Massachusetts General Laws

Mass. Gen. Laws ch. 4, § 9A (2026)

Recital giving unsealed instrument effect of sealed instrument; ''person'' defined

✓ current as of July 2026

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Section 9A. In any written instrument, a recital that such instrument is sealed by or bears the seal of the person signing the same or is given under the hand and seal of the person signing the same, or that such instrument is intended to take effect as a sealed instrument, shall be sufficient to give such instrument the legal effect of a sealed instrument without the addition of any seal of wax, paper or other substance or any semblance of a seal by scroll, impression or otherwise; but the foregoing shall not apply in any case where the seal of a court, public office or public officer is expressly required by the constitution or by statute to be affixed to a paper, nor shall it apply in the case of certificates of stock of corporations. The word ''person'' as used in this section shall include a corporation, association, trust or partnership.

Notes of Decisions

Cited in 17 cases (2 in the last 5 years), 1968–2026 · leading case: Knott v. Racicot, 442 Mass. 314 (Mass. 2004).

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Knott v. Racicot, 442 Mass. 314 (Mass. 2004). · cites it 2× “See *320 G. L. c. 4, § 9A, inserted by St. 1929, c.”

Nalbandian v. Hanson Restaurant & Lounge, Inc., 338 N.E.2d 335 (Mass. 1975). · cites it 3× “See G. L. c. 4, § 9A (originally enacted by St.”

Springfield Library & Museum Ass'n, Inc. v. Knoedler Archivum, Inc., 341 F. Supp. 2d 32 (D. Mass. 2004). · cites it 2× “2 (1975) (holding that language in an agreement that recited that it was “[sjigned and sealed” was sufficient to give the instrument the legal effect of a sealed instrument by virtue of Mass. Gen. L. ch. 4, § 9A 3 ). It follows, then, that Plaintiff *38 either needed to have…”

Marine Contractors Co. Inc. v. Hurley, 310 N.E.2d 915 (Mass. 1974). “G.L. c.4, § 9A. 3 We should not be taken to imply that the seal would of itself render a purely gratuitous promise specifically enforceable.”

Johnson v. Norton Hous. Auth., 375 N.E.2d 1209 (Mass. 1978). · cites it 2× “G. L. c. 4, § 9A. Marine Contractors Co. v.”

Ward v. Ward, 874 N.E.2d 433 (Mass. App. Ct. 2007). “94, 98 (1954); G. L. c. 4, § 9A. Furthermore, the jury determined that Arthur, Jr.”

City of Boston v. Roxbury Action Prog., Inc., 862 N.E.2d 763 (Mass. App. Ct. 2007). “See G. L. c. 4, § 9A; Nalbandian v. Hanson Restaurant & Lounge, Inc.”

Kingston Hous. Auth. v. Sandonato & Bogue, Inc., 577 N.E.2d 1 (Mass. App. Ct. 1991). “Under G. L. c. 4, § 9A, “a recital that [an] instrument is sealed .”

201 Forest Street LLC v. LBM Fin. LLC (In Re 201 Forest Street LLC), 409 B.R. 543 (Bankr. D. Mass. 2009). “2d 7, 8 (1950) (“[T]here was a recital in each that it was executed under seal, which under G.L. c. 4, § 9A, is sufficient to constitute a sealed instrument, and no actual consideration need be shown.”

Holt v. Fed. Deposit Ins., 216 B.R. 71 (D. Mass. 1997). “Mass. Gen. Laws ch. 4, § 9A. The signing of a document under seal is adequate consideration to support a valid agreement.”

Eaton Fin. Corp. v. Dewar, 1990 Mass. App. Div. 156 (Mass. Dist. Ct., App. Div. 1990). “With respect to the defendant’s claim that the instrument of guaranty fails for lack of consideration, we note that the guaranty was executed as a sealed instrument G.Lc. 4, §9A Consideration is conclusively presumed where the agreement is under seal and the obligor is bound by…”

Michael Gerhardt & Another v. Robert S. Burr & Others. (Mass. App. Ct. 2026). · cites it 4× “That statement gives each agreement the legal effect of a sealed instrument under G. L. c. 4, § 9A. See Nalbandian, 369 Mass.”

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