224  FORMAL  CONTRACTS

omits  by  mistake  to  affix  a  seal,  the  instrument  cannot  be
considered  as  his  deed.''

An  official  seal,  such  as  that  of  a  Vice-Consul,  impressed
upon  a  promissory  note,  does  not  make  it  a  sealed  instru-
ment.® Nor  does  the  printed  representation  of  a  seal  on  the
note  of  a  corporation  restrain  its  negotiability,  or  make  it  a
single  bill  only  assignable  as  such.  The  object  of  the  seal  is
rather  to  attest  the  genuineness  of  the  note.''^

When  a  contract  made  by  a  corporation,  and  signed  by  its
officers,  has  the  corporate  seal  affixed,  but  there  is  no  refer-
ence to  the  seal  in  the  body  of  the  contract,  and  it  does  not
purport  to  be  a  specialty,  the  instrument  is  to  be  regarded
as  a  simple  contract.*

Delivery  is  essential.^  To  constitute  delivery  the  obligor
must  do  some  act  putting  it  out  of  his  power  to  revoke.
Delivery  may  be  to  the  grantee,  or  to  a  third  party  or  stranger
for  the  grantee.  It  may  be  inferred  from  the  circumstances
of  the  case,  and  is  prima  facie  presumed  to  have  taken  place

5  state  V.  Humbird,  54  Md.  327 ;  Stabler  v.  Cowman,  7  G.  &  J.  284.
When  a  written  contract  concludes  with  the  words,  "witness  our
hands  and  seals,"  but  is  signed  and  not  sealed,  it  is  valid  as  a  sim-
ple contract.     Noel  v.  Atlas  Cement  Co.,  103  Md.  209.
6  De  Bebian  v.  Gola,  64  Md.  262.
7  Jackson  v.  Myers,  43  Md.  452.
