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Updated: May 18, 2025
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.
Dunseath tried out in accordance with Mr. Gladstone's panacea, Adams, after repeated lawsuits, improved his financial position by an infinitesimal sum per annum without becoming an owner of his farm. It was also agreed that the Estates Commissioners appointed to administer the Act, should be administrative officials under the Government, and not amateur judges.
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