Fixity of tenure was secured by enabling a tenant to convert his interest into what is called in the act a _statutory term_. Such a term may be created by an agreement between the landlord and tenant for an increased rent, or by having a fair rent fixed, or by filing in court an agreement for a judicial rent. A _statutory term_ can be created only in respect of a "present" tenancy except when in regard to a "future" tenancy the tenant has agreed with the landlord to an increased rent. The provisions as to the fixing of a fair rent apply only to "present" tenancies. Section three of the act gives a tenant power to dispose of his holding by bequest. Perhaps the most important provisions of the act are those enabling a landlord or tenant to have a "fair rent" fixed. Either party may apply to the court to have the rent made a _judicial rent_. The court fixes this rent after considering all the circumstances of the case, holding, and district, and having regard to the interests of both parties. No rent shall be payable in respect of improvements made by the tenant unless he has been already compensated for them by the landlord. In the administration of the act the word "improvements" has given rise to endless litigation. In the now famous case of Adams _v._ Dunseath it was held that "improvements" meant improvement works and not increased letting value. It was also held in a case affecting the same holding that a tenant is entitled to "a fair return by way of annual allowance in respect of the present capital value of his improvement works which may be estimated by way of percentage on such capital value; and if after making this percentage there is still a surplus of increased letting value, it is within the exclusive jurisdiction of the Land Commission to determine whether, and in what proportions, such surplus shall be divided between landlord and tenant." It was further laid down that the Land Commission was to treat "the latent and dormant resources of the soil, as let by the landlord to the tenant, as the property of the landlord, and the development of those resources by the tenant as the act of the tenant." This act was undoubtedly a great charter for the tenants and created something like a revolution in Ireland. It contained many defects, and was marred by many blemishes, but on the whole it was a masterly attempt to settle the question. Like much of the land legislation for Ireland, most of its shortcomings were due to a reckless disregard on the part of British ministers for Irish opinion. Indeed, this was the cause of most of the amending legislation that followed.