ſo related to the other, as to make but one and the ſame eſtate in law. 3. By way of paſſing a right, or mitter le droit: as if a man be diſſeiſed, and releaſeth to his diſſeiſor all his right; hereby the diſſeiſor acquires a new right, which changes the quality of his eſtate, and renders that lawful which before was tortious[1]. 4. By way of extinguiſhment: as if my tenant for life makes a leaſe to A for life, remainder to B and his heirs, and I releaſe to A; this extinguiſhes my right to the reverſion, and ſhall enure to the advantage of B's remainder as well as of A's particular eſtate[2]. 5. By way of entry and feoffment: as if there be two joint diſſeiſors, and the diſſeiſee releaſes to one of them, he ſhall be ſole ſeiſed; and ſhall keep out his former companion; which is the ſame in effect as if the diſſeiſee had entered, and thereby put an end to the diſſeiſin, and afterwards had enfeoffed one of the diſſeiſors in fee[3]. And hereupon we may obſerve, that when a man has in himſelf the poſſeſſion of lands, he muſt at the common law convey the freehold by feoffment and livery; which makes a notoriety in the country: but if a man has only a right or a future intereſt, he may convey that right or intereſt by a mere releaſe to him that is in poſſeſſion of the land: for the occupancy of the releſſee is a matter of ſufficient notoriety already.
8. A confirmation is of a nature nearly allied to a releaſe. Sir Edward Coke defines if[4] to be a conveyance of an eſtate or right in eſſe, whereby a voidable eſtate is made ſure and unavoidable, or whereby a particular eſtate is encreaſed: and the words of making it are theſe, "have given, granted, ratified, approved, and confirmed[5]." An inſtance of the firſt branch of the definition is, if tenant for life leaſeth for forty years, and dieth during that term; here the leaſe for years is voidable by him in reverſion: yet, if he hath confirmed the eſtate of the leſſee for years, before the death of tenant for life, it is no longer voidable but ſure[6]. The latter branch, or that which tends
