The fee simple is the primary interest in land under common law. It is an estate of a potentially unlimited duration as stated in the Walsingham’s case. The court stated that he who has a fee simple in land has a time in that land without end, or the land for time without end. A feature of the fee simple is that it is capable of infinite transimissibity (capable of transferred as many times as ever). It may be transferred inter vivos or testamentally. A person owning the fee simple may die but the estate remains. However, fee simple would terminate if the holder died without leaving any descendants or blood relations. The owner of this interest does not have any burdens such as rent. Where the land was alienated, the fee simple would continue as long as there were heirs of the new tenant.