Under the former rule in force a vendee could not acquire property adversely against the vendor, the court in one case stating,38 "Such holding and occupancy could not in a hundred years ripen into an adverse holding and the complainant would be equitably estopped from so claiming."

This rule has now been modified, however, so that where the vendee claims to be the owner of said property, under the contract of purchase, and under and by virtue of said claim, occupies same adversely, for a period of twenty years after the last payment was due on such contract or after the last payment was made on such contract, he will be permitted to assert such title against his vendor.39