distrain on the goods of a sub-tenant, although that tenant may have paid his rent to the tenant-in-chief. An exhibition of pictures was thus seized for ground rent, within the last year or two; and we all remember the disgraceful scene at the close of the dress exhibition, where the same thing happened. In that case, the property seized belonged to foreign exhibitors. What should we say if such a thing happened to English exhibitors in Berlin or Paris?
The ground landlord can force an outgoing tenant to put a house into repair, although it is intended to pull it down. In such a case, however, he sometimes accepts a sum of money for the repairs which are never to be made. Even should the house fall down, the leaseholder must put it up again. A very flagrant instance of this occurred some sixteen years ago, and owing to the tenant's resistance, is not yet settled. A lady took over the remainder of a lease of ninety-nine years. The ground landlord, a great nobleman who owns whole districts of the west end, in granting the original lease, inserted the usual clause stipulating that the house to be built upon the land should be constructed "in a suitable and workmanlike manner," and of course the further clause, that at the expiry of the ninety-nine years the house should be handed over "in good and habitable order." It must be obvious that this condition implies that the house is capable of standing at least till the expiration of the lease. The house in question, however, was a bad case of "jerry-building"—a fact which escaped the notice of the duke's surveyors. Only about twenty-seven of the ninety-nine years had expired when the original lessees sold the remainder of the lease to Miss J. M. Scott; and in three years more the house collapsed. The collapse was so serious that the Metropolitan Board of Works condemned the house as "a dangerous structure." The builder sent to examine the damage was astonished that it had stood upright so long, considering the manner in which it had been built—now fully revealed by the collapse. By every rule of equity, the cost of making the house safe and habitable ought to have been shared between the ground landlord and the original lessees; the surveyors of the former had passed the house as well built, and the original
