rent fixed and periodically revised, irrespective of the wishes of the landlord, by an independent tribunal. Vast masses of property in Ireland had been sold under the Incumbered Estates Act by a government tribunal acting as the representative of the Imperial Parliament, and each purchaser obtained from this tribunal a parliamentary title making him absolute owner of the soil and of every building upon it, subject only to the existing tenancies in the schedule. No accounts of the earlier history of the property were handed to him, for except under the terms of the leases which had not yet expired he had no liability for anything in the past. The title he received was deemed so indefeasible that in one memorable case, where by mistake a portion of the property of one man had been included in the sale of the property of another man, the Court of Appeal decided that the injustice could not be remedied, as it was impossible, except in the case of intentional fraud, to go behind parliamentary titles.[44] In cases in which the land was let at low rents, and in cases where tenants held under leases which would soon expire, the facility of raising the rents was constantly specified by the authority of the Court as an inducement to purchasers. What has become of this parliamentary title? Improvements, if they had been made, or were presumed to have been made by tenants anterior to the sale, have ceased to be the property of the purchaser, and he has at the same time been deprived of some of the plainest and most inseparable rights of property. He has lost the power of disposing of his farms in the open market, of regulating the terms and conditions on which he lets them, of removing a tenant whom he considers unsuitable, of taking the land back into his own hands when the specified term of a tenancy had expired, of availing himself of the enhanced value which a war or a period of great prosperity, or some other exceptional circumstance, may have given to his property. He has become a simple rent-charger on the land which by inheritance or purchase was incontestably his own, and the amount of his rent-charge is settled and periodically revised by a tribunal in which he has no voice, and which has been given an absolute power over his estate. He bought or inherited an exclusive right. The law has turned it into a dual ownership. A tenant right which, when he obtained his property, was wholly unknown to the law, and was only generally recognised by custom in one province, has been carved out of it. The tenant who happened to be in occupation when the law was passed can, without the consent of the owner, sell to another the right of occupying the farm at the existing rent. In numerous cases this tenant right is more valuable than the fee simple of the farm. In many cases a farmer who had eagerly begged to be a tenant at a specified rent has afterwards gone into the land court and had that rent reduced, and has