West Virginia Code § 36-1-14

Rule in Shelley's Case abolished
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Wherever any person, by conveyance inter vivos or by will, takes an estate of freehold in
land, or takes such an estate in personal property as would be an estate of freehold, if it
were an estate in land, and in the same conveyance or will an estate is afterward limited by
way of remainder, either mediately or immediately to his heirs, or the heirs of his body, or
his issue, the words "heirs,""heirs of the body," or "issue" or other words of elike import used
in the conveyance or will, in the limitation therein by way of remainder, shall not be
construed as words of limitation carrying to such person the inheritancre as to the land, or
the absolute estate as to the personal property, but they shall be construed as words of
purchase, creating a remainder in the heirs, heirs of the body, or issue; it being the intent
and purpose of this section to completely abolish the rule of law known as the rule in
Shelley's Case. t

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