Definition
"Che" as a legal term does not appear to carry independent substantive meaning in the historical common law tradition. The fragment preserved in Burrill's Law Dictionary under this heading is incomplete as indexed, and the entry as it surfaces in the corpus appears to be a truncated cross-reference or indexing artifact rather than a defined term. No freestanding legal doctrine, procedural rule, or term of art bearing the name "che" has been identified in English or American common law sources.
Researchers encountering "che" in historical legal manuscripts or indexes should treat it as a possible abbreviated form, a partial headword, or a filing artifact rather than a self-contained legal concept.
Common Confusion
Researchers should not conflate this apparent heading with:
— CHE as an abbreviation in civil law or French legal tradition (where "chose" — meaning "thing" — appears in phrases like chose in action and chose in possession, sometimes abbreviated in manuscript sources).
— CHATTEL (occasionally abbreviated "chat." or "ch." in older indexes), which is the likely parent entry here.
If a historical document uses "che" as a shorthand, the most probable referents are "chose," "chattel," or a proper name element, depending on context.
Why It Matters in Research
The principal research risk here is false confidence: a corpus hit for "che" in a historical legal dictionary or document index does not reliably indicate a discrete legal term. The Burrill entry associated with this headword in the Law Mind corpus resolves immediately into discussion of chattel interests in real property — the substantive content concerns the distinction between real and personal estate, and the nature of a term-of-years as a chattel interest. This strongly suggests that "che" as indexed is either an abbreviation for "chattel" or a truncated heading that was separated from its full form during digitization or original typesetting.
If your research led you to this entry while tracing property law concepts, the operative material is found under CHATTEL, CHATTEL INTEREST, and ESTATE FOR YEARS. The passage preserved in the Burrill fragment — citing Stephens' Commentaries, Kent's Commentaries, and Hilliard on Real Property — belongs squarely to that body of doctrine.
Historical Dictionary Support
Burrill's Law Dictionary contains no complete independent entry for "che" as a legal term of art. The text fragment associated with this heading in the corpus reads as the tail end of a longer entry, discussing the capacity of a real property interest to be held as a chattel or personal estate — specifically the estate for years. The authorities cited (1 Steph. Com. 262; 2 Kent's Com. 342; Burton's Real Prop. ch. 5; 1 Hilliard's Real Prop. 51) are all standard nineteenth-century treatise citations on the personal property character of leasehold estates. No other historical dictionary in the Law Mind shelf — not Black's, not Bouvier, not Tomlin — lists "che" as a headword.
The most reasonable conclusion is that this entry is an indexing or pagination artifact. The substantive doctrine it points toward — that a leasehold or estate for years is classified as personal property despite involving land — is well-developed in the sources cited and is properly treated under CHATTEL INTEREST and ESTATE FOR YEARS.