[1], Missouri has two statutes that prescribe a harsh remedy for waste. market value (MV); See
This principle is established in the French law. Waste is a legal theory that gives rise to a cause of action by the remainderman. [Last updated in June of 2022 by the Wex Definitions Team], Ameliorative waste refers to modifications that increase the value of, While traditionally ameliorative waste entitled the property owner to. on Inj. Life v. Harris Trust & Savings Bank, 859 F Supp 1163, 1165 (ND Ill 1994); Anno: 55 ALR3d 1041: Appointment of Receiver"Waste"). The total damages were alleged to be $16,159.00, but was found by the district court to be $10,433.00. Nonetheless, not all use of land depletes it, and some uses like routinely harvesting crops on a farm do not qualify as affirmative waste. The remainderperson would argue that the cutting imperils the productive use of the land in the future, because the value of the land after the immature trees have been cut would be decreased. They argued . 3 Yeates, R. 261;
(D) 'Equitable' wastewanton or malicious damage or destruction; "that which a prudent man would [definitely] not do in the management of his own property", Turner v Wright (1860) 2 De GF & J 234, 243, 45 Eng Rep 612 (Storey's Equity Jurisprudence (14th ed. Because of this, some states dont allow owners to claim damages when ameliorative waste has occurred since the landlord has actually benefited from them. improper tillage. For similar terms with different meanings, see. They fail to notify the landlord but do put a small bowl down to catch the drips. The surviving spouse of a person who dies intestate, meaning without a will, or the surviving spouse who has submitted a petition to the court for an elective share, may take a life estate in one-third of the value of all the real estate the deceased spouse possessed. that the landlord is entitled to recover from the tenant the costs of preparing and serving a notice under s.146 of the Law of Property Act 1925 (the preliminary to forfeiture of the lease). 392; S. C. 1 Moore, 100; 1 Saund. & T. 447; 2 Yeates, 281; 4 Smith's Laws of Penn. v. Spencer's Kenosha Bowl, 137 Wis.2d 313, 404 N.W.2d 109, 113 (Wis App 1987)no longer recognizing a distinction between 'active' and 'passive' waste; Cf. Waste; Whart. it may be brought by him in reversion or remainder for life or years, as
Comm. Fixtures; Bac. fair wear and tear(BrE), improvement, wear and tear(AmE). Permissive waste In property law, this refers to harm to a piece of property, such as the land falling into disrepair, caused by a tenant's neglect of the property. Rep. 277; Bac. cut timber on a non-timber estate or open new mines, and he is then said to be 'unimpeachable' for waste, although he is generally restrained from committing equitable waste (Lewis Bowles Case (1615) 11 Co Rep 79b; Vane v Barnard (Lord) (1716) 2 Vern 738, 23 Eng Rep 1082; The American Law Institute, Restatement of Property (St. Paul, MN: 1936), 141, Comment (a)). You have successfully signed up to receive the Casebriefs newsletter. They are sometimes also called negligent waste, passive waste highest and best use; however, and many of the other states, the law has applied itself to our
cultivation, without being liable to waste, but he cannot cut down the whole
This can be an odd situation for a landlord to find himself in. Permissive waste refers to an injury caused by an omission, rather than an affirmative act, on the part of the tenant. B loves studying ancestry and hopes to one day live in the historic building on his family's land. 1918), 1242; Camden v. Handle, supra at 871). 596 (1932)). the jury under the direction of the court. Prudential Ins. Friedman. Law Practice, Attorney And to what extent the wood and
Rather than requiring some bad act on the part of the tenant, this requires the failure to maintain ordinary repairs, pay taxes, or pay interest on the mortgage by the life tenant or the lessee of a leasehold estate. 13.-Sec. 59 M. Where the tenant, by the conditions of his lease,
Under English common law, when ameliorative waste occurs, the interested party can recover from the tenant the cost of restoring the land to its original condition. More Real Estate Terms Voluntary waste. 8. Wake County, North Carolina: Register of Deeds, North Carolina General Statutes: Chapter 41, Estates, North Carolina General Statutes: Article 28, Special Duties to Pay Taxes, North Carolina General Statutes: Chapter 29, Intestate Succession, North Carolina Department of Health and Human Services: MA 3226-Estate Recovery. 53, a; and taking it down after it is built, is a waste. The first type of waste is called permissive waste. The Law Landlord's Liability On private land, it is the responsibility of the landowner to remove the waste and dispose of it legally. The remainderman may sue for waste in compensatory damages, for injunctive relief in equity, or for receivership. 1 Woodfall's Law of Landlord and Tenant (London: Loose-leaf), 13.10813.130. 252, n. See,
When most people think of a devise or other grant of property, they assume it is a complete and absolute transfer of that property, but this is not always the case. This dont just result in repair costs to the landlord, but might also cause a depreciation of property value. Dig. This relaxation of the old rule has taken place between two descriptions of persons; that is, between the landlord and tenant, and between the tenant for life or tenant in tail and the remainder-man or reversioner. Permissive waste. Oxford: 2006), pp. the lessee himself, unless they were erected for the purposes of trade. It results from a tenant's failure to make normal repairs to property so as to protect it from substantial deterioration. Waste may be classified as: (A) 'Permissive' waste (in the US, also called 'negligent' or 'passive' waste)failure to do that which ought to be done, as by negligence, or an omission to make necessary repairs, so that a property is permitted to fall into a state of decay, e.g. Waste is a term used in the law of real property to describe a cause of action that can be brought in court to address a change in condition of real property brought about by a current tenant that damages or destroys the value of that property. Equitable waste is a harm to the reversionary interest in land that is inconsistent with fruitful use. Waste, D 2. Waste can be caused either by acts of commission or acts of omission. 78 Am.Jur.2d., Waste (Rochester, NY), 143. Waste is a term describing neglect or misconduct, but does not refer to ordinary depreciation. The latter action has this advantage over an action of waste, that it may be brought by him in reversion or remainder for life or years, as well as in fee or in tail; and the plaintiff is entitled to costs in this action, which he cannot have in an action of waste. The tenant notices that a central heating radiator is dripping from a valve. Causing damage to piping and insulation systems. . This information should not be considered complete, up to date, and is not intended to be used in place of a visit, consultation, or advice of a legal, medical, or any other professional. 499, 501 (1909); Finley v. Chain, 374 N.E.2d 67, 79 (Ind App 1978); 30 C.J.S., Waste (St. Paul, MN), 1). The court held that the neighboring properties had sufficiently changed the nature of the area and allowed the estate holder to convert the land despite the existence of potential ameliorative waste. It involves some positive act of injury to the property, thereby diminishing its value for the person next in succession. In an action on the case in the nature of waste, the plaintiff recovers only damages for the waste. A Law Dictionary, Adapted to the Constitution and Laws of the United States. Voluntary waste. . Voluntary waste is waste caused by willful destruction or carrying away of something attached to the property. This Cause of Action is recognized only by courts of Equity and is not regarded as legal waste in courts of law. Active waste- When an act is done which causes major waste of the property or leads to the reduction in the value of mortgaged property, then the mortgagor will be liable to the mortgagee. The type of waste being examined in connection with the premises where Wife resides is permissive waste. Inst. "Waste, vastum, is a spoil or destruction in houses, gardens, trees, or other corporeal hereditaments, to the detriment of him that has the remainder or reversion in fee simple or fee tail", 2 Bl Comm 281 (Powys v Blagrave (1854) 4 De GM & G. 448, 43 Eng Rep 582; Keogh v. Peck, 316 Ill 318, 147 NE 266, 268, 38 ALR 1115, 1157 (1925); Camden Trust Co. v. Handle, 132 NJ Eq 97, 26 A.2d 865, 867 (1942); Jowdy v. Guerin, 10 Ariz App 205, 457 P.2d 745, 748 (1969)). Charlottesville, VA: 1994- ), Ch. This question is now before us as a result of a claim of waste made by the holder of a second mortgage on commercial property against the mortgagors (grantors of the Deed of Trust), after the holder failed to recover its loan amount when the property was sold at foreclosure. G.S. Landl. As between the landlord and tenant it is now the law, that if the
Friedman on Leases (5th ed. The district magistrate sustained the defense of laches or estoppel, which upon appeal to the district court, was rejected as a defense and judgment was entered in favor of the remaindermen. See 6 Ves. made to this rule, which were at last effectually engrafted upon it in favor
n. 2400. A spoil or destruction houses, gardens, trees, or other corporeal
What Happens if the Remainderman in a Life Estate Deed Dies? Permissive waste in houses is punishable where the tenant is expressly bound to repair, or where s/he is so bound on an implied covenant. whether it be larger or smaller than the first; 2 Roll. 57 111. Those implied by statute; 2. the same as when he entered. A remainderman who pays taxes on the property may recover their money in an action against the life tenant. B can sue A for ameliorative waste and get an injunction preventing the construction of the club. Intr. a, n. i. Permit or License Applicant [Endangered Species], Asbestos-Containing Waste Materials [National Emission Standard for Asbestos], Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal, Corrosion Expert [Hazardous Waste Management], Eligible Solar, Wind, Waste or Geothermal Facility. dential shifts in American property law before moving on to the current status of waste law in the United States, with special at-tention paid to the modern tenant's obligations under permissive waste. cut down trees for the reparation of the houses, fences, hedges, stiles,
Cutting down fruit trees; 2 Roll. grosses reparations(F); Cluster development is a type of site planning where a Get email updates on what is going on and the occasional free stuff ;). Certain laws provide for temporary relief if acts of waste are either threatened or committed. Examples of equitable waste are cutting down trees that are clearly meant to be ornamental or taking away elements (roof, windows, floor boards, etc.) strata title; n. 1) any damage to real property by a tenant which lessens its value to the landlord, owner or future owner. Estate An easement is a right to use another person's real estate for a specific purpose. The Court found that the majority of the waste occurred in the last two to three years of the life tenancy and that the remainderman Moore attempted to communicate her concerns about the deterioration of the property to the life tenant, who did nothing. In areas that have waste statutes, the statutes may require forfeiture of the possessors interest in the land. 2,
W.B. R. 339; 2 Hayw. the house was uncovered when the tenant took possession. 6. (ii) 'Permissive waste' occurs when the property is allowed or permitted to fall into disrepair, eg, by the life tenant's failure to maintain a house, or fences, or to clean the drains. Peter completed a Bachelor of Arts in Psychology and Philosophy from Western Washington University. In the US, the cutting of timber and similar acts when in the interests of "good husbandry" or "reasonable use" of the land is not considered as waste, especially where new land was opened up for use and occupation (5 Am.L.Prop., 20.5). Every Bundle includes the complete text from each of the titles below: PLUS: Hundreds of law school topic-related videos from In common law, a tenant for a term of years is liable for voluntary and permissive waste, unless excused by agreement or by the consent of the landlord (Davies v Davies (1888) 38 Ch D 499; Dayani v Bromley London Borough Council [1999] 3 EGLR 144; 51C C.J.S., L & T (St. Paul, MN), 261). Damages resulting from waste are beyond regular wear and tear. 3. 14. Prescriptive easement denied because longstanding use of neighboring land was presumed to be permissive July 19, 2017. leasehold enfranchisement; Are the claims raised by the remaindermen for waste filed eleven years after the creation of the life estate (and the death of the life tenant) barred by laches or estoppel? The tenant may
Marital property is real or personal property acquired during the course of the parties' marriage through the use of marital funds, or through the sale of additional marital property. Copyright 1999-2023 LegalMatch. For example, if a life estate owner on a farm destroys an out of use barn to plant more crops, the remainder owner can no longer sue for ameliorative waste in the United States because the economic value of the farm increased overall. A person found to have committed voluntary waste without the written permission of the holder of the future interest is forced to pay treble damages to the holder of the future interest, and the person's present interest (whether a life estate or a lease) is automatically terminated. If the surviving spouse has a life estate in the home, the real property is usually protected from Medicaid claims after five years from the transfer date. 6. Permissive Waste Law and Legal Definition Permissive waste refers to an injury caused by an omission, rather than an affirmative act, on the part of the tenant. a leaseholder), is responsible for repairs unless they are expressly undertaken by the landlord. the freehold during the term, and afterwards takes it away, it is waste. Voluntary waste describes intentional actions taken by the possessor to cause damage to the property. restoring a dilapidated building or changing the method of husbandry in order to improve the profitability of the land (London (City of) v Greyme (1607) Cro Jac 181, 79 Eng Rep 158; Meux v Cobley [1892] 2 Ch 253, 263; J.H. A property owners' association or another "representative designated by an owner" may file a lawsuit to enforce a restrictive covenant. Even where the lessee covenants not to do waste, the lessor has his
Waste is a term used in property law to describe a cause of action that can be brought in court to address a change in condition of real property brought about by a current tenant that damages or destroys the value of that property. bargain and sale; This doctrine fits under the broader framework of equity, in which a legal right to do something is not so unrestrained that it is impossible to abuse that right. down ornamental trees, or those planted for shelter; 6 Ves. On the one hand, a tenant might have the best intentions to improve the quality of life and also help the property appreciate. 53, b; and for mixing and repairing all
All content on this website, including dictionary, thesaurus, literature, geography, and other reference data is for informational purposes only. It is one of the four types of tort of waste, which is to be distinguished from the concept of waste under environmental law. A prerogative or liberty, on the part of the crown, of committing waste on the lands of felons, by pulling . This prevents the remainderman from failing to receive the full recovery from the insurance company in the event that there is an accident resulting in the death of the life tenant. According to Texas Homeowners Association Law, the end result most typically . accounted here. "I1 . More commonly, the tenant breaks a window, damages walls or woodwork, or otherwise damages the apartment. There are 3 main types of waste as described in legal terms. Generally, there are two types of waste: If waste has occured, damages may include: The law of waste is very complex and can differ drastically from state to state. 375; 2 Swanst. It has been decided that a tenant for years may remove cider-mills,
hereditaments, to the disherison of him that hath the remainder or reversion
Stoebuck & D.A. permissive waste. 430 (Mich 1916)). Person B is willed to inherit the estate after A dies. The tenant may cut down trees for the reparation of the houses, fences, hedges, stiles, gates, and the like and for mixing and repairing all instruments of husbandry, as ploughs, carts, harrows, rakes, forks, etc. This case should be read closely because it provides a good illustration of key concepts of law and equity. Was this document helpful? The defenses of laches and estoppel are based on the theory that the delay in filing suit has caused the defense prejudice in their ability to defend the suit, and that it would be unfair to allow the suit to proceed. It is adapted to our circumstances. The related rules section is for members only and includes a compilation of all the rules of law in Quimbee's database relating to this key term. en.wiktionary.org permissive waste ConceptNet 5 is licensed under a Creative Commons Attribution-ShareAlike 4.0 International License. Waste is an unreasonable or improper use of land by an individual in rightful possession of the land. lessee may fell a part of the wood and timber, so as to fit the land for
281, note by Chitty. Rep. 334. action, which he cannot have in an action of waste., 2 Saund. 4. relation extends only to erections for the purposes of trade. For example, imagine a property owner who has the most convenient access point to a public hiking trail. Com. Peter is also an editor and writer, and you can find out more about him by checking out his Linkedin page. 268, n. F; 1 Eq. It has been decided that a tenant for years may remove cider-mills, ornamental marble chimney pieces, wainscots fixed only by screws, and such like. Issue. Com. The duties of the landlord and the tenant respectively, concerning the state and condition of the premises, are imposed in three ways: 1. Law, Government Ab. Ibid. It is one of four types of tort of waste, and is not to be confused with the concept of waste under environmental law. resulting trust (and Quistclose trust); Ill 1940); 2 Summers on Oil and Gas 223 (1977 repr.)). If the apartment has been damaged, the landlord will use part or all of the deposit for repairs. 'Permissive waste' means damaging the premises by failure to act, and obviously covers much the same sort of territory as express covenants to repair. 278; 7 John. A person who is devising real property to a beneficiary but who wants to remain on the property during their lifetime may draft a life estate deed. This type of waste might occur, for example, if a tenant permits a house to fall into disrepair by not making reasonable maintenance repairs. A tenant for life (whether a tenant for his own life or for the life of another) is not liable for permissive waste (Woodhouse v Walker (1880) 5 QBD 404, 4067), except as may be reasonably necessary to prevent further deterioration to the property (unless he is made responsible for repairs as a condition of his holding the estate). The motivations of a tenant to do this are usually immaterial as these actions are in serious breach of the lease contract terms. Login. The court may directly require the party responsible for the waste to restore the property to its original condition. Section 94 provides that a town board, on its own motion, may cause to be submitted for voter approval any board resolution against which a petition for permissive referendum could be filed pursuant to Town Law. An elective share offers the surviving spouse the right to choose to receive certain property from the estate. not repairing a roof damaged by storm or allowing decay to continue due to a lack of protective paint (1 Co Litt 53a, 54b; 2 Bl Comm 281; Norris v. Laws, 150 NC 599, 64 S.E. Cf. so long that the rafters or other timbers of the house become rotten, unless
Waste may be distinguished from trespass as the former is an act committed by one who is rightfully in possession, whereas trespass is a wrongful act of possession. An owner can sue for damages for waste, terminate a lease of one committing waste, and/or obtain an injunction against further waste. en legal Links to other resources. 53 b; and carrying away the soil, is waste. Rep. 433. implied covenant. Life Tenancy and Waste. Cal. Waived their rights by joining with the deceased spouse to convey the real estate. Permissive waste- A mortgagor who is in possession of the mortgaged property is not liable to the mortgagee for any minor waste. 2. 3 Bro. Categories of Waste There are two main categories of waste that courts have developed over time: affirmative waste and permissive waste.19 Permissive waste "occurs when the life tenant fails to take some Waste is either
1. This remedy is generally not favored by courts. Ameliorative waste [ edit] A court will order an injunction if it finds that irreparable harm will occur and that the legal remedy would be inadequate, unless otherwise provided by statute. Browse USLegal Forms largest database of85k state and industry-specific legal forms. 10. A spoil or destruction houses, gardens, trees, or other corporeal hereditaments, to the disherison of him that hath the remainder or reversion in fee simple or fee tail. It is committed in houses by removing wainscots,
A lawsuit for waste can be brought against a life tenant or lessee of a leasehold estate, either by a current landlord or by the owner of a vested future interest. Jessica Zimmer is a journalist and attorney based in northern California. Rep. 1111; 2 Saund. [Last updated in June of 2022 by the Wex Definitions Team], Furthermore, a prior use exception exists to this general rule stating that if prior to the tenant residing there, the land was. Anno: 82 ALR2d 1106: DamagesWaste by Tenant. election to bring either an action on the case, or of, covenant, against the
Co. Lit. In some cases, the plaintiff has been able to recover treble damages twice--once for voluntary waste and again for wantonly committed waste.[2]. However, it may generally be considered that a mortgagor should not do anything that may impair the capital value of the security, especially if the action results in a reduction in the value of the security below the amount of the debt. 70 'Waste'. Instead, A decides that the land would be more valuable as a nightclub and draws up a business plan to transform the old estate into a new late night hotspot. emphyteotique lease; 35 (1917). The latter action has this advantage over an action of waste, that
Further explanation of the style of reference material is provided in the While traditionally ameliorative waste entitled the property owner to recover the costs of reverting the change, the majority rule in the modern-day United States prevents landowners from recovering damages for waste unless the value of their property decreased. Civil Code 1950.5 (b) (2). en property . Copyright 2023 Leaf Group Ltd. / Leaf Group Media, All Rights Reserved. 18Roby v. Newton, 121 Ga. 679, 49 S. E. 694 (1905); . Ab. It is the life tenants duty to keep the property of the life estate in good repair. The law of waste is concerned with limitations placed by law upon the use and enjoyment of land. Title examiners and land professionals frequently encounter future interests and Kentucky Revised Statutes Annotated 381.350 (2006). Permissive waste. There, a person found to have committed voluntary waste without the written permission of the holder of the future interest is forced to pay treble damages. part 4, p. 1667, n.; 3 Yeates, 251. Nonetheless, not all use of land depletes it, and some uses like routinely harvesting crops on a farm do not qualify as affirmative waste. Vern. We welcome all submissions and reserve the right to publish or not publish them. Windfalls are the property of the landlord, for whatever is severed
Ameliorating waste. possession; They are sometimes also called negligent waste, passive waste. Courts of Equity have no means of interfering in cases of permissive waste by a tenant for life of real property. This kind of waste is committed in houses, in
Permissive waste is failure to maintain the estate, either physically or financially. so as permanently to injure the inheritance. Permissive waste is defined as that kind of waste which is a matter of omission only, as by suffering a house to fall for want of necessary reparations. Medicaid excludes a life estate interest as an asset in determining eligibility for Medicaid. Waste, D 5; F. N. B. New Rep. 290; 4 Taunt. in fee simple or fee tail 2 Bl. Permissive Easements. It is a form of wasted caused by the failure to take reasonable care of the property. 73940 for a review of the history of the law of waste in England and the US in the 19th century; Cf. 3 P. Wms. Hire the top business lawyers and save up to 60% on legal fees. 227. As between tenants in common, 5 Taunt. A voluntary waste is an act of commission, as tearing down a house. This occurs when lessees or life tenants fail to make repairs or conduct maintenance that are essential for the property to retain its integrity. Whensomeonehas a future interest inaproperty,the person in possession of the land has a duty to maintain it in a manner that is not destructive to the future interest. A lawsuit for recovering taxes paid can be brought only in the appropriate division of the general court of justice of the county in which the real property is located. Waste, D 4. 738 (Wis. 1899), the Pabst Brewing Company's plant encroached on a residential home. The tenant has the responsibility to keep the rental property clean, to properly dispose of waste, and shall not deliberately or negligently allow damage to the property. The Executrix (Defendant) could not defend the suit for damage resulting from waste to property held in life tenancy by Ada Brannan based on estoppel, which requires the defense to show prejudice resulting from the conduct of the delay in filing suit. 7. https://legal-dictionary.thefreedictionary.com/Waste, She said Malaysia also fully supported Norway's proposal for plastic, A good model is San Fernando, Pampanga, which achieved a 78-percent, He said the hospitals' administration had strictly been directed to avoid from throwing medical, The environmental service providers contracted with Tadweer collect and transports, Mr Agyepong indicated that the gesture was also part of the company's effort to complement the government's commitment to deal with, So right now, less than 50 per cent of the, Dictionary, Encyclopedia and Thesaurus - The Free Dictionary, the webmaster's page for free fun content, Waste: A matter that needs to be resolved, Minister: Amendments to Basel Convention will help curb movement of plastic waste, Tadweer implements new waste management strategy, Over a million tonnes of waste collected until June in Abu Dhabi, No proper system for monitoring waste management in hospitals, Without waste management, Nigerians are contributing to climate change, throwing money away -Prof Osibanjo, Increase in summer tourism activity worries DENR chief, Was paid cash at work, threat to sue for overpayment, Waste Acceptance Criteria Certification Committee, Waste Acceptance for Nonradioactive Disposal, Waste Acceptance Preliminary Specifications, Waste Accountability, Shipping, Packaging. 23940, 5048. Inst. A link to your Casebriefs LSAT Prep Course Workbook will begin to download upon confirmation of your email 15775, 2756. home valuation code of conduct (HVCC)(US); In common law, a mortgagor is responsible for equitable waste, but (unless he has agreed to the contrarywhich is the case in most mortgage deeds) may permit the property to fall into disrepair and may do acts, such as cutting timber, that alter the character or diminish the capital value of the mortgaged property (Harper v Aplin (1886) 54 LTNS 383; Van Pelt v. McGraw, 4 NY 110 (1850); Searle v. Sawyer, 127 Mass 491, 34 Am Dec 425 (1879)). 817, l.
He later went on to receive his Juris Doctor from University of Pacific - McGeorge School of Law. Proflitt v. Henderson, 29 Mo. It is waste if the tenant suffer a house leased to him to remain uncovered
resecuritization; Com. 7, p. 226 to 238. 286. Permissive waste is an injury caused by an omission, rather than an affirmative act, on the part of the tenant. Ameliorative waste refers to modifications that increase the value of property made by a tenant who failed to obtain the landowner or future interest holders permission. All rights reserved. en value en voluntary waste Synonyms. Present recovers only damages for the waste. In some states, attorneys feesmay also be included in damages. ornamental marble chimney pieces, wainscots fixed only by screws, and such
Landlords typically protect against this type of voluntary waste by requiring a damage or security deposit from the tenant at the commencement of the lease. The doctrine of waste is somewhat different in this country from
In most areas, waste is not regulated by statute and so what is considered waste is often determined by neighborhood custom and the character of the land. PERMISSIVE. Some decisions have made it doubtful whether an action on the case
Waste, D 2. Common examples of this situation are life estates and leases, where thecurrentpossessormust preserve the land for the future possessor or landowner. It is difficult to classify states as strictly recourse or non-recourse. a mineral leas; 3) when prior to the grant, the land was used in exploitation of such natural resources, so that the grantor most likely intended the life tenant to .
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