us the limit of the estate the grantee gets (e.g. for 50 years, for life, etc.). To create a life estate, it is enough to say “To Comrade Wisdom for life”. To create a fee simple estate, the common law provides that it should be “To A and his heirs”. Without imputing the „heirs‟ the grant will be valueless or at best, a life estate is presumed. Where Comrade Wisdom gets a life estate, he can transfer this life estate by lease or sale. In this case, the transferee acquires an estate pur autre vie (anestate for the life of another). A grantee cannot transfer more than he has. If X has an estate for life and he transfers a 20 years lease to Y and X dies 4 years after the grant, the interest of Y automatically terminates because the interest of Y is predicated on the life of X. Most contentions are with regards to creation of fee simple estate. At common law, the technical words are „to Comrade Wisdom and his heirs‟. In 1882, the Conveyancing and Law of Property Act provided that in lieu of of the common law phrase [to Comrade Wisdom and his heirs], the vendor may use in fee simple. That is, „To Comrade Wisdom in fee simple‟. This is regarded as acceptable. In 1925, The Law of Property Act, England further simplified conveyance by providing that even without words of limitation, the grantee can obtain a fee simple so long as there is no contrary intention express in the document. In other words, a transferee is deemed to obtain a fee simple unless there is a contrary intention express in the deed. Up to this point, we imagine that the transfer is “inter vivos”. Section 85(1) of the Property and Conveyancing Law of 1959 enacted essentially provisions of the Law of Property Act. When the transfer is by devise (Will), the foregoing principles apply. As a