See Cal. Crv. Proc. Code § 872.210 (West 2006); see also Forrest v. Elam, 88 Cal.App.3d 164, 151 Cal.Rptr. 591, 594 (Cal.Ct.App.1979) (stating that partition provides a successful resolution where life tenant commits waste). In California, partition of real property is a special statutory proceeding and is available only in limited instances. See § 872.210. Section 872.210 of the California Code of Civil Procedure permits partition of real property where the property is owned in successive estates. § 872.210(a)(2). Under the former version of Section 872.210, partition of such estates was limited to actions by a life tenant against the remainderman. CAL. CIV. PROC. CODE § 752, (repealed 1976). See Akagi v. Ishioka, 47 Cal.App.3d 426, 120 Cal.Rptr. 807, 811 (Cal.Ct.App.1975) (<HOLDING>). The new version expressly removes that
holding that a plaintiff had no injury in fact and consequently no standing when it had no enforceable contract right against the defendant recognizing that statutory right to partition in kind exists where mineral rights are involved holding that remainderman had no right of action for partition against life tenant in the absence of special statutory authority holding that a judge did not act in clear absence of all jurisdiction where he had colorable authority to take the action in question holding that plaintiffs had no right to proceed in rem against vessel under supplemental rule cla when they only possessed a statutory lien ie statutory right of action under  202h