It is held that riparian rights do not ex tend beyond access to navigable water and this is subject to a general right of naviga tion ; Stuart v. Greanyea, 154 Mich. 132, 117 N. W. 655, 25 L. R. A. (N. S.) 257.
In North Carolina it has been held that the bed of a lake may be the subject of private ownership, but if the waters are nav igable in their natural state, the public have an easement of navigation In them which cannot be obstructed ; State v. Narrows Island Club, 100 N. C. 477, 5 S. E. 411, 6 Am. St. Rep. 618. The riparian proprietor upon a navigable lake has the exclusive right of access to and from the lake in front of his land and of building wharves in aid of navi gation not interfering with the public rights; Delaplaine v. Ry. Co., 42 Wis. 214, 24 Am. Rep. 386; Rice v. Ruddiman, 10 Mich. 125. See Austin v. R. Co., 45 Vt. 215. In Eng land, a non-tidal lake is the subject of pri vate ownership ; L. R. 3 App. Cas. 641.
Where the ownership of the bed of the lake is in the state, it has no power arbi trarily to destroy the rights of the riparian owner on such lake without his consent and without due process of law, for the sole pur pose of benefiting some other riparian owner or for any other merely private purpose; and an act authorizing the drainage of such a lake without the consent of a riparian owner is unconstitutional ; Priewe v. Imp. Co., 93 Wis. 534, 67 N. W. 918, 33 L. R. A. 645 ; nor have a board of supervisors, in the absence of a statute directly conferring it, the right to construct a bridge over such a lake; Snyder v. Foster, 77 Ia. 638, 42 N. W. 506.
The water of a navigable lake cannot be withdrawn below the original low water mark for irrigation purposes, to the injury of a riparian owner who acquired his rights prior to the adoption of the constitutional provision vesting title to the navigable wa ters in the state; Madson v. Water Co., 40 Wash. 414, 82 Pac. 718, 6 L. R. A. (N. S.) 257.
In the case of a meandered lake the ripa rian proprietor is held entitled to the middle thereof ; Olson v. Huntamer, 6 S. D. 364, 61
N. W. 479 ; but in Illinois the title to such waters and the land covered by them is held to be in the state in trust for the people; Fuller v. Shedd, 161 Ill. 462, 44 N. E. 286, 33 L. R. A. 146, 52 Am. St. Rep. 380. Meander lines do not cut off land between such lines and the waters of a,Meandered lake; Stoner v. Rice, 121 Ind. 51, 22 N. E. 968, 6 L. R. A. 387; Boorman v. Sunnuchs, 42 Wis. 233 ; Pere Marquette Boom Co. v. Adams, 44 Mich. 403, 6 N. W. 857; Hardin v. Jordan, 140 U. S. 371, 11 Sup. Ct. 808, 838, 35 L. Ed. 428 ; and derelict land left by the receding waters of a meandered lake is held to belong to the riparian owners; Warren v. Chambers, 25 Ark. 120, 97 Am. Dec. 538, 4 Am. Rep. 23; Poynter v. Chipman, 8 Utah 442, 32 Pac. 690; but not where the lake is artificially drained; Noyes v. Collins, 92 Ia. 566, 61 N. W. 250, 26 L. R. A. 609, 54 Am. St. Rep. 571 ; and in Illinois, gradual recession of the wa ters of a meandered lake is held to give the riparian proprietors the right to the new land by following the recession of the wa ters to their edge; but a considerable body of new land suddenly or perceptibly formed by reliction is held to belong to the state; Fuller v. Shedd, 161 III. 462, 44 N. B. 286, 33 L. R. A. 146, 52 Am.. St. Rep. 380.
Where R non-navigable pond several hun dred acres in area gradually dried up, leav ing a tract of fertile land, and the riparian owners, who, by the law of the state (Min nesota), owned the beds of such ponds, ap plied to have their boundary lines determin ed, it was settled that they each took tri angular pieces meeting at the center of the pond; Scheifert v. Briegel, 90 Minn. 125, 96 N. W. 44, 63 L. R. A. 296, 101 Am. St. Rep. 399.
See 18 L. R. A. 695, n.; BOUNDARY ; GREAT LAKES; HIGH SEAS; NAVIGABLE WATERS; PONDS ; RIPARIAN RIGHTS ; WATERS.