Massachusetts General Laws

Mass. Gen. Laws ch. 184, § 24 (2026)

Defects, irregularities or omissions in deeds; curative period

✓ current as of July 2026

Find cases: SyfertCases citing this section MAmalegislature.gov (official) JustiaChapter on Justia CornellLII Search CasesGoogle Scholar

Section 24. When any owner of land the title to which is not registered, or of any interest in such land, signs an instrument in writing conveying or purporting to convey his land or interest, or in any manner affecting or purporting to affect his title thereto, and the instrument, whether or not entitled to record, is recorded, and indexed, in the registry of deeds for the district wherein such land is situated, and a period of ten years elapses after the instrument is accepted for record, and the instrument or the record thereof because of defect, irregularity or omission fails to comply in any respect with any requirement of law relating to seals, corporate or individual, to the validity of acknowledgment, to certificate of acknowledgment, witnesses, attestation, proof of execution, or time of execution, to recitals of consideration, residence, address, or date, to the authority of a person signing for a corporation who purports to be the president or treasurer or a principal officer of the corporation, such instrument and the record thereof shall notwithstanding any or all of such defects, irregularities and omissions, be effective for all purposes to the same extent as though the instrument and the record thereof had originally not been subject to the defect, irregularity or omission, unless within said period of ten years a proceeding is commenced on account of the defect, irregularity or omission, and notice thereof is duly recorded in said registry of deeds and indexed and noted on the margin thereof under the name of the signer of the instrument and, in the event of such proceeding, unless relief is thereby in due course granted.

Notes of Decisions

Cited in 13 cases (1 in the last 5 years), 1971–2024 · leading case: Bank of Am., N.A. v. Casey, 52 N.E.3d 1030 (Mass. 2016).

Sort: Relevance Newest Treatment

Bank of Am., N.A. v. Casey, 52 N.E.3d 1030 (Mass. 2016). “The trustee argues the following: the omission of the mortgagor’s name in the acknowledgment is a material defect that renders invalid the recording of the mortgage to which the acknowledgment is affixed; a § 5B attorney’s affidavit like Quintín’s in this case is insufficient to…”

Allen v. Allen, 16 N.E.3d 1078 (Mass. App. Ct. 2014). “Harold argues that even if he was required to record the July deed, as we have concluded, he is protected by the safe harbor of G. L. c. 184, § 24, under which a defective acknowledgment cannot be challenged after ten years.”

Bank of Am., N.A. v. Casey (In Re Pereira), 791 F.3d 180 (1st Cir. 2015). · cites it 2× “It pointed out that there was a statute, Mass. Gen. Laws ch. 184, § 24 , which it read to explicitly provide a procedure for curing defects in title, including a defective certificate of acknowledgement, and that statutory procedure had not been used.”

HSBC Bank USA, N.A. v. Lassman, 550 B.R. 157 (D. Mass. 2016). “See Mass. Gen. Laws ch. 184, § 24 . As the First Circuit recently observed, the language of the statute and the interpretative case law are ambiguous as to whether the running of the statute is tolled by a proceeding to avoid the mortgage initiated prior to the expiration of the…”

Bank of Am., N.A. v. Casey, 517 B.R. 1 (D. Mass. 2014). “She argues that the sole method for curing a defective acknowledgment is found in Mass. Gen. Laws ch. 184, § 24 , which provides: When any owner of land the title to which is not registered, or of any interest in such land, signs an instrument in writing conveying or purporting…”

Lassman v. HSBC Bank USA., N.A. (In re DeMore), 530 B.R. 519 (Bankr. D. Mass. 2015). “184, § 24 , which applies to recorded land, is evidence that the legislature intended for certificates of title to provide constructive notice of encumbrances to third parties is unmeritorious.. Noting that § 24 provides that recorded instruments conveying title to real property…”

Greater Love Tabernacle Church v. VFC Partners 18 LLC (In re Greater Love Tabernacle Church), 536 B.R. 38 (Bankr. D. Mass. 2015). · cites it 2× “§ 546 (a), its filing of the Complaint was timely notwithstanding Mass. Gen. Laws ch. 184, § 24 which establishes a ten year period after the recordation of a mortgage during which proceedings to contest the validity of the mortgage must be commenced.”

Opinion of the Justices to the Governor, 274 N.E.2d 336 (Mass. 1971). “305; G. L. c. 184, § 24, as appearing in St. 1964, c.”

Howson v. Crombie Street Congregational Church, 412 Mass. 526 (Mass. 1992). “In any event, any defect in the filing of the statement was cured ten years later under the provisions of G. L. c. 184, § 24, set forth in full in the margin.”

Eresian v. Mantalvanos, 111 N.E.3d 1113 (Mass. App. Ct. 2018). “Finally, we reject Eresian's assertion that he has standing under G. L. c. 184, § 24. Notwithstanding Eresian's citation to paragraph 5 of the Trust declaration, 5 it is not obvious that § 24, which establishes the validity of instruments effecting title to unregistered land,…”

Nationstar Mortg. LLC v. Daniel J. Galvin (D. Mass. 2018). “See docket #14 at 4-5 (discussing Mass. Gen. Laws ch. 184, § 24 ). The quitclaim deed was recorded on October 4, 2002.”

DaSilva v. Deutsche Bank Nat'l Trust Co. (D. Mass. 2020). “93A (Count V); (4) lack of proper assignment of the Mortgage (Count VI); and (5) lack of proper notarization of the Mortgage in violation of Mass. Gen. Laws c. 184, § 24 (Count VII).”

Show all 13 citing cases →

Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.