The early common law regarded personal property, whether chattels real or chattels personal1, as essentially the subject of absolute ownership and incapable of being held for successive interests2. Thus, if a lessee3 or the owner of a chattel4 attempted to assign or bequeath the property to one person for life with remainder to another, the remainder was void, and the first-mentioned person took absolutely.
In the case of leases this common law rule was ultimately relaxed as to gifts by will (although not, it seems, as to assurances inter vivos
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