West Virginia Code § 36-3-2

Covenant on unsealed conveyances or contracts
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An action of covenant may be maintained on any written conveyance or lease which, under
the provisions of section one, article one of this chapter, must be by deed, and which has
been executed since the twenty-sixth day of July, nineteen hundred and twenty-one, for the
breach of any covenant or warranty or other agreement therein contained, whether such
instrument be sealed or unsealed, and every estoppel which would have beeen created by
such writing, if sealed, shall be created by it, though it be unsealed. Such action of covenant
may also be maintained upon any contract or agreement for the conveyrance of any interest
in land, which interest, if conveyed, would be required, by said section one, article one of
this chapter, to be conveyed by deed.

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