overboard. For this exclusion from the benefits of the Act there was, on
principle, no excuse. A Bill of Parnell's to remedy it was thrown out in
1883 by a majority of four to one, and the 35,000 tenants who suffered
from it were not entirely accorded the privileges of the other tenants
until the passing of the Rent Redemption Act of 1890. The average
reduction in rent effected for this class of tenant has amounted to 35
per cent.

One further fact in connection with the Act of 1881 deserves mention as
showing that though Parliament may propose a remedy for an admitted
grievance, the Courts of law are able to dispose its application by
their interpretation in direct contravention of the intentions of the
legislature.

Section 8, sub-section 9, of the Act of 1881 provided:--"No rent shall
be allowed or made payable in any proceedings under this Act in respect
of improvements made by the tenant or his predecessors in title, and for
which, in the opinion of the Court, the tenant or his predecessors in
title shall not have been paid or otherwise compensated by the landlord
or his predecessors in title." In the case of Adams _v_. Dunseath, in
February, 1882, it was held by the Court of Appeal, in the teeth of the
obvious intention of Parliament, that the fact that a tenant had for a
longer or shorter period of time enjoyed the benefit of his improvements
might be taken into consideration by the judge as being an equivalent
for compensation and as serving to limit the reductions in rent effected
by the Commission on land which had been subjected to these
improvements. By this interpretation many thousands of pounds were put
into the landlords' pockets during the years which intervened before
1896, when it was superseded by a provision in the Act of that year
which re-affirmed and established the principle, the enactment of which