WILLIAMS' CASE.—3 BLAND. 275

has been in a great many instances submitted to the consid- 265
eration *of the General Assembly. In one of which the
widow was to be allowed not more than a fifth nor less than an
eighth; 1801. ch. 82; and in another not more than a sixth nor less
than an eighth of the net proceeds of sale; 1815, ch. 45; in others
she was to be allowed one-eighth, or not exceeding one-eighth;
1811, ch. 137, 149; 1813. ch. 152, 161; in others not more than a
seventh nor less than a tenth; 1811, ch. 45; 1816, ch. 246; in others
the proceeds of sale were directed to be invested; and the widow
to be allowed one-third of the interest or dividends during her life;
1807, ch. 37, 135; 1809, ch. 49; 1810, eh. 138; in others she was to
have awarded to her a proportion of the net proceeds of sale ac-
cording to the rule of the Court of Chaucery; 1812, ch. 160; 1814,
ch. 90; 1816, ch. 224; or the land was directed to be sold without
affecting the widow's right of dower; 1819, ch. 129; but iu the
greater number of cases the matter has been left entirely at the
discretion of the Court, to award to the widow such a proportion
of the net proceeds of sale as might be deemed equal in value to
her dower. 1802, ch. 07; 1803, ch. 91: 1810, ch. 25. 74; 1818, ch. 31,
93, 161, 175; 1819, ch. 102; 1825. ch. 64; 1827, ch. 102. And in
cases of tenants for life, the whole proceeds of sale have been di-
rected to be invested, and the interest or the dividends of the
whole investment awarded to the tenant for life during her life.
1808, ch. 15: 1810, ch. 50. The General Assembly have not. how-
ever, in any of these private Acts, referred to any rule by which the
value of a life interest in lands was to be calculated, nor have they
indicated the principles by which they had been governed in
awarding to the owner what they so specified as an equivalent, or
by which the Courts of justice were to be regulated in estimating
the present value of such interests when the matter was iu part or
altogether left to their discretion.

Besides these various private Acts, in the passing of which this
subject appears to have been placed before the mind of the Legis-
lature, there are several public and important laws in relation to
the valuing of life interests, iu the passing of which by the Gene-
ral Assembly, it is but reasonable to presume, that the matter must
have been more fully and deliberately considered.

In the beginning of the year 1800, the then existing law regu-
lating the descents of real estates, was so modified as to declare,
that in case of a sale of the real estate of au intestate for the pur-
pose of effecting a division of its value among the heirs, there
should be awarded to the widow, according to her age, health,
*and condition, not more than a seventh nor less than a
tenth of the net amount of sales in lieu of her dower; 1799, 266
ch. 49, s. 6; which provision has been embodied in the now exist-
ing general Act directing the course of descents of intestates' real
estates. 1820, ch. 191, 6, 28. The same range of allowance to the