West Virginia Code § 62-2-7

Proof of possession of or title to property
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In a prosecution for an offense committed upon or relating to or affecting real estate, or for
stealing, embezzling, destroying, injuring, or fraudulently receiving or concealing, any
personal estate, it shall be sufficient to prove that when the offense was committed, the
actual or constructive possession, or a general or special property in the whole or any part of
such estate, was in the person or community alleged in the indictment or oteher accusation to
be the owner thereof.

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