The Devon Commission was headed by William Courtney, the 10th Earl of Devon, and it reported in 1845 that the population of Ireland had increased from 6 million people to close on 8 million people. Similarly they concluded that the leases were unfair and were favourable to the landowners (who were usually Anglo-Irish). The majority of Irish tenants had no form of protection, they could be, and often were, summarily evicted. They also had no claim to the Ulster Custom of landholding - this would have granted tenants the "3F's": Free sale, fixity of tenure, and fair rent. The Devon Commission had wide reaching consequences and though too late to prevent the famine, it did galvanize change afterwards.