32. Life Estates Defined.
33. Creation of Life Estate. 84-36. Conventional Life Estates.
32. Life estates are freeholds not of inheritance. They include:
(a) Estates for the tenant's own life.
(b) Estates for the life of another,-per antre vie.
(c) Estates for an uncertain period, which may continue during a life or lives.
Life estates come next below estates tail in order of quantity of interest. They are freeholds, but not of inheritance.1 In general terms, they are estates whose duration is limited by the length of a human life. Estates of uncertain duration, which may continue during a life or lives, are regarded as life estates.2 It is immaterial how improbable it is that the estate will last during a life. It is sufficient if by possibility it may do so. An estate to a woman during widowhood is a life estate. It may last during her life, but it cannot last longer.3