The court of chancery in England always acted in personam, and not in rem, and consequently, in adjudicating rights of the different parties to a proceeding concerning land, it did not, by its decree, undertake to transfer the title from one to the other of such parties, but gave relief by ordering one party to make a conveyance, cancel an instrument, or do other acts so as to establish and perfect the rights of the respective parties as adjudicated. This principle of action on the part of courts of equity has, however, been changed by statute in many states of this country, so that, instead of requiring the parties to carry out the decree, the court itself does so. acting through a commissioner or other officer, and, under some statutes, the decree alone, without any further action, is sufficient to transfer the title.41 As regards land outside the jurisdiction, however, the court must still act in personam.42

39. Freeman, Cotenancy, Sec.Sec. 550-564.

40. 2 Dembitz, Land Titles, Sec. 156.

41. Huston, Decrees in Equity, Ch. 2.

42. Pomeroy, Eq. Jur. Sec.Sec. 134, 135, 170, 1317. See Arndt v. Griggs, 134 U. S. 316, 33 L. Ed. 918; Lindley v. O'reilly. 50 N. J. L. 636, 1 L. R. A. 79, 7 Am. St. Rep. 802, 15 Atl. 379.

While a judgment in an action concerning lard of a strictly legal character, such as ejectment, or the old real actions, or the statutory "trespass to try title," is usually decisive of the rights of the parties thereto in regard to the ownership of the land, as between themselves, it cannot be regarded as transferring the title in any sense, but merely decides what effect is to be given to previous transfers.