A tenant whose estate is terminated by an uncertain event which he could neither foresee nor control, is entitled to the annual crop which he sowed while his estate continued, by the law of emblements. But a tenant for years knows when his lease will expire. Nevertheless he has usually some right to the crop he sowed, and to so much possession of the land as may be necessary to getting in the crop; but this right must depend either on agreement or on usage. At common law he has no such right. (p) 1 The local usages of this country, in this respect, vary very much, and are not often distinctly defined or well established. Thus, there is some uncertainty as to the property in the manure of a farm. Generally, in this country, the outgoing tenant cannot sell or take away the manure, (q)2 although it would seem that in England he can. (r)

(o) Reeve v. Bird, 1 C. M. & R. 31; Walls v. Atcheson, 11 J. B. Moore, 379; Woodcock v. Nuth, 8 Bing. 170; Thomas v. Cooke, 2 B. & Ald. 119; Johnstone v. Hudlestone, 4 B. & C. 922.

(p) Caldecott v. Smythies, 7 C. & P. 808; Wigglesworth v. Dallison, Dougl. 201. See also Griffiths v. Puleston, 13 M. & W. 358; Strickland v. Maxwell, 2 Cr. & M. 539; Boraston v. Green, 16 East, 71; Davis v. Cannop, 1 Price, 53; Beavan v. Delahay, 1 H. Bl. 5; Knight v. Banett, 3 Bing. 364; Hutton v. Warren, 1 M. & W. 466; Senior v. Armytage, Holt, 197; Webb v Plummer, 2 B. & Ald. 746; Holding v. Pigott, 7 Bing. 465. By the custom of Pennsylvania, the right of the tenant for a definite term to his away-going crops, seems to be well established. Diffedorffer v. Jones, cited in Carson v. Blazer, 2 Binn. 487, and in Stultz v. Dickey, 5 Binn. 289; Comfort v. Duncan, 1 Miles, 229; Demi v. Bossier, 1 Penn. 224. Such is the case also in New Jersey. Van Doren v. Ever-itt, 2 Southard, 460; Templeman v. Bid-die, 1 Harring. (Del.) 522.

(q) Lassell v. Reed, 6 Greenl. 222; Staples v Emery, 7 Greenl. 201; Daniels v. Pond, 21 Pick. 367, 371; Lewis v. Lyman, 22 Pick. 437,442; Middlebrook v. Corwin, 15 Wend. 169; Lewis v. Jones, 17 Penn. St. 262. See also Kittredge v. Woods, 3 N. H. 503.

(r) See Roberts v. Barker, 1 Cr. & M

1 Under a five years' lease, ending July 18, the tenant was allowed to take hay maturing a week earlier, if good farming, though he had the hay ripening in first year of lease. Willey v. Connor, 44 Vt. 68. - K.

2 A covenant by a lessee not to carry away manure, etc, is a reservation to the lessor. Heald v. Builders' Ins. Co. 111 Mass. 38. If manure is a tenant's personal property, he does not lose his title by leaving it on the farm when he quits. Fletcher v Herring, 112 Mass. 382. If a dairy farm is also cultivated, the manure belongs to the lessor. Bonnell v. Allen, 53 Ind. 130. A tenant for two years cannot take manure under a provision that he shall substitute dressing for hay removed. Hill v. De Rochemont, 48 N. H. 87. - K.