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In this Ontario case, a transfer of land was made of "all the (grantor's) estate and interest in the said piece of land." This seemed at variance with the ancient common law rule that the use of words other than to the "grantee and his heirs" only conveyed a life estate and not a fee simple. But legislation existed in Ontario (as it does now in most common law provinces) called the Conveyance and Law of Property Act which abolished the strict common law terminology requirement and, in fact, reversed such as a fee simple conveyance is now presumed unless the wording of the conveyance suggests the contrary. The court looked at the use of the word "transfer" and concluded that there had been a conveyance of a fee simple estate.

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