levant et couchant

from Bouvier's Law Dictionary, Revised 6th Ed (1856)
LEVANT ET COUCHANT. This French phrase, which ought perhaps more properly to 
be couchant et levant, signifies literally rising and lying down. In law, it 
denotes that space of time which cattle have been on the land in which they 
have had time to lie down and rise again, which, in general, is held to be 
one night at least. 3 Bl. Com. 9; Dane's Ab. Index, h. t; 2 Lilly's Ab. 167; 
Wood's Inst. 190; 2 Bouv. Inst. n. 1641. 
    

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