If by the mortgage deed the mortgagor attorns to the mortgagee, the relationship of landlord and tenant arises between them1, but the value of such a clause is doubtful2. Such a clause is invalid so far as it purports to confer a right to distrain upon any chattels unless registered as a bill of sale3, but the invalidity does not extend to a case where the mortgagee has actually entered into possession and demised the land to the mortgagor as his tenant at a fair and reasonable rent
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