It is sometimes a matter of difficulty to decide whether a particular form of words operates to grant a licence or an estate. Each case depends on its own circumstances, and it is impossible to lay down any general rule except that words denoting liberty to work minerals1, if unexplained by the other parts of the deed, only amount to the grant of a licence2. Where the words occur by way of exception or reservation in a grant of land it is important to consider what estate in the minerals the person in whose favour the exception or reservation
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