Mass. Gen. Laws » Part II Title I Chapter 184
Massachusetts General Laws

Mass. Gen. Laws ch. 184, § 22 (2026)

Encumbrance of record; liability for removal

✓ text as last checked Sept. 2026 (this copy records no edition or section history)
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Section 22. Whoever conveys real property by a deed or mortgage which contains a covenant that it is free from all encumbrances shall, if it appears by a public record that an actual or apparent encumbrance, known or unknown to him, exists thereon, be liable in an action of contract to the grantee, his heirs, executors, administrators, successors or assigns, for all damages sustained in removing the same.

Notes of Decisions
Cited in 3 cases, 1923–2006 · leading case: Gallison v. Downing, 138 N.E. 315 (Mass. 1923).
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Gallison v. Downing, 138 N.E. 315 (Mass. 1923). “The provisions of G. L. c. 184, § 22, have no pertinency to the facts here disclosed.”
Dyer v. Scott, 149 N.E. 146 (Mass. 1925). “This is an action of contract for breach of covenant of warranty against an encumbrance in a deed from the defendant to the plaintiff’s grantor, brought under G. L. c. 184, § 22, which provides that “Whoever conveys real *431 property by a deed or mortgage which contains a…”
Brooks v. Bornstein, 20 Mass. L. Rptr. 646 (Mass. Super. Ct. 2006). · cites it 7× “93A and violations of G.L.c. 184, §22. Defendant Thomas Quinn, doing business as Quinn and Driscoll Real Estate Limited (Quinn), brought a third-party action against Richard S.”
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