lord, but descended to the heir of the surrenderor. | are devised, the steward is entitled to fees as in Roe d. Jeffreys v. Hicks, 2 Wils. 13. A copyholder in fee surrendered to the use of another person, and afterwards, and before the admittance of the surrenderee, was convicted of simple felony: there being a custom in the manor that any tenant of customary tenements, who should commit and be convicted of felony, should forfeit his tenements to the lord :-Held, that the surrenderor, before admittance, was still tenant for the purpose of forfeiture, and that his estate was forfeited to the lord, and the surrenderee not entitled to be admitted. Rex v. Mildmay, 5 B. & Ad. 254. respect of a surrender to the use of the will, though such surrender is no longer necessary to the same amount as would have been payable for an actual surrender. Ib. Where, by the custom of a manor, surrenders were, before the statute, sometimes made in court, and sometimes out of court, and then presented in court, registered and enrolled, the payment is still to be made, the labour of the steward having been practically the same in each case. Ib. Where a steward refuses to admit except upon payment by the tenant of fines and fees not duly payable (as where the steward insists on Where a copyholder was convicted of a capital payments as for four admittances where payfelony, but pardoned upon condition of remain-ments are due in respect of one only, or of higher ing two years in prison, and the lord did not do any act towards securing the copyhold:-Held, that, at the expiration of the two years, the copyholder might maintain an ejectment for the land against one who had ousted him, inasmuch as the pardon restored his competency, and the estate would not vest in the lord without any act done by him. Doe d. Evans v. Erans, 5 B. & C. 584; 8 D. & R. 399. Estoppel of Tenant.]-A copyholder who has been admitted to a tenement, and done fealty to the lord of the manor, is estopped, in an action by the latter for a forfeiture, from shewing that the legal estate was not in the lord at the time of admittance. Doe d. Nepean v. Budden, 1 D. & R. 243; 5 B. & A. 626. Effect on Leases.]-See ALIENATION, infra. Forfeiture for Cutting Timber.]-See cases, supra, as to TIMBER. 2. STEWARD. Fees-Preparing Deeds.]-A steward of a manor sued in the county court a copyhold tenant for solicitor's costs attending the enfranchisement of his tenement. The tenant agreed to abide by the valuation of the surveyor named by the steward, and paid over the consideration and the surveyor's fee in accordance with that valuation. The steward's claim consisted of the costs of the enfranchisement deed, which the tenant had received from the steward: -Held, that this being a voluntary enfranchisement, the Copyhold Acts, 1852 and 1858, did not apply; therefore the steward was entitled to the charges for work done on the tenant's behalf, and the words "as steward," by which he described himself in the plaint, might be treated as surplusage. Blaker v. Wells, 28 L. T. 21. It is a good custom in a manor that the steward or his deputy should have the sole right of preparing all the surrenders of copyhold tenements within the manor. Rex v. Rigge, 2 B. & A. 550; S.P., Reg. v. Bishop's Stoke, 8 D. P. C. 608; 4 Jur. 630. Amount.]—A fee of 138. 4d., claimed in respect of special custom, would be rank. Traherne v. Gardner, 5 El. & Bl. 913; 25 L. J., Q. B. 201; 2 Jur., N. S. 394. Where admittance is claimed on behalf of joint tenants, the steward (in the absence of special custom) is not entitled to higher fees than upon the admittance of a single tenant. Ib. Under 55 Geo. 3, c. 192, s. 2, if copyhold lands VOL. II. fees to himself upon the admittance of joint tenants, than are due in respect of a single tenant), the tenant, if he pays the money under protest, is entitled to recover it back as money had and received. Ib. His right to recover the full excess is not lessened by his having, on one occasion, offered to pay, upon admittance, a sum including part of such excess, the steward not having accepted such offer. Ib. Under Lands Clauses Act.] - Where a steward of a manor was by custom entitled to one fee upon the surrender, and another on the admittance to copyhold lands :-Held, that under the Lands Clauses Act, 8 & 9 Vict. c. 18, s. 95, he was entitled to one fee only on a surrender. Cooper v. Norfolk Railway Company, 6 Railw. Cas. 94; 3 Ex. 546; 18 L. J., Ex. 176; 13 Jur. 195. Different Tenements.]-Where a person is admitted to several distinct copyhold tenements, the steward of the manor is not entitled, as a matter of general right, to the full fees on each admission separately; and therefore, where no custom prevails in the manor to that effect, he must stand on his quantum meruit. Everest v. Glyn, 2 Marsh. 84; 6 Taunt. 425; Holt, 1. U., a copyhold tenant, was owner of sixteen tenements, holden by sixteen separate copies of court-roll, and sixteen separate yearly quit-rents. He was admitted to these tenements at five different times, and by five different titles. An act passed, directing commissioners to allot the waste lands among the owners, in proportion to their rights and interests. The act directed that the allotted lands should be held by the allottees under the same tenures, rents, customs and services as the lands in respect of which they were allotted would have been in case the act had not passed; and that, where the lands were held under different titles or for different estates, the commissioners should distinguish the lands held for each of such estates and titles, and set out the The commissioners allotments accordingly. allotted to U., in respect of his sixteen copyhold tenements, five pieces of land, amounting to forty-nine acres, but did not distinguish in respect of which of the tenements, or of what particular estates, the five pieces were allotted. U. afterwards surrendered to E. the fifth allotment, and he was duly admitted to the same. Before the act passed, when any person was admitted in severalty to a part of a copyhold tenement, the steward of the manor was entitled, upon such admission, to the same amount of fees as if such person had been admitted to the whole M M of such tenement. In an action by the steward to recover sixteen fees in respect of the admission to the fifth allotment:-Held, that such allotment must be considered as an allotment of a portion of each of the sixteen former tenements, and that therefore the steward was entitled to recover sixteen fees. Erans v. Upsher, 16 M. & W. 675; 16 L. J., Ex. 185. Authority to receive Fines.]-The defendant having purchased copyhold land was admitted by C., who had acted as his attorney in completing the purchase, and had been appointed by the steward of the manor as his deputy for that turn to admit the defendant. Nine days afterwards the defendant gave C. a cheque on his bankers for 877. 108. 8d., viz., 781. 158. for the lord's fine, 4l. 118. 8d. steward's fees, 41. 48. C.'s own charges as the defendant's attorney. This cheque was crossed by the defendant at the request of C. to C.'s bankers. The amount of the cheque was duly paid by the defendant's bankers to C.'s bankers, who retained the money in discharge of a debt due to them by C., who had overdrawn his account. In an action by the lord against the defendant to obtain payment of the fine for the admittance-Held, by Bovill, C. J., and Montague Smith, J., that, assuming that the steward had power to appoint a deputy with authority to receive the fine for the lord, and that he did appoint C. as his deputy with authority to receive the fine, it could only be an authority to receive it in cash, or in that which was equivalent to cash, and might be handed over as it was received to the steward or the lord; and consequently that, as between the lord and the defendant, the giving to C. of a crossed cheque for a sum which comprised, besides the lord's fine, charges payable to the steward for his fees and to C. himself for his professional charges, was no payment to the lord-Held, by Byles, J., that C. had, under the circumstances, authority to receive the fine; and that the payment to him by the cheque was payment of the fine to the lord. Bridges v. Garrett, 4 L. R., C. P. 580; 38 L. J., C. P. 242; 17 W. R. 1072; 21 L. T. 141. Reversed, 5 L. R., C. P. 451; 39 L. J., C. P. 251; 22 L. T. 448; 18 W. R. 815-Ex. Ch. Liability.]-The steward of a court baron is a judicial officer; and therefore is not responsible for the acts of the regular bailiffs of the court to whom process is directed. Bradley v. Carr, 3 Scott, N. R. 523; 3 M. & G. 221. But he is responsible where he directs the process to bailiffs specially nominated by the party who sues it out, taking an indemnity. 1b. A steward of a manor is bound, when called upon, to deliver up the papers, of which he has the charge, in a proper condition. North-Western Railway Company v. Sharp, 10 Ex. 451. Displacement by Court.]-The court will not displace one steward without seeing that there is another to perform his functions. Windham v. Giubilei, 40 L. J., Ch. 505; 24 L. T. 653. And see ADMISSION, &c., infra. 3. THE COURT ROLLS. Custody of.]-On an application of the guardian ad litem of an infant lord of a manor, the court refused to order the steward to deliver up the court-rolls to the receiver in the cause, there being no suggestion of any improper conduct on the part of the steward. Windham v. Giubilei, 40 L. J., Ch. 505; 24 L. T. 653; and see NorthWestern Railway Company v. Sharp, supra. Inspection of.]-In a suit by plaintiffs against the lord of a manor, claiming as freeholders a tract of pasture or sheep-walk with the minerals and usual incidents of the ownership in fee-simple of freehold land, and expressly denying the exist ence of any rights of ownership in the lord over this sheep-walk, where the defendant by his answer stated that the plaintiffs were tenants of the manor, and as such had exclusive right of pasturage over the sheep-walk, but claimed as lord of the manor to be absolutely entitled to the soil of this sheep-walk, subject only to the plaintiff's right of pasturage :-Held, that the plaintiffs were not entitled to an inspection of the rolls of the manor. Owen v. Wynn, 9 Ch. D. 29; 38 L. T. 623; 26 W. R. 944—C. A. Reversing 38 L. T. 445; 26 W. R. 644. And see Minet v. Morgan, post, DISCOVERY. Mandamus to Inspect.]-The demand to inspect the rolls of a manor cannot be made by the agent of a person authorized by warrant of attorney to make the demand on behalf of the tenant, although the agent's authority is in writing, so as to obtain a mandamus in case of refusal. Hutt, Ex parte, 7 D. P. C. 690; 3 Jur. 1105. And see EVIDENCE. II. RIGHTS OF COPYHOLDERS. 1. NATURE OF TENURE AND GRANT. a. Generally. Period of.]-A copyhold must have been such time out of mind, and cannot be created within the time of legal memory. Roe d. Newman V. Newman, 2 Wils. 125. When there is no custom for that purpose, the lord of the manor cannot make a new grant of copyhold. Rex v. Hornchurch, 2 B. & A. 189. Perfecting Regularity.]-In order to constitute the grantee of a copyhold a perfect of court, such grant must be notified at the customary tenant, where the grant is made out next customary court, or at such other subsequent court as the custom points out, and must be entered on the rolls of the court. Whitaker, 3 N. & M. 225. Doe v. the court-rolls at a void court as at a good court, But it is sufficient if, having been entered on it appears on the court-rolls at a subsequent good court, and is not then objected to by the tenants. Ib. It is no objection to a copyhold grant that it is made upon the surrender of a former grantee former grant been expressly respited, and of in remainder, whose admittance had upon such whose admittance at any subsequent time there was no entry in the court-rolls. Ib. Nor is it an objection to the grant of several customary tenements by one copy of court-roll, that several rents are reserved, without specify- | remaindermen under A.'s will, claiming that ing which is reserved out of each tenement, it appearing that former entire grants of the same several tenements contained similar entire reservations. Ib. Nor is it an objection that two heriots are expressed to be reserved, where in former grants only one heriot has been reserved. Ib. A customary court cannot be held out of the manor, unless there is a custom to warrant it; and if a court is so held, all that is done at it is void. Ib. But the nullity of such court only affects such matters as are required to be done at a court. Ib. A lord may grant to and admit a copyhold tenant, not only out of court but also out of the manor. Ib. A grant by the lord in person is good, although it purports to be made at a court within the manor, which in fact was held out of the manor. 1b. The steward of a manor may take a surrender out of court. Ib. Ib. But a steward cannot admit out of court. But a voluntary grant of a copyhold, made by the steward at a court held off the manor, is sufficient where such steward is also clothed with a power of attorney, which expressly authorizes him to make voluntary grants. Ib. So, although the grant purports to be made by such steward, as steward, and without any reference being made in the grant to the special authority. 16. Alienation by Lord.]-A lord, having only a temporary estate in his manor, may make grants of copyhold to endure after the determination of his own interest; but such grants must conform strictly to the custom of the manor. Doe d. Rayer v. Strickland, 2 Q. B. 792; 2 G. & D. 278. An alienation of the fee by a lord of a manor does not affect the rights of a copyhold tenant. Phillips v. Ball, C. B., N. S. 811; 29 L. J., C. P. 7; 6 Jur., N. S. 48. Therefore, where a lord had granted the inheritance of a portion of the manor to A. — Held, that it was competent to a copyhold tenant to dispose of his interest to a grantee by an ordinary common-law conveyance; the customary mode of conveyance being rendered impossible by the act of the lord. Ib. Void Grants by Lord.]-A lord of a manor cannot grant copyhold lands to his wife; if he does the grant is void. Firebrass d. Symes v. Pennant, 2 Wils. 255. Grants of copyhold are ineffectual and void in law, when made by the lord to himself. Christchurch Orford (Dean and Chapter) v. Buckingham (Duke), 17 C. B., N. S. 391; 33 L. J., C. P. 322; 10 Jur., N. S. 749; 10 L. T. 575; 12 W. R. 986. Effect of Devise for Life.]-A., who held lands of a manor, devised them to three trustees and their heirs to the use of B. for life, with remainders over. After A.'s death B. was admitted and enjoyed the lands during his life. He died, having by his will, according to the custom of the manor, nominated his successor. He nominated a stranger. On a bill by the the power of nominating a successor was vested in B. by virtue of the will, and that therefore it must be exercised by him in reference to the limitations of the will, and not in favour of a stranger :-Held, that B. was customary tenant under the will, and also a trustee for the purposes of the will, and that every right which he had acquired by admission on the court-rolls was, beyond his own life estate, held for the benefit of the remaindermen. Allen v. Bewsey, 7 Ch. D 453; 37 L. T. 688-C. A. Customs.-There is no general custom for all copyholds. Everest v. Glyn, 6 Taunt. 425; 2 Marsh. 84; Holt, 1. Occupancy.]-Copyhold estates are liable to special occupancy. Doe d. Lempriere v. Martin 2 W. Bl. 1148. And see Zouch . Forse v. Forse, 7 East, 186; 3 Smith, 191. Wastes. If there is a custom within a manor for a lord to grant parcels of the waste by copy of court-roll, the premises granted in that mode are well described as copyhold premises, though the date of the grant is modern. Northwick (Lord) v. Stanway, 3 B. & P. 346. A grant of parcel of the waste of a manor to hold to B. and his heirs by way of increase to his copyhold, by such services as the copyhold was subject to. for which B. paid a fine of 108., does not enure as copyhold, there being no custom to warrant such grant, nor as an estate in fee-simple. Rex v. Wilby, 2 M. & S. 504. After a grant of the soil of wastes to trustees for the use of the copyholders of free socage, the lands, when inclosed, will be freehold, and not copyhold. Revel v. Jodrell, 2 T. R. 415. There is no general common-law right of tenants of a manor to common appendant on the waste. Dunraven (Earl) v. Llewellyn, 15 Q. B. 791. And see COMMONS. Divided Enjoyment.] - One may hold the prima tonsura of land as copyhold, and another may have the soil and every other beneficial enjoyment of it as freehold. Stammers v. Dixon, 7 East, 200; 3 Smith, 261. Grant of Reversionary Estate.]-Under a grant by copy of court-roll of a reversionary estate to A. (who had before a life estate in the premises) habendum to him for the lives of B. and C., his grandsons, during the life of either of them longest living, successively, according to the custom, reserving a heriot and 68. rent; A. only takes the legal estate in reversion, and not the cestuis que vie, there being no custom to enable them to take, although they were stated to be admitted tenants in reversion. Right v. Bawden, 3 East, 260. Trusts.]-Where a lord of a manor admits a tenant upon the trusts of an indenture referred to in the surrender, he is to be considered as consenting to those trusts, and is bound by them upon the death of the trustee without an heir. Weaver v. Maule, 2 Russ. & Mylne, 97. But, in the absence of custom, he is not bound to make a surrender by deed burthened with trusts. Flack v. Downing College, Cambridge, | been thrown into the garden of the other forty 13 C. B. 945. There may be such a custom. Snook v. Mattock, 5 A. & E. 239. W., tenant by copy of court-roll for his life, took, according to the custom, a grant from the lord of the reversion to C. and D., his sons, for the term of their lives, in trust for W., as sole purchaser-Held, that C. and D. were trustees of the reversion for W. Keats v. Hewer, 10 Jur., N. S. 1040; 11 L. T. 209; 13 W. R. 34. - Corporation.] A corporation cannot hold land by copy of court-roll. Att.-Gen. v. Lewin, 1 Cooper, 51. Form of Tenure.]-Where lands are held by copy of court-roll, according to the custom of the manor, they are copyhold within 55 Geo. 3, c. 192, although they are not held at the will of the lord. Doe d. Edmunds v. Llewellyn, 2 C., M. & R. 503; 1 Gale, 193; 5 Tyr. 899. years ago by the then common proprietor, and the boundary-line being left doubtful on the plans-Held, that the fact that the piece in question had actually been occupied with the leasehold property for more than twenty years, was conclusive. Tear v. Taylor, 1 F. & F. 480. Customary estates, which are peculiar to the north of England, are not freehold, but seem to fall under the same general consideration as copyholds; alienable by bargain and sale, and admittance thereon, and not holden at the will of the lord. Doe d. Reay v. Huntington, 4 East, 270. The difference between copyholders and customary tenants explained. Vaughan d. Atkins v. Atkins, 5 Burr. 2764. The freehold of an estate, parcel of a manor, and demisable only by licence of the lord, passing by surrender and admittance, to which the tenant was admitted by the description of a customary tenement, to have to her and her heirs, to hold of the lord by the rod, according to the custom of the manor, by the accustomed rent, suit of court, customs and services, is in the lord, and not in the tenant, though not holden at the will of the lord. Doe d. Cook v. Danvers, 7 East, 299; 3 Smith, 291. In a manor there are customary tenures of the following nature:-The court of the manor is held twice a year; the steward, having summoned a jury of the freeholders, presides in the court. An applicant for a tenement in the manor goes through the following forms: he is asked by the steward for what purpose he attends there; he says that he seeks to be admitted as tenant of a house, as purchaser, devisee, or as the case may be. The steward inquires of the foreman of the jury if he knows of any objection to the admission of the applicant ; should he not do so, the steward, after hearing the whole discussion, decides granting or refusing the application, according to his judgment. If the application is granted, the name of the outgoing tenant is struck out of the roll by the steward, who inserts the name of the applicant in its place. The applicant Where the copies of admission were anciently does not hold by copy of the manor-roll. "to hold of the lord according to the custom of applicant takes the oath of fealty and pays to husbandry of the manor," but other copies were the steward a fee, but no fine is paid to the lord to "hold at the will of the lord" also, and all the of the manor -Held, that the holder of such a modern copies were so :-Held, that this land was tenure, provided its yearly value amounts to 107., copyhold, and not customary freehold. Bourn was entitled to vote as being seised of copyhold V. Rawlings, 3 Smith, 405; S. C., nom. Brown v. or other tenure, within the meaning of 2 Will, 4, Rawlings, 7 East, 509. c. 45, s. 19. Garbutt v. Trevor, 15 C. B., N. S. 550; 1 H. & R. 69; 33 L. J., C. P. 73; 9 L. T. 535; 12 W. R. 471. The One who holds in fee land parcel of a manor, which by the custom of the manor is conveyed by ordinary assurance, and without any necessity for a licence from the lord, or any enrolment and admittance, is a freeholder within 8 Hen. 6, c. 7, although at the time of acquiring the estate he acknowledged to holding the land "by free deed, fealty, suit of court," &c. Passingham v. Pity, 17 C. B. 299; 25 L. J., C. P. 4; 2 Jur., N. S. 837. Leases.-A lessee for years of a copyholder may maintain ejectment, though there is no custom in the manor to lease, and no licence has been obtained from the lord, such lease being good between the parties to it, and void only as against the lord. Doe d. Tresidder v. Tresidder, 1 Q. B. 417; 1 G. & D. 70; 5 Jur. 931. Presumption as to Boundaries—-Occupancy.] -In ejectment between the purchasers of copyhold and leasehold properties adjoining, the question being as to the limits of the garden ground of each, a portion of the garden of one having Where, according to the custom of a manor, the customary tenements pass by lease and release and admittance, although no surrender is required, the freehold is in the lord, and not in 14 L. J., C. P. 268; 9 Jur. 927. the tenant. Thomson v. Hardinge, 1 C. B, 940; Purchase by Lord.]-Where a customary tenement is freehold, and the lord, being only tenant for life of the manor, purchases the fee of the customary tenement, the seigniory is suspended during the life of the lord, but revives at his death, and the customary tenement descends to his heir. Bingham v. Woodgate, 1 Russ. & Mylne, 33. Where the custom of a manor requires a bargain and sale, as well as a surrender and admittance, to pass the customary tenement, the freehold is in the tenant, and not in the lord. Ib. Conveyance by Lord.]-Where a feme sole, after marriage, was admitted tenant of a manor in the north of England, of certain premises to her and her heirs, as of her own tenant right, according to the custom; and afterwards the lord executed a conveyance of the same premises to the husband in fee, and enfranchised the same from all seigniory rights to which they were out of court, and execute the deed of bargain previously liable; it seems that this conveyance, after his death, did not operate by way of grant of the estate in fee, but as an enfeoffment of the tenant-right estate; and that the wife's estate became a tenancy in fee-simple, and descended upon her heirs; and that those who derived title from them had a right to claim as heirs ex parte maternâ. Doe d. Newby v. Jackson, 2 D. & R. 514; 1 B. & C. 448. If the lord of a manor conveys a customary estate to the tenant, he cannot reserve to himself the ancient services; for the tenant, by reason of the statute of quia emptores, must then hold of the superior lord. Bradshaw v. Lawson, 4 T. R. 443. A copyhold, to which a right of common was annexed, having by the custom of the manor vested in the lord by forfeiture, and been regranted by him as a copyhold tenement with the appurtenances -Held, that it having always continued demisable, whilst in the hands of the lord, it was a customary tenement, and, as such, was still entitled to the right of common. Budger v. Ford, 3 B. & A. 153. Renewals.]-The conventionary tenants within the assessionable manors of the duchy of Cornwall, have a perpetual indefeasible right, to them and their customary heirs and surrenderees, to renew their estates from seven years to seven years. Rowe v. Brenton, 3 M. & R. 361; 8 B. & C. 758. Admission-Succession to.]-If the custom of a manor is that the customary tenements are held to a tenant and his heirs, and when a tenant dies seised, leaving sisters only, go wholly to the eldest sister, in exclusion of the other sisters, or, if such eldest sister dies during the life of such tenant, to her heir in exclusion of her younger sisters; there, if the heir of a tenant who had been admitted and died seised, enters but dies without being admitted, he nevertheless dies seised, and the custom attaches in respect of his sisters. Doe d. Hamilton v. Clift, 4 P. & D. 579; 12 A. & E. 576. But, if the customary estate is, not a customary estate of inheritance, to which the tenant is admitted to hold to him and his heirs, but one to which he is admitted to hold during the joint lives of himself and the lord, with a tenant-right of renewal binding the lord to admit the customary heir of a tenant; there, if the customary heir is not admitted in his lifetime, though he enters, he has no estate, and does not die seised, and the custom does not attach. Ib. Necessary to Pass Estate.]-In a manor the custom of tenure is tenant right; the freehold of the customary tenements is in the lord. On alienation a deed of bargain and sale is executed by the parties. The alienor appears with his deed in court; and, after proclamation, the steward says to him, "You (alienor) surrender into the hands of the lord of this manor the premises (specifying them as on the roll), to the use and behoof of the alienee, his heirs and assigns, according to the custom. Are you content to make this surrender?" The surrenderor (alienor) says, "Yes." After proclamation, the alienee is admitted tenant of the premises. When husband and wife surrender lands out of court, they appear before the lord. his steward, or deputy, and sale; the wife is separately examined, and the surrenderor taken before the lord, his steward or deputy, with the exception that there is no proclamation. There is no instance of a married woman surrendering lands within the manor by attorney. Surrenders, and also admittances by the custom of the manor, may be made out of court, and they may be made by or to the parties themselves or their attorneys. M. and E. his wife, being seised in right of the wife of customary tenements within the manor, E., after a separate examination, executed a deed of customary bargain and sale; by which M. and E. bargained, sold, aliened, surrendered and confirmed unto T. M., his heirs and assigns, the customary tenements in question; and by which, also, they severally and respectively appointed an attorney for them, and in each or either of their names, to surrender the customary tenements into the hands of the lord, according to the custom, to the use of T. M., his heirs and assigns, for ever. At a special court held on the following day the attorney for M. and E. made a formal surrender for them accordingly; and T. M. being thereupon admitted tenant in person, the jury made and signed their presentment of the alienation. At the time when this was done E. was dead :-Held, first, that, by the custom of the manor, surrender and admittance, as well as bargain and sale, were necessary to transfer an estate in the customary tenements; and that, therefore, the estate in the customary tenements did not pass by the deed of bargain and sale only. Graham v. Jackson, 6 Q. B. 811; 14 L. J., Q. B. 129; 9 Jur. 275. Held, secondly, that the power of attorney to surrender was invalid in its inception; and, if not so, was revoked by the death of the wife; and that, therefore, the surrender was inoperative. Ib. Compelling.]-The 3 & 4 Will. 4, c. 74, s. 53, only applies to equitable estates of tenants in tail of lands held by copy of court-roll; the court, therefore, refused a mandamus to the lord of a manor, commanding him to enter on the court-rolls an indenture touching certain customary freehold hereditaments, although it appeared that the steward of the manor was accustomed to give admittances signed by him to the grantee of such hereditaments, but did not enrol the deed by which they were granted. Reg. v. Ingleton, 8 D. P. C. 693; 4 Jur. 700. Enfranchisement of.] See ENFRANCHISEMENT, infra. --- c. Quasi Tenancy by Curtesy. Admittance.]—A copyhold having descended to a wife as heir-at-law, who died before admittance, having first borne a child to her husband, which died an infant, the husband was held entitled to hold for his life, in the nature of a tenant by the curtesy of England, according to the custom of the manor, though the only evidence of such custom on the rolls was three instances of husbands admitted as tenants by the curtesy, according to the custom, whose respective wives had been admitted during their lives; the title of a wife claiming as heir by descent being complete without admittance, by the general law of copyhold, and the title of a tenant by the |