Possession may be recovered by the person entitled by means of an action of ejectment against the tenant holding over,34 but in most jurisdictions statutes have been enacted providing that a lessor, or his successor in interest, may, as against a person who entered on the land as his tenant, or as against one claiming under such person, recover the possession of the premises by a proceeding of a summary character, without the necessity of bringing an action of ejectment. The proceedings authorized by these statutes may be conveniently referred to as "summary proceedings." By some of the statutes they arc so designated, while a number of the statutes give them no specific designation. In perhaps a majority of the slates the statutory provisions authorizing proceedings of this character by a landlord against his tenant are found in connection with provisions authorizing summary proceedings to recover land by one who has been forcibly expelled or excluded therefrom by a stranger, they both being under the head of "forcible entry and detainer," the tenant's retention of possession being frequently stated to constitute "unlawful detainer." Any difference, however, in the titles applied to proceedings of this character has no relation to any difference in the proceedings themselves.35

Q. B. Div. 60; Meaker v. Pome-roy, 49 Ala. 146; Harris v. Foster, 97 Cal. 292, 33 Am. St. Rep. 187, 32 Pac. 246; Board of County Com'rs of Pitkin County v. Brown, 2 Colo. App. 473, 31 Pac. 525; Bacon v. Brown, 9 Conn. 334; Smith v. Singleton, Hunt & Co., 71 Ga. 68; Stuart v. Hamilton, 66 111. 253; Lautman v. Miller, 158 Ind. 382, 63 N. E. 761; Longfellow v. Longfellow, 54 Me. 240; Hogsett v. Ellis, 17 Mich. 351; Chambers v. Ross, 25 N. J. L. 293; Abeel & Abeel v. Radcliff, 13 Johns. (N. Y.) 297, 7 Am. Dec. 377; Van Brunt v. Pope, 6 Abb. Pr. N. S. (N. Y.) 217; Schworbel v. Fugina, 14 N. D. 375, 104 N. W. 848; Williams v. Ladew, 171 Pa. St. 369, 33 Atl. 329.

29. Hoagland v. Crum, 113 111. 365, 55 Am. Rep. 424; Guthmann v. Vallery, 51 Neb. 824, 66 Am. St. Rep. 475, 71 N. W. 734.

30. Henderson v. Squire, L. R. 4 Q. B. 170; Harding v. Cre-thorn, 1 Esp. 57; Ibbs v. Richardson, 9 Adol. & E. 849; McKen-zie v. City of Lexington, 34 Ky. (4 Dana.) 129; Dimock v. Van Bergen, 94 Mass. (12 Allen) 551; Bless v. Jenkins, 129 Mo. 647, 31 S. W. 938.

31. Ante Sec. 68, notes 90, 91.

32. Sargent v. Smith, 12 Gray (Mass.) 426; See Russel v. Kil-lion, 7 Phila. (Pa.) 110; Comyn. Landlord & Ten. 510; Adams (Waterman's Ed.) at pp. 383, 446.

33. 2 Tiffany, Landlord & Ten. Sec. 213a.