This state of things led to outrage and constant agrarian disturbance. Various suggestions for reform of the Land Laws were made, but such proposals were usually denounced as confiscatory. Mr. Butt’s proposal in 1866 that sixty-three years’ leases, with power to the landlord of varying the rent, when any accidental circumstances increased the value of the land, should be given by every landlord to his tenants, was described by Lord Dufferin as “communistic” and “as subversive of the rights of property.” Mr. John Stuart Mill, speaking on a Land Bill introduced by Mr. Chichester Fortescue (May 17th, 1865), denounced the policy of clearing away the small tenants to make room for capitalist farmers. “You cannot,” he said, “evict a whole nation.” Various attempts to alter the law were defeated, until at length, in 1870, Mr. Gladstone took the matter in hand, and passed his Landlord and Tenant Act—the beginning of a new Land Code. The justification for the Act of 1870 was the same as for the Act of 1881, which followed it. The tenant had made all the improvements on the land, and yet had no legal property in them. He was liable to capricious eviction from a holding, the value of which was often mainly due to his labour, and he was subject to arbitrary increases of rent. The Act of 1870 did three things: (1) It gave compensation for disturbance; (2) it gave compensation for improvements; and (3) it legalised the Ulster Tenant Right Custom. _Compensation for Disturbance._ I.—Compensation for disturbance was strictly limited to such loss as “_the Court shall find_” to have been sustained by the tenant. The loss was often held to be the less the higher the rent. The amount of compensation could in no case exceed £250, and was limited to tenancies created after the passing of the Act. No compensation was to be given to tenants who had sublet or subdivided their holdings without the consent in writing of the landlord, or to any tenant under a lease for thirty-one years or upwards, and the landlord had a right of deduction from the amount awarded, for deterioration, &c. _Compensation for Improvements._ II.—The right to compensation for his improvements to be awarded to a tenant when quitting his holding was subject to so large a variety of exceptions as to greatly limit the number of tenants able to take advantage of the provision. Even when compensation was awarded, the landlord could deduct from the amount any arrears due for rates and taxes and for the loss due to the non-observance of express or implied covenants or agreements, and the Court in awarding compensation was required in reduction of the claim of the tenant to take into consideration the time during which the tenant had enjoyed the advantages of such improvements, and also any other benefits he had had. _Ulster Custom._