TITLE BY ADVERSE POSSESSION 159

Where a statute of limitation requires action to be brought within twenty years, or some other period after the owner or his predecessor shall have been seised or possessed of the premises, a different result may possibly be reached than where the statute runs from the time when the right of action accrues. It was held in Michigan,^°2 under such a statute, that a party must bring his action within twenty-five years after his disseisin, whether the persons in possession claimed through or from each other or not. The object of such a statute, it was said, is to compel every party disseised to use sonfe diligence and to bar a right of entry after twenty-five years' practical abandonment of the possession to strangers. This distinction, however, has not been followed in other jurisdictions. Henry W. Ballantine. University of Illinois, Urbana.

• "* Riopelle v. Oilman, 23 Mich. 2,3 (1871). See also 5 Cal. L. Rev. 429.