The Devon Commission, the Report of which was issued in 1845, recommended that in future compensation should be given to Irish tenants for permanent improvements effected by them. Bills to carry out the recommendation of the Commission were introduced in 1845 by Lord Stanley, in 1846 by Lord Lincoln, and in 1852 by Mr. Napier, the Attorney-General for Ireland. But it was not until the Act of 1870 was passed--a quarter of a century after the Report of the Commissioners had been issued--that its recommendations were embodied in an Act of Parliament. So far was this from being the case with the next statute dealing with Irish land--Deasy's Act, passed in 1860--that it aimed at the substitution of the commercial principles of contract for the equitable principles of custom in the relations between landlord and tenant, in this respect that it refused to allow compensation to the tenant for improvements other than those made with the landlord's consent. The object of this Act--the last word of the Manchester School on the Irish Land Question--was, therefore, to destroy any claim by a tenant in respect of future improvements, unless under the terms of some contract, express or implied. In point of fact, the Act proved almost a dead letter, and the one result which ensued from its passing into law was to make the position of the tenant less secure, in so far as it made the process of ejectment less costly and more simple, and enabled the landlord in many instances to confiscate improvements. Twenty-three Bills in favour of the tenants were thrown out in the forty years which followed Emancipation. The struggle between landlord and tenant was occupied with the attempts of the latter to enforce the custom of tenant-right in Ulster, and secure its application in the other provinces. The Land Act of 1870, for the first time, gave legal sanction to this principle by giving the tenant a claim to compensation for disturbance. It gave its imprimatur to the doctrine that an Irish tenant does not contract for the occupation of a farm, that Irish land is not the subject of an undivided ownership, but of a simple partnership. The pecuniary damages to which a landlord was liable under its provisions was a blow aimed at wanton evictions, and with the curtailment of the power arbitrarily to effect these, the threats by which landlords had been able unjustly to raise rents were robbed of much of their force. The tenant under the Act secured a recognition of his property in the land and of his right to occupy it, provided he complied with certain conditions, and, in addition, he obtained compensation, albeit inadequate, for disturbance for non-payment of rent, in cases in which the Court considered the rent exorbitant, and in which failure to pay was due to bad seasons. Thus tenant-right, which Lord Palmerston had dismissed with epigrammatic flippancy as landlord wrong only a few years before, received the sanction of law from his own party.