WILLIAMS' CASE.—3 BLAND. 201

The Acts of Assembly which authorize the sale of real estates of infants
considered as to their true construction, their practical utility, and their
constitutionality

Where the widow herself is the petitioner her separate assent to a sale is not
required

The credit given on the sale of an infant's real estate considered as an in-
vestment for his benefit

A bid may be reserved, or a bye-bidder allowed in certain cases (a)

An estate ordered to be sold is under the protection of the Court, and may
be rented until a sale can be effected

The various cases in which it may become necessaiy to put a present value
upon a life interest in property

The formation of tables shewing the expectation of human life at every age

In ascertaining the present value of a life interest, and in apportioning a
burthen between the tenant for life, and the remainderman or rever
sioner, the estimate must be made from a consideration of all circum
stances, in which assistance may be derived from tables shewing the ex-
pectation of life (b)

(a) But see Moncrieff v Goldsborough 4 H & McH 281 Peck v List, 23
W Va 338, Bank v. Sprague, 20 N J Eq 159 Yerkes v Wilson, 81 Pa St
9, Mortimer v Bell, L R 1 Ch 10, Heatley v Newton, 19 Ch D 326 In
Peck v List, it was held that if the owner of goods, which are put up for
sale at auction by his direction employ a puffer to bid for him, it is a fraud
on the real bidders, and the highest bidder cannot be compelled to complete
his contract In an article on Auctions and Auctioneers, 8 Southern Law
Rev 5b4, there is said to be considerable conflict among the authorities as to
the extent to which the rule against puffers is to be carried If the vendor
notifies bidders of his intention to employ by bidders it does not vitiate the
sale Many cases hold that the vendor may employ a bidder if he does it
bonafide to prevent a sacrifice of the property under a given price

(b) The most usual cases in which it becomes necessary to determine the
present value of life estates are dower and curtesy In the case of dower it
is provided by Rev Code, Article 47, section 63, that where a widow con
sents to the sale of an intestate s real estate by commissioners in proceedings
for partition, the Court shall awaid to such widow in lieu of her dower
such proportion of the proceeds of sale as shall be just and equitable, not ex
ceeding one-seventh nor less than one-tenth part of the net amount of sales
according to the age, health and condition of such widow

The following rule has been adopted by the Circuit Court of Baltimore
City to determine the allowance out of the proceeds of sale of land to a
widow in lieu of her dower

If the widow is under 40 years of age, not more than one seventh
If above 40, and under 45, not more than 2 15
" 45, " 51, ' " 1 8
" 51, 56, " ' 19
" " 56, not less than 1-10 of the net proceeds of sale

Where repairs or improvements are to be made on real estates in which a
widow has dower the Orphans Court may adjudge, determine and appor-
tion in then discretion what part of the expenses shall be borne by the
widow Rev Code, Art 50, sec 222

The statutory rule in the case of curtesy, is that in case of the sale of a
married woman's real estate by Commissioners the Court shall award to