In the name of a penalty. In the civil law, a legacy was said to be left nomine poena where it was left for the purpose of coercing the heir to do or not to do something. Inst. 2, 20, 3G. The term has also been applied, in English law, to some kinds of covenants, such as a covenant inserted in a lease that the lessee shall forfeit a certain sum on non- payment of rent, or on doing certain things, as plowing up ancient meadow, and the like. 1 Crabb, Real Prop. p. 17i,

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