From this sketch it will be seen that the law governing the relations of landlord and tenant in Ireland became more and more favourable to the owner. This tendency culminated in 1860, when, by “Deasy’s Act” (23 & 24 Vic., c. 154)—which was passed through Parliament without amendment—the relation between landlord and tenant was defined as founded on contract and not upon tenure. The Act proceeded on the assumption that the land is the exclusive property of the landlord, and that the tenant’s interest is nothing more than that of a person who has agreed to pay a certain remuneration for the use of the soil for a limited period. It simplified and increased the remedies of the landlord for recovering possession of the land, and rendered efficient the law of ejectment for non-payment of rent and on notice to quit. Thus a default in payment of one year’s rent entitled a landlord to evict the tenant and get possession of the land, with all improvements on it, even where such improvements many times exceeded in value the amount due. So also, by serving a Notice to Quit, the landlord could similarly get rid of the tenant without cause, and take possession of the holding and all its improvements, no matter how valuable these might be, and without having to pay any compensation. The governing principle of the Act was that whatever attached to the freehold became part of the freehold. Position of the Irish Tenant from 1860-1870.—The Devon Commission reported (1844) that farm Improvements are made by the Tenants. During the ten years after the passing of “Deasy’s Act” the position of the Irish tenant reached its nadir. He had no right of any kind, except such as the contract under which he held gave him. Almost all the improvements which rendered the land capable of being worked were made by him. He had built the houses, erected the fences, made the roads, drained and manured the land, reclaimed it from bog or mountain—generally at a cost out of all proportion to the return—and yet he could be turned out without compensation at the will of the owner, either by the service of a Notice to Quit or by ejectment for non-payment of one year’s rent. That the tenants in Ireland made the improvements was universally admitted. The Devon Commission (presided over by a leading Irish landlord) in the year 1844, reported: