The rights of limited owners are governed by the doctrine of waste1. Prima facie, working new or unopened mines or quarries2 is waste, but working open mines is not waste: it is enjoyment of the profits of the estate3. The right to commit waste is not incident to the equitable interest of a tenant for life4 or the estate of a tenant for years5. Consequently, in the absence of express provision contained in the instrument under which their interests arise, tenants
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