8. How then is the rule to be applied to leaseholds for lives? There
appear to be four ways. The first, by insuring the life of the new cestui
que vie for the amount of the fine, and compelling the tenant for life in
possession to keep down the interest and pay the premiums upon the
policy; the second, by estimating the probable benefit derived by the

(h) Jones v. Jones, 5 Hare, 463 ; Huddleston v. Whelpdale, 9 Hare, 485.
(i) White V. White, 9 Yes. 558.
(k) Nightingale t. Lawson, 1 Bro. 0. C. 440.
August, 1853 — 12



178 bunyon's lite asstjkancb.
tenant for life or successive tenants for life and remainderman b^ the ad-
dition of the new life, and dividing the fine in such proportions; the third,
by waiting until the death of the tenant for life, and then estimating the
proportions according to the result then experienced ; and lastly, by wait-
ing until the lapse of the additional life, and estimating the term thereby
gained as if an absolute term.
Of these four methods the first alone recommends itself as possessing
both simplicity and perfect justice. The burden of the fine is imposed
upon the income during the term of the life of the new cestui que vie,
and is borne by the recipients of that income in exact proportion to their
receipts. It is also equally easy of applioationj however numerous the
successive tenants for life.
