And, in addition to Jones above, clearly not limited to Indians, or even Americans:

“The arguments that were urged in this case by the appellant would lead to the conclusion that all the land that was purchased in fee simple by Mr. Dixon, and belonged to him as long as grass shall grow and water run, must all be personalty just as much as the machinery erected upon the land.”
[Fisher v. Dixon, Reports of Cases Decided in the House of Lords, 1845-1848]