CHANCERY. 527

An. Code, sec. 220. 1904, sec. 205. 1888, sec. 190. 1838, ch. 303.

235. The court may decree a sale of vessels or other personal property
held by two or more persons jointly.

As to the sale of personal property which cannot be partitioned, and for a
note on the joint ownership of personal property, see Crapster v. Griffith, 2 Bl. 5.
And see Hewitt's Case, 3 Bl. 184.
As to the partition of lands, etc., see sec. 152.

An. Code, sec. 221. 1904, sec. 206. 1888, sec. 191. 1847, ch. 150.

236. When there is a decree for the sale of any reversion in lands to
which rent is incident, the court may order any rent in arrear to be sold
with such estate, and the purchaser shall have the same right to recover
such rent by distress, entry or action, as if he had been owner of the estate
when the rent accrued.

An. Code, sec. 222. 1904, sec: 207. 1888, sec. 192. 1835, ch. 380, sec. 1.

237. In all cases where a suit is instituted for the sale of real or per-
sonal property, or where from the nature of the case a sale is the proper
mode of relief, the court, in its discretion, may order a sale of the property
before final decree, if satisfied clearly by proof that, at the final hearing
of the case, a sale will be ordered, and order the money arising from such
sale to be deposited or invested, to be disposed of as the court shall direct
by the final decree.

Object of this section and effect of an order of sale thereunder. This section
should never be applied except in very plain and unquestionable cases, and even
then only after a full hearing. Proof held insufficient to justify a sale. Bill of
complaint may be amended after the decree of sale. Kelly v. Gilbert, 78 Md.
435. And see Title Co. v. Burdette, 104 Md. 673; Donohue v. Daniel, 58 Md. 600;
Washington, etc., R. R. Co. v. Southern, etc., R. R. Co., 55 Md. 156; Cornell v.
McGann, 37 Md. 99; Dorsey v. Garey, 30 Md. 498.

To justify a sale under this section, it should appear beyond a reasonable doubt
that a sale must be inevitably decreed at the final hearing. A sale under this sec-
tion upheld. Proper parties. Donohue v. Daniel, 58 Md. 597. And see Washington,
etc., R. R. Co. v. Southern, etc., R. R. Co., 55 Md. 156; Cornell v. McGann, 37
Md. 99.

Upon satisfactory proof as prescribed in this section, the court may pass an
order of sale at any time after bill filed, without waiting for the defendant's ap-
pearance or answer. Proof held sufficient. This section applied.. Sec. 232 must be
read in connection with, and is subordinate to, this section. The discretion of the
court in ordering a sale, is reviewable on appeal. What " final decree " is contem-
plated by this section? Dorsey v. Dorsey, 30 Md. 528. And see Cornell v. McGann
37 Md. 99.

No appeal lies from the refusal to order a sale under this section, nor from the
recission of an order of sale. An appeal lies, however, under art. 5, sec. 23, from
an order directing a sale. Washington, etc., R. R. Co. v. Southern, etc., R. R. Co.,
55 Md. 155. Cf. Dorsey v. Garey, 30 Md. 499.

A decree of sale under this section, cannot be inquired into collaterally, provided
the court had jurisdiction. Dorsey v. Garey, 30 Md. 499.

A sale held not to have been ordered under this section, and that the proof did
not justify a sale thereunder. Cornell v. McCann, 37 Md. 98. Cf. Dorsey v. Garey
30 Md. 495.

It is the habit of the court to apply this section in applications for sales of real
estate to pay debts, under sec. 233. Hammond v. Hammond, 2 Bl. 359.

An. Code, sec. 223. 1904, sec. 208. 1888, sec. 193. 1835, ch. 380, sec. 2.

238. The court may decree a sale to enforce a vendor's lien upon any
estate in lands, whether legal or equitable, or may decree a sale to enforce