An easement may be extinguished by an express release thereof made by the owner of the dominant tenement in favor of the owner of the servient tenement,57 and such an express re51. Post, Sec. 565.

52. Post, Sec. '561.

53. Clayton v. County Court, 58 W. Va. 253, 2 L. R. A. N. S. 598, 52 S. E. 103.

54. Allen v. City of Chicago, 176 111 113, 52 N. E. 33; Clayton v. County Court, 58 W. Va. 253, 2 L. R. A. N. S. 598, 52 S. E. 103.

55. Googins v. Boston, & A. R. Co., 155 Mass 505, 30 N. E. 71; Currie v. Bangor, & A. R. Co., 105 Me. 529, 75 Atl. 51.

56. Lewis, Eminent Domain, Sec. 531, note 21.

57. Goddard, Easements, 575; Gale, Easements, 512. Jersey Farm Co. v. Atlanta Realty Co., 164 Cal. 412, 129 Pac. 593; Richards v. Attleborough Branch R. Co., 153 Mass. 120, 26 N. E. 418; Flaten v. Moorehead City, 58 Minn. 324, 59 N. W. 1044; Mcallister v. Deoane, 76 N. C. 57.

Somewhat analagous to the case of an express release is a case in which it was held that one who made a conveyance of land with a covenant of warranty therein was estopped, upon subsequently acquiring adjoining lease must, at common law, like any other release, be under seal.58 Under the doctrine of abandonment of an easement,59 however, as recognized in the modern decisions, it seems that even an oral relinquishment of the easement might be effective.

One who has only a partial or limited interest in the dominant tenement can obviously extinguish the easement by release only as against himself.60