Massachusetts General Laws
Mass. Gen. Laws ch. 244, § 22 (2026)
Suit without previous tender
✓ text as last checked Sept. 2026 (this copy records no edition or section history)
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Section 22. The person entitled to redeem may, before the expiration of the three years limited for redemption, and before or after an entry for breach of condition, and before a sale pursuant to a power contained in the mortgage, commence suit for redemption without previous tender, and may in such suit offer to pay such amount as shall be found due from him, or to perform such other condition as the case may require; but a mortgagee who has published a notice of sale prior to the commencement of such suit may proceed with said sale unless the amount due is paid into court or the sale enjoined.
Notes of Decisions
Cited in 4
cases, 1928–2004 · leading case: Brown v. Gerstein, 460 N.E.2d 1043 (Mass. App. Ct. 1984).
Brown v. Gerstein, 460 N.E.2d 1043 (Mass. App. Ct. 1984). “The plaintiffs argue, however, that Gerstein was negligent because he failed to advise them of alternatives to avoid foreclosure (and in the case of the remedy allegedly provided by G. L. c. 244, § 22, because he failed to find and plead that statute), and that Gerstein was…”
In re Crichlow, 322 B.R. 229 (Bankr. D. Mass. 2004). “See G.L. c. 244 § 22. Beal v. Attleborough[Attleboro] Savings Bank, 248 Mass.”
White v. Macarelli, 166 N.E. 734 (Mass. 1929). “See G. L. c. 244, § 22. Beal v. Attleborough Savings Bank, 248 Mass.”
Depon v. Shawye, 161 N.E. 243 (Mass. 1928). “accord with G. L. c. 244, § 22, or that Depon had acted fraudulently.”
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