If  the  estate  be  determined  by  the  act  of  the  lessor  or  of  God,
after  crops  have  been  sown,  the  tenant  is  entitled  to  emble-
ments ;  and  the  tenant  may  enter,  harvest  and  carry  away  such
crops  after  the  determination  of  his  estate.  The  reason  of  this
rule  is  that  the  tenant,  in  sowing  the  land,  had  a  reasonable
presumption  that  his  estate  would  continue  until  the  crops  ma-
tured, and  the  law  will  not  permit  that  he  should  be  prejudiced
by  the  imforeseen  sudden  determination  of  his  estate,  against
which  no  provisions  could  be  made.*"'  If  the  tenancy  be  deter-
mined by  the  tenant,  he  will  not  be  entitled  to  emblements."^

At  the  common  law,  a  tenancy  at  will  could  be  determined
without  notice,  at  the  will  of  either  party .^"

The  estate  was  also  determined  by  any  conduct  on  the  part
of  either  landlord  or  tenant  contrary  to  the  relationship  of
landlord  and  tenant,  and  from  which  an  intent  to  terminate
that  relationship  could  be  inferred.
Thus,  the  abandonment  or  surrender  of  possession  by  the
tenant  terminated  the  tenancy.
"'Harris  vs.  Frink,  49  N.  Y.,  24.
"'Carpenter  vs.  Jones,  63  111.,  517.
Klplinger  vs.  Green,  61  Mich.,  340.
'"Hilsendegen  vs.  Schelch,  55  Mich.,  468.
TENANTS  FROM  YEAR  TO  YEAR,  235

So,  the  conveyance  of  the  property  by  the  landlord  will,  at
common  law,  terminate  the  estate.  In  most  of  the  States  statutes
have  been  passed  requiring  a  notice  to  quit  to  be  served,  before
an  estate  at  will  can  be  terminated.  The  length  of  notice
varies  under  different  statutes.^  °°

TENANCIES  FROM  YEAR  TO  YEAR.
A  TENANCY  FROM  YEAR  TO  YEAR  IS  AN  ESTATE  FOR
AN  INDEFINITE  NUMBER  OF  DEFINITE  PERIODS.
