A deed must be completely written when it is delivered, and for this reason any alterations or interlineations in the instrument must be made before delivery,195 though they may be added after the deed has been signed.196 An alteration by a stranger to the instrument does not affect the validity of a deed,197 and as to the

187 Thompson v. Thompson, 9 Ind. 323.

188 Lake Erie & W. R. Co. v. Whitham, 155 111. 514, 40 N. E. 1014; Ells-worth v. Railroad Co., 34 N. J. Law, 93; Ford v. Gregory's Heirs, 10 B. Mon. (Ky.) 175.

189 Fash v. Blake, 44 111. 302; Blanchard v. Tyler, 12 Mich. 339; Henderson v. Baltimore, 8 Md. 353; Flynn v. Flynn (N. J. Ch.) 31 Atl. 30.

190 Ingram v. Little, 14 Ga. 173.

191 U. S. v. Nelson, 2 Brock. G4, Fed. Cas. No. 15,862, per Marshal, C. J.

192 Duncan v. Hodges, 4 Mccord (S. C.) 239; Devin v. Himer, 29 Iowa, 300. But see Chauncey v. Arnold, 24 N. Y. 330; Drury v. Foster, 2 Wall. 24.

193 Schintz v. Mcmanamy, 33 Wis. 299; Clark v. Allen, 34 Iowa, 190; Pence v. Arbuckle, 22 Minn. 417; Otis v. Browning, 59 Mo. App. 326 (grantee's name).

194 Though an element of fraud is generally present. Upton v. Archer, 41 Cal.85;cooperv.page,62me.192.

195 People v. Organ, 27 111. 26; Wallace v. Harmstad, 15 Pa. St. 462. 196 Stiles v. Probst, 69 111. 382; Penny v. Corwithe, 18 Johns. (N. Y.) 499. 197 Robertson v. Hay, 91 Pa. St. 242.

§ 265) effect of such alterations by the grantee the cases are conflicting. Some courts hold that the only effect is on the remedy,-that is, that the grantee cannot bring snit on the deed;198 while other courts hold that the validity of the deed is affected only as far as it is to be used in evidence.199 Where alterations or interlineations are present in a deed, the presumption is that they were made before the deed was delivered,200 though there are cases holding the contrary.201