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No. Plants in the ground fall into the area of "leasehold improvements" and therefore become part of the real property covered by the lease - known as the "demised premises." As such, plants which are IN the ground have the same legal status as a fence and become the property of the owner rather than thenant, and they cannot be removed without the owner's permission.

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Q: Can a tenant come back 2 months later and dig up her plants?
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