improvements" implies some secondary
consideration to what Leyburn has defined as "corn right."

In the case of _Hughes_ vs. _Dougherty_, the significance of
"improvements," or "corn rights," vis-a-vis "cabin rights" is
particularly noted.[27] The following summary of that case, found in
_Pennsylvania Reports_, emphasizes that significance, in addition to
defining a Fair Play "code" pertaining to land tenure:

THIS was an ejectment for 324 acres of land, part of the Indian
lands in _Northumberland_ county.

The plaintiff claimed under a warrant issued on the 2d _May_ 1785,
for the premises, and a survey made thereon upon the 10th _January_
1786. The defendant, on the 20th _June_ 1785, entered a caveat
against the claims of the plaintiff, and on the 5th _October_
following, took out a warrant for the land in dispute, on which he
was then settled. Both claimed the pre-emption under the act of 21st
_December_ 1784,[28] and on the evidence given the facts appeared to
be:

That in 1773, one _James Hughes_, a brother of the plaintiff,
settled on the lands in question and made some small improvements.
In the next year he enlarged his improvement, and cut logs to build
an house. In the winter following he went to his father's in
_Donegal_ in _Lancaster_ county, and died there. His elder brother
_Thomas_ was at that time settled on the Indian land, and one of the
"Fair Play Men," who had assembled together and made a resolution,
(which they agreed to enforce as the law of the place,) that "if any
person was absent from his "settlement for six weeks he should
forfeit his right." [Quotation marks as published.]

In the spring of 1775 the defendant came to the settlement, and was
advised by the Fair Play Men to settle on the premises which
_Hughes_ had left; this he did, and built a cabin. The plaintiff
soon after came, claiming it in right of his brother, and aided by
_Thomas Hughes_, took possession of the cabin; but the defendant
collecting his friends, an affray ensued, in which _Hughes_ was
beaten off and the defendant left in possession. He continued to
improve, built an house and stable, and cleared about ten acres. In
1778 he was driven off by the enemy and entered into the army. At
the close of the war, both plaintiff and defendant returned to the
settlement, each claiming the land in dispute.