Pending title confirmation limits liquidation purchaser's possession rights, preserving a school's occupation through the academic year.

A purchaser of assets sold in liquidation cannot obtain immediate possession of land occupied by an operating school while the purchaser's title and entitlement to conveyance remain pending in appeal. Eviction before title is finally conferred is inequitable. The school may continue in occupation until title is conferred; if title is conferred during an academic year, educational continuity requires it to remain until that academic year ends. The school must then vacate and deliver possession to the purchaser.

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Issues: Whether the purchaser of assets sold in liquidation was entitled to immediate possession of the five-acre area occupied by a school.

Analysis: The purchaser's title and entitlement to conveyance remained under consideration in a pending appeal. Immediate eviction of an operating school was therefore inequitable before title was finally conferred. The school could continue pending confirmation of the sale and conveyance; where title is conferred during an academic year, continuity of education required occupation until that academic year ends.

Conclusion: The school may remain in occupation until title is conferred on the purchaser and, if that occurs during an academic year, until the end of that academic year, after which it must vacate and deliver possession.

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