A warehouse receipt is a contract, delivery of which carries constructive possession and often title to the goods represented thereby. The common law receipt was not negotiable but rather assignable as any other contract. The delivery of the receipt represented the delivery of the goods, and operated to vest in the assignee the same title as would be vested by an actual transfer of the goods themselves coupled with a similar agreement. "At common law a valid assignment could be made without indorsement by a mere delivery of the receipt, with intent to pass title to the goods. And, statutes authorizing a transfer of warehouse receipts by indorsement have been generally construed not to prevent a valid transfer by any method previously effectual."
Crawford M. Bishop,
Warehouse Receipts as Collateral,
2 Wash. L. Rev.
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