Upon the making of a lease for years, the estate of the person making the lease, the lessor, ceases to be an estate in possession and becomes an estate in reversion, or, as it is usually called, a reversion.19 There is considered to exist, even at the present day, between the lessor, or his successor in interest, as owner of the reversion, and the person to whom the lease is made, the lessee, or his successor in interest,20 a modified species of tenure21 and the relation between the owners of the estates is known as that of landlord and tenant; these terms being ordinarily used to designate respectively the owner of the reversion and the owner of the lesser estate. It is in this sense, as meaning a party to the relation of tenancy, that we use the word tenant, without the mention of any estate in the land. But not in frequently we use the word merely as the equivalent of owner or holder of some estate mentioned, without reference to the existence of any relation of tenancy, as when we speak of a tenant in fee simple, in tail, for life, or for years.

Gray v. La Fayette County, 65 Wis. 567, 27 N. W. 311.

Not infrequently, however, a lease has been regarded as not a "conveyance," as that word is used in some particular statute. See instances cited in editorial notes 15 Columbia Law Rev. 265; 2 Virginia Law Rev. 399.

15. Co. Litt. 45b; 2 Blackst. Comm. 142. A lease for nine hundred and ninety nine years is valid. See Morrison v. St. Paul & N. P.Ry. Co., 63 Minn. 75, 30 L.

R. A. 546, 65 N. W. 141; Todhunter v. Des Moines, I. & M. R. Co., 58 Iowa, 205, 12 N. W. 267; Lilley v. Fifty Associates, 101 Mass. 432.

16. The statutes are summarized in 1 Tiffany, Landlord & Ten. Sec. 12 c. (1).

17. Robertson v. Hayes, 83 Ala. 290, 3 So. 674.

18. Clark v. Barnes, 76 N. Y. 301, 33 Am. Rep. 306.

19. Post Sec. 129.

20. Ante Sec. 54.

21. Ante Sec. 13.

The relation of landlord and tenant obviously may exist by reason of a lease other than for years, as for instance a lease for life, from year to year or at will. A lease for life is very unusual, an estate for life being almost invariably created by devise or by a conveyance of an estate for life to one person with remainder to another.22 A lease at will is also, in most jurisdictions, unusual.23 A lease from year to year frequently occurs.24 A holding under a lease for years is however ordinarily regarded as presenting the typical case of the relation of landlord and tenant, and it is convenient in this connection to discuss matters which appertain generally to that relation unaffected by the quantum of the estate held by the tenant.

The words "tenant" and "lessee" are frequently used by the courts with considerable looseness, as if equivalent in meaning. The word "lessee" should however be applied only to the person to whom the lease is originally made, while the word "tenant" is applicable to any person who holds possession under a lease, whether the original lessee or the latter's assignee. A lessee, provided he has entered under the lease, is necessarily a tenant, but a tenant is not necessarily a lessee, since he may be merely an assignee, mediate or immediate, of the lessee. So the lessor, the person who makes the lease, is, after the lessee has entered, necessarily a landlord, but a landlord is not necessarily a lessor, since he may be merely a transferee of the reversion.

22. Post Sec. 135.

23. Post Sec. 61.

24. Post Sec. 64.