An exception to the rule that the tenant and not the landlord is liable for defective conditions of leased premises has for its basis the landlord's promise or covenant to repair. Unlike other exceptions, this one is neither well defined nor uniformly applied through-out the states. How the courts construe the landlord's promise to repair as affecting his liability in tort is the concern of this note.
Edmund Button, Covenant to Repair as Evidence of Landlord's Control, 16 Clev.-Marshall L. Rev. 319 (1967)