606 ARTICLE 21.

such deed or mortgage shall be as valid as if the said commissioner had
been duly qualified to act at the time of the taking of such acknowledgment,
or doing any other official act.

An. Code, sec. 23. 1904, sec. 23. 1888, sec. 23. 1715, ch. 47, sec. 4. 1794, ch. 57.

24. Neither livery of seisin nor indenting shall be necessary to the
validity of any deed.

Under the acts of 1776, ch. 14, and 1715, ch. 47, the enrollment of deeds is a sub-
stitute for, and equivalent to, the act of livery. Rogers v. Sisters of Charity, 97
Md. 553; Riley v. Carter, 76 Md. 596; Handy v. McKim, 64 Md. 569; Evans v.
Horan, 52 Md. 611; Key v. Davis, 1 Md. 39; Mathews v. Ward, 10 G. & J. 448;
Smith v. Steele, 3 H. & McH. 104.
As to proof of whether a deed was indented, see Gittings v. Hall, 1 H. & J. 14.

An. Code, sec. 24. 1904, sec. 24. 1888, sec. 24. 1782, ch. 23.

25. Any person seized of an estate tail, in possession, reversion or re-
mainder, in any lands, tenements or hereditaments may grant, sell and
convey the same in the same manner and by the same form of conveyance
as if he were seized of an estate in fee simple; and such conveyance shall
be good and available, to all intents and purposes, against all persons whom '
the grantor might debar by any mode of common recovery, or by any ways or
means whatsoever.

Under this section, an estate in fee tail amounts to a fee simple. Tongue v.
Nutwell, 13 Md. 424. And see Thomas v. Higgins,'47 Md. 452; Estep v. Mackey, 52
Md. 599; Benson v. Linthicum, 75 Md. 144.

Where there is a judgment against a tenant in tail who subsequently sells the
property and thus enlarges the estate under this section, the fee simple estate is
not liable to be sold for the payment of the judgment. The words " debar by any
mode of common recovery," construed. Maslin v. Thomas, 8 Gill, 18. See also
Coombs v. Jordan. 3 Bl. 299.

Under this section, a tenant in tail may defeat the estate altogether or convey
only a qualified estate. Effect of an absolute and also of a qualified conveyance.
Under this section, an estate tail cannot be devised. Laidler v. Young, 2 H. & J.
71. And see Paca v. Forwood, 2 H. & McH. 176.

The claim of a tenant in tail, held to be barred by limitations and adverse
possession. Wickes v. Wickes, 98 Md. 318.

An estate tail special, held subject to be docked under this section. Pennington
v. Pennington, 70 Md. 436. And see Brogden v. Walker, 2 H. & J. 285; Todd v.
Pratt, 1 H. & J. 465; Ridgely v. M'Laughlin, 3 H. & McH. 220.

By this section, the ancient mode of docking estates tail by common recovery is
abolished. Newton v. Griffith, 1 H. & G. 128; Maslin v. Thomas, 8 Gill, 18.

Purpose and construction of this section. Key v. Davis, 1 Md. 41.

This section held to bar the reversionary interest of the proprietary. Howard v.
Moale, 2 H. & J. 261.

For cases involving the act of descents (1786, ch. 45), as applicable to estates in
tail, see Posey v. Budd, 21 Md. 477: Smith v. Smith, 2 H. & J. 314.

For cases involving estates in tail, see Partridge v. Dorsey, 3 H. & J. 302;
Carroll v. Maydwell, 3 H. & J. 292; Jones v. Jones, 2 H. & J. 281; Hopkins v.
Threlkeld, 3 H. & McH. 443; Calvert v. Eden, 2 H. & McH. 279.

This section referred to in construing a will. Chelton v. Henderson, 9 Gill, 438.

An. Code, sec. 25. 1904, sec. 25. 1888, sec. 25. 1856, ch. 154, sec. 21.

26. Every power of attorney authorizing an agent or attorney to sell
and convey any real estate shall be attested and acknowledged in the same
manner as a deed, and recorded with the deed executed in pursuance of such