on terminating 
his tenancy, even though the tenancy is terminated in order to 
effect a duly authorised improvement under the Act consisting 
of a golf course. A tenant for life who desires to make such 
improvement must pay the compensation out of his own 
moneys. 
4. Produce. There have been several cases in the past year 
dealing with the sale of milk. In Plowright v. Burrell (82 
L.J.K.B., 571 ; 1913, 2 K.B., 362) the Dairy Supply Co., Lim., 
agreed to supply a retail dealer with the whole of the new 
