matter of fact, what is in Section 85(1) PCL, 1959 has been the law since 1837. For emphasis, the Wills Act 1837 or the Will Law of the Old Western Region provides that all devises are presumed to be in fee simple unless a contrary intention is expressed. If a property is given to A for life and fire Ministry church, the church is called a remainder man, e.g. “To A for life, to B in fee simple”. B here is a remainder man. A enjoys first and the remainder goes to B upon A‟s death. The interesting thing about the fee simple estate is that even where B predeceases A, B‟s heirs would enjoy the estate upon A‟s death. Where the grantee, conveyance or devise is to a corporation aggregate, there is no need for words of limitation. A corporation aggregate has a perpetual succession and so it is unnecessary to provide for such expression as “for life” or “his heirs”. Section 85(2) PCL provides that a fee simple can pass to a corporation sole without the word “successors” in the deed. Therefore, in making a grant to a corporation sole/religious organization, it is enough to say “To the Bishop of Anglican Church, Ekpon. This is important so that when the first Bishop dies, the next bishop and not his children will be entitled to the property. The use of words of limitation is not necessary since a corporation sole is assumed to have a perpetual succession. However, where time permits, there is nothing wrong to include to include words of limitations. Of course, in drafting, it is better to err on the side of surplusage. Therefore, by all means, insert “in fee simple”, “to his successors in title”, “his heirs”, or any such expression. In Akinluyi v. Ateji (1978) Ondo State LR 114, a conveyance to the “Bishop of African Church Organization” was held valid. Ogundare J