Conn. Gen. Stat. » Title 47 — LAND AND LAND TITLES · Chapter 821a — Forms of Deeds and Mortgages
Connecticut General Statutes

Conn. Gen. Stat. § 47-36h (2026)

Force and effect of “Mortgage Deed” form

✓ current as of May 2026
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A deed following the form entitled “Mortgage Deed”, when duly executed, has the force and effect of a deed to the mortgagee in fee simple, subject to defeasance, with mortgage covenants, to secure the payment of money as well as the performance of any obligation or obligations therein specified or referred to; provided any other lawful covenants, agreement or condition may be inserted in the mortgage deed and any of the terms and provisions of said statutory mortgage covenants and conditions may be added to by any lawful agreement, covenant and condition specified in the mortgage deed.

(P.A. 75-309, S. 11; P.A. 79-602, S. 16.)

History: P.A. 79-602 substituted “has” for “shall have” and “the” for “such” where appearing.

Cited. 189 C. 212; 224 C. 563.

Cited. 20 CA 163.

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Notes of Decisions
Cited in 7 cases, 1983–2006 · leading case: Conf. Ctr. Ltd. v. TRC—The Rsch. Corp., 455 A.2d 857 (Conn. 1983).
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Conf. Ctr. Ltd. v. TRC—The Rsch. Corp., 455 A.2d 857 (Conn. 1983). · cites it 2× “To resolve this issue, we must take account of three convergent areas of the law: under mortgage law, the right of a mortgagee in a “title” jurisdiction to possession of mortgaged premises; under landlord-tenant law, the right of a tenant to enforce a covenant of quiet…”
Ocwen Fed. Bank, FSB v. Charles, 898 A.2d 197 (Conn. App. Ct. 2006). · cites it 2× “General Statutes § 47-36h . . . .” (Citations omitted.”
Red Rooster Constr. Co. v. River Assocs., Inc., 620 A.2d 118 (Conn. 1993). · cites it 2× “The issue in this case, therefore, is whether a mortgagee is an owner for the purposes of the statute and is thereby entitled to notice of the filing of the lien.”
Barclays Bank of New York v. Ivler, 565 A.2d 252 (Conn. App. Ct. 1989). · cites it 2× “General Statutes § 47-36h; State v. Stoneybrook, Inc.”
New Milford Sav. Bank v. Jajer, 691 A.2d 598 (Conn. App. Ct. 1997). · cites it 2× “General Statutes § 47-36h .... Under our law, an action for strict foreclosure is brought by a mortgagee who, holding legal title, seeks not to enforce a forfeiture but rather to foreclose an equity of redemption unless the mortgagor satisfies the debt on or before his law day.”
Connelly v. Fed. Nat. Mortg. Ass'n, 251 F. Supp. 2d 1071 (D. Conn. 2003). · cites it 2× “"); Conn. Gen.Stat. § 47-36h ("A deed following the form entitled `Mortgage Deed', when duly executed, has the force and effect of a deed to the mortgagee in fee simple, subject to defeasance, with mortgage covenants, to secure the payment of money as well as the performance of…”
Connelly v. Fed. Nat'l Mortg. Ass'n, 251 F. Supp. 2d 1071 (D. Conn. 2003). · cites it 2× “”); Conn. Gen.Stat. § 47-36h (“A deed following the form entitled ‘Mortgage Deed’, when duly executed, has the force and effect of a deed to the mortgagee in fee simple, subject to defeasance, with mortgage covenants, to secure the payment of money as well as the performance of…”
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