he said in 1863, was "absolutely essential to the welfare of the country." Furthermore, Gladstone met resistance from Whigs in his Cabinet itself, especially Robert Lowe, and the resulting compromise measure was so weak that it had little difficulty in passing both Houses of Parliament, with one significant amendment. As well as the Land Act, the Liberal government also passed the Irish Church Act 1869 and put forward the Irish University Bill that failed to pass both Houses of Parliament. Policymakers made much use of the statistical data recently collated in Griffith's Valuation (1853–68). Terms 1. The Ulster custom or any similar custom prevailing elsewhere, was given the force of law where it existed. 2. Tenants not enjoying this protection (the vast majority) gained increased security by: a) compensation for improvements made to a farm if they surrendered their lease (these had previously been accredited to the landlord, hence no incentive to the tenant); b) compensation for 'disturbance', i.e. damages, for tenants evicted for causes other than non-payment of rent. 3. The 'John Bright Clauses', which Gladstone accepted reluctantly, allowed tenants to borrow from the government two-thirds of the cost of buying their holding, at 5% interest repayable over 35 years, provided the landlord was willing to sell (no compulsory powers). To prevent eviction by rack-renting, and so avoiding paying compensation to tenants, the Bill said that rents must not be "excessive", leaving this for the courts to define. But the House of Lords in a wrecking amendment substituted "exorbitant" in its place. This enabled landlords to raise rents above what tenants could pay, and then to evict them for non-payment without giving any compensation. Consequences However well-intentioned, the Act was at best irrelevant, at worst counter-productive. Fewer than 1,000 tenants took up the 'Bright Clauses', since the terms were beyond most tenants and many landlords did not wish to sell. Many substantial leasehold farmers, who had led the campaign for land reform, were excluded from the Act because their leases were longer than 31 years. Legal disputes over customary rights and "exorbitant" rents actually worsened landlord-tenant relations. Figures do not indicate any impact of the Act on the rate of eviction, which was anyway at a low level. In the late 1870s when depression struck, evictions for non-payment of rent mounted, tenants had no protection, and in reply 'outrages' and the campaign by the Land League, led by Michael