The first major reform Gladstone undertook was the disestablishment of the Church of Ireland as embodied in the Irish Church Act 1869. This was followed by the Landlord and Tenant Act of 1870 which attempted to protect Irish tenants from unfair treatment from landlords by lending public money to tenants to enable them to buy their holdings. The Act limited landlords' powers to arbitrarily evict their tenants and established compensation for eviction, which varied according to the size of holdings and was not eligible for those evicted for failing to pay rents.