The Missouri statute providing that the use of the words, "grant, bargain and sell", in a fee simple conveyance shall be construed as imposing on the grantor certain covenants of title, is not only interesting in respect to its history, but, as it stands at present, it appears to be different in scope from any statute on the subject in any other jurisdiction. Furthermore, this statute has been construed by the Missouri Supreme Court so that the final joint product of the legislative and the judicial branches of the state is surprising.
James W. Simonton,
Statutory Covenants for Title in Missouri,
28 Bulletin Law Series.
Available at: http://scholarship.law.missouri.edu/ls/vol28/iss1/3