Conn. Gen. Stat. » Title 49 — MORTGAGES AND LIENS · Chapter 846 — Mortgages
Connecticut General Statutes

Conn. Gen. Stat. § 49-24 (2025)

Court may foreclose lien or mortgage on land by sale or market sale

✓ laws through the 2024 session: the source has not yet published 2025 Public Acts (checked Sept. 2026)
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All liens and mortgages affecting real property may, on the written motion of any party to any suit relating thereto, be foreclosed (1) by a decree of sale instead of a strict foreclosure at the discretion of the court before which the foreclosure proceedings are pending, or (2) with respect to mortgages, as defined in section 49-24a, that are a first mortgage against the property, by a judgment of foreclosure by market sale upon the written motion of the mortgagee, as defined in section 49-24a, and with consent of the mortgagor, as defined in section 49-24a, in accordance with sections 49-24a to 49-24g, inclusive, and sections 49-26 to 49-28, inclusive.

(1949 Rev., S. 7205; P.A. 14-84, S. 1; 14-217, S. 207; P.A. 16-65, S. 83.)

History: P.A. 14-84 designated existing provision re decree of sale as Subdiv. (1) and added Subdiv. (2) re foreclosure by market sale; P.A. 14-217 changed effective date of P.A. 14-84, S. 1, from October 1, 2014, to January 1, 2015, effective June 13, 2014; P.A. 16-65 deleted reference to Sec. 49-31t and made a technical change.

Nature of sale. 98 C. 152. Procedure where one of two mortgages foreclosed is invalid in part. 103 C. 743. Whether foreclosure by sale will be ordered rests in discretion of court; refusal to order held proper. 108 C. 30. Remedy of second mortgagee order of sale and not apportionment. 119 C. 455. Cited. 179 C. 232; 196 C. 172; 199 C. 368.

Cited. 11 CA 53; 13 CA 239; 21 CA 275; 23 CA 192; 35 CA 81. In the absence of motion requesting foreclosure by sale, court did not err in ordering strict foreclosure; in Connecticut, strict foreclosure is the rule, foreclosure by sale the exception. 121 CA 554.

Cited. 25 CS 516.

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Notes of Decisions
Cited in 31 cases (3 in the last 5 years), 1965–2024 · leading case: Fid. Trust Co. v. Irick, 538 A.2d 1027 (Conn. 1988).
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Fid. Trust Co. v. Irick, 538 A.2d 1027 (Conn. 1988). · cites it 6× “General Statutes § 49-24 provides: '“All liens and mortgages affecting real property may, on the written motion of any party to any suit relating thereto, be foreclosed by a decree of sale instead of a strict foreclosure at the discretion of the court before which the…”
Toro Credit Co. v. Zeytoonjian, 267 A.3d 71 (Conn. 2021). · cites it 12× “2 General Statutes § 49-24 provides in relevant part: ‘‘All liens and mortgages affecting real property may, on the written motion of any party to any suit relating thereto, be foreclosed (1) by a decree of sale instead of a strict foreclosure at the discretion of the court…”
Hartford Fed. Sav. & Loan Ass'n v. Tucker, 491 A.2d 1084 (Conn. 1985). · cites it 2× “General Statutes § 49-24; City Savings Bank v.”
Amresco New England II, L.P. v. Colossale, 774 A.2d 1083 (Conn. App. Ct. 2001). · cites it 5× “The closest statute on point is General Statutes § 49-24. 7 It permits a trial court to determine whether to order a strict foreclosure or a foreclosure by sale.”
Homebridge Fin. Servs., Inc. v. Jakubiec, 309 A.3d 1223 (Conn. App. Ct. 2024). · cites it 4× “In interpreting this statute, we have stated that [i]n Connecticut, the law is well settled that whether a mortgage is to be foreclosed by sale or by strict foreclosure is a matter within the sound discretion of the trial court.”
Town of Voluntown v. Rytman, 573 A.2d 336 (Conn. App. Ct. 1990). · cites it 2× “See also General Statutes § 49-24. The procedure for the foreclosure of municipal tax liens, like all other liens is governed by General Statutes § 49-25.”
Nat'l City Mortg. Co. v. Stoecker, 888 A.2d 95 (Conn. App. Ct. 2006). · cites it 2× “General Statutes § 49-24 provides that on written motion of any party to a foreclosure proceeding, a mortgage or lien on real property may be foreclosed at the discretion of the court.”
U.S. Bank Nat'l Assn. v. Christophersen, 180 A.3d 611 (Conn. App. Ct. 2018). · cites it 2× “General Statutes § 49-24 provides: All liens and mortgages affecting real property may, on the written motion of any party to any suit relating thereto, be foreclosed by a decree of sale instead of a strict foreclosure at the discretion of the court before which the foreclosure…”
Hartford Fed. Sayings & Loan Ass'n v. Tucker, 536 A.2d 962 (Conn. App. Ct. 1988). · cites it 2× “3 General Statutes §§ 49-24 through *248 49-26; Matter of Loubier, 6 Bankr.”
Madison Hills Ltd. P'ship II v. Madison Hills, Inc., 644 A.2d 363 (Conn. App. Ct. 1994). · cites it 2× “General Statutes § 49-24 appends to that definition the remedy of foreclosure by sale without altering the existing common law definition.”
Citibank, N.A. v. Lindland, 27 A.3d 423 (Conn. App. Ct. 2011). · cites it 4× “Judge Holzberg found incorrectly that there was substantial equity in the property justifying a sale 4 pursuant to General Statutes § 49-24 5 et seq. rather than strict foreclosure.”
Fed. Deposit Ins. v. Bombero, 657 A.2d 668 (Conn. App. Ct. 1995). · cites it 2× “Such lienholders have also lost the right to move for foreclosure by sale pursuant to General Statutes § 49-24, if they determine that a sale may provide funds out of which payment of their liens may come.”
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