No consideration is necessary for modern statutory conveyances.179 Bargain and sale deeds, however, require, as we have seen,180 a consideration to make them valid, though the requirement has been greatly relaxed in modern times. For a covenant to stand seised a good consideration is sufficient.181 Between the parties to a deed it is valid without the payment of any consideration,182 but it may not be so as to purchasers and creditors of the grantor who attack its validity, claiming that it is in fraud of their rights.183 Where the receipt of a consideration is acknowledged in a deed, this may be rebutted so far as it operates as a receipt;184 though the amount so stated is prima facie the amount paid for the conveyance of the land.185 When the receipt of consideration is thus acknowledged, it may operate as a waiver of the vendor's lien as to subsequent purchasers.186

176 2 Bl. Comm. 297.

177 Devi. Deeds, § 136. See Merritt v. Clason, 12 Johns. (N. T.) 102.

178 Martind. Conv. (2d Ed.) § 15.

179 Cunningham v. Freeborn, 11 Wend. (N. Y.) 241, 248; Rogers v. Hill-house, 3 Conn. 398.

180 Ante, p. 410.

181 Ante, p. 411.

182 Brown v. Brown (S. C.) 22 S. E. 412.

183 De Lancey v. Stearns, 66 N. Y. 157; Keys y. Test, 33 111. 317; Palmer v. Williams, 24 Mich. 328; Glidden v. Hunt, 24 Pick. (Mass.) 221.

184 Mccrea v. Purmort, 16 Wend. (N. Y.) 460; Bullard v. Briggs, 7 Pick. (Mass.) 537; Wilkinson v. Scott, 17 Mass. 257; Goodspeed v. Fuller, 46 Me. 141. And see Mildmay's Case, 1 Coke, 175; Gale v. Williamson, 8 Mees. & W. 405.

185 Clements v. Landrum, 26 Ga. 401. And cf. Wilkes v. Leuson, Dyer, 169a; Frafton v. Hawes, 102 Mass. 533.

186 Jackson v. M'chesney, 7 Cow. (N. Y.) 360; per Sutherland, J.

428 title. (Ch. 16