A lease usually contains a covenant on the tenant's part to deliver up the premises on the determination of the term. In the absence of such a covenant, or of any express stipulation, the tenant is under an implied contract to restore possession to the landlord1. The damages for breach of this express or implied obligation2 are not limited to the value of the land but are the amount of any actual damage sustained by the landlord3. This will include the rent of the premises during the time the landlord is kept out of possession
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