Notwithstanding the principles previously articulated1, a sale of growing grass for the purpose of being mown and made into hay by the purchaser, a sale of hops not yet in bine, a sale of growing turnips (no time being stipulated for removing them) and a contract with an incoming tenant to take and pay for growing crops and tillages in consideration of letting him a farm, have all been held to be sales of an interest in land2.
The initial labour of planting a fruit tree does not render all the fruit that in subsequent years may grow in it
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