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Commencement date of an implied periodic tenancy when a tenant holds over on the expiry of a fixed term

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In Croft v William F Bly Ltd ([1919] 2 Ch. 343, CA (Eng)) T held over at the end of a fixed term (Christmas day 1916). The rent during the fixed term was a yearly rent payable quarterly on the usual quarter days. The tenant held over at the end of the term without any express agreement having been entered into as to the terms on which T held over. L accepted a quarter’s rent on the quarter day after the holding over began. The question was as to when the yearly tenancy began. The English Court of Appeal held that the periodic tenancy began when the fixed term ended. Six months’ notice to quit expiring on Christmas day 1917 was valid.



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