Estates in fee simple, when thus subjected to the possibility of termination, have been usually considered as forming a class by themselves, and are considered in the next section under the head of "determinable, base, or qualified fees."

An estate tail may be limited to terminate on some contingency.62 An estate for life may likewise be subject to such a limitation, as appeared in our discussion of estates for life; it being there stated that the character of an estate as one for life is not changed by the fact that it may terminate on a contingency before the end of the life.63 Examples of estates for life so subject to the possibility of termination are presented by a grant to a woman so long as she remains unmarried, or during widowhood, or so long as she behaves well, or to a man and a woman during coverture, or so long as the grantee dwells in a certain house.64 So an estate may be limited to one for life, to terminate on its voluntary alienation by him, or on his bankruptcy or insolvency,65 or for so long as he may use the property for certain business purposes.66

An estate for years may likewise be limited to terminate on a contingency before the expiration of the number of years named,67 as when a lease is for twenty61. Challis, Real Prop. 252 Sheppard's Touchstone, 125; Port-ington's Case, 10 Coke, 35a, 41b.

62. Challis, Real Prop. 226; Leake Prop. in Land, 217; Gray, Restraints on Alienation, Sec. 69; Portington's Case, 10 Coke 36.

63. Ante Sec. 29. See Thompson v. Baxter, 107 Minn. 122, 21 L. R. A. (N. S.) 575, Harrison v. Foote,

9 Tex. Civ. App. 576, 30 S. W. 838.

64. Co. Litt. 214b.

65. Gray, Restraints on Alienation, Sec.Sec. 78, 80.

66. Warner v. Tanner, 38 Ohio St. 118.

67. See 1 Tiffany, Landlord & Ten. Sec. 12d; Munigle v. City of Boston, 3 Allen (Mass.) 230; Shaw v. Hoffman, 25 Mich. 172.

One years if A lives so long, in which case the lease expires on A's death before the lapse of twenty-one years.68 So an estate for years may be subject to a special limitation that it shall expire before the end of the term, at the option of the lessor,69 or of the lessee.70 An estate for years subject to a rent cannot, however, ordinarily be regarded as one on special limitation, if it is to terminate on the contingency of a default in some matter by the lessee, even though it is expressly provided that the lease shall be "void" on such default, such a provision being regarded as a condition, and not as a limitation.71