Can a tenant acquire a prescriptive easement over land which the tenant is renting for the benefit of freehold land, which the tenant owns, which is adjacent to the land which he is renting?

Whether a tenant can acquire a prescriptive right

Where an easement is claimed by prescription, it must be claimed in favour of the fee simple of the dominant tenement as against the fee simple of the servient tenement. Therefore, a tenant cannot acquire an easement by prescription against his landlord, but by the use of the land of a stranger he may gain a prescriptive right in fee for his landlord which he will be able to enjoy as a tenant. This is not the case for claims to light under the Prescription Act 1832—a tenant may acquire rights of light by prescription; see Practice Note: Establishing and maintaining rights of light.

However, this area has been the subject of much academic discussion that the reason why there are few cases in England where a tenant has succeeded in claiming a prescriptive right is not due to any special rules