New York Consolidated Laws

N.Y. Real Property Law § 244 (2026)

When grant takes effect

✓ current as of May 2026

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§ 244. When grant takes effect. A grant takes effect, so as to vest
the estate or interest intended to be conveyed, only from its delivery;
and all the rules of law, now in force, in respect to the delivery of
deeds, apply to grants hereafter executed.

Notes of Decisions

Cited in 42 cases (6 in the last 5 years), 1985–2025 · leading case: In Re Minbatiwalla, 424 B.R. 104 (Bankr. S.D.N.Y. 2010).

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In Re Minbatiwalla, 424 B.R. 104 (Bankr. S.D.N.Y. 2010). “See N.Y. Real PropeRTY Law § 244 (“A grant takes effect, so as to vest the estate or interest intended to be conveyed, only from its delivery; and all the rules of law, now in force, in respect to the delivery of deeds, apply to grants hereafter executed.”

Matter of Humann, 136 A.D.3d 1036 (N.Y. App. Div. 2016). “The respondent moved for summary judgment dismissing the petition and the petitioner cross-moved for summary judgment on the petition.”

In Re Mims, 438 B.R. 52 (Bankr. S.D.N.Y. 2010). “” According to N.Y. Real PROPERTY Law § 244 , assignments in New York state may be effectuated by the delivery of the relevant note and mortgage.”

In re Idicula, 484 B.R. 284 (Bankr. S.D.N.Y. 2013). “at 56 ; see also N.Y. Real PropeRty Law § 244 (“A grant takes effect, so as to vest the estate or interest intended to be conveyed, only from its delivery; and all the rules of law, now in force, in respect to the delivery of deeds, apply to grants hereafter executed.”

In re Benyamin, 587 B.R. 243 (Bankr. S.D.N.Y. 2018). “See N.Y. Real Property Law § 244 ("A grant takes effect, so as to vest the estate or interest intended to be conveyed, only from its delivery; and all the rules of law, now in force, in respect to the delivery of deeds, apply to grants hereafter executed.”

M&T Real Est. Trust v. Doyle, 987 N.E.2d 257 (NY 2013). “Real Property Law § 244 states that a “grant takes effect, so as to vest the estate or interest intended to be conveyed, only from its delivery; and all the rules of law, now in force, in respect to the delivery of deeds, apply to grants hereafter executed.”

In Re 234-6 West 22nd St. Corp., 214 B.R. 751 (Bankr. S.D.N.Y. 1997). “2d 93 (1996), citing N.Y. Real Property Law § 244 ; Manhattan Life Ins.”

Garson v. Tarmy, 2020 NY Slip Op 06104 (N.Y. App. Div. 2020). · cites it 2× “A corrective deed is valid and enforceable so long as it is delivered to and accepted by the grantee ( see Real Property Law § 244; 43A NY Jur 2d Deeds § 188).”

Whalen v. Harvey, 235 A.D.2d 792 (N.Y. App. Div. 1997). “Plaintiff contends that the deed was never delivered to defendant during decedent’s lifetime and, therefore, there was no valid inter vivos gift of the property.”

James v. Lewis, 135 A.D.2d 785 (N.Y. App. Div. 1987). “His challenge at trial was not clearly focused, but on appeal he claims that it had not been his or his mother’s intention in 1971 to deliver the deed, and hence to convey title, to the corporation, and that therefore, all subsequent conveyances are void.”

Nationstar Mtge., LLC v. Goodman, 2020 NY Slip Op 05631 (N.Y. App. Div. 2020). “Real Property Law § 244 provides that "[a] grant takes effect, so as to vest the estate or interest intended to be conveyed only from its delivery; and all the rules of law, now in force, in respect to the delivery of deeds, apply to grants hereafter executed.”

Tomhannock, LLC v. Roustabout Resources, LLC, 149 A.D.3d 1219 (N.Y. App. Div. 2017). “Rather, title to property vests upon the execution and delivery of the deed (see Real Property Law § 244; Matter of Humann, 136 AD3d at 1036 ), and the fact that the deed may not be recorded until a later date — or at all — does not affect the validity of the conveyance (see…”

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