WVC 36 - 3 - 2
§36-3-2. Covenant on unsealed conveyances or contracts.
An action of covenant may be maintained on any written
conveyance or lease which, under the provisions of section one,
article one of this chapter, must be by deed, and which has been
executed since the twenty-sixth day of July, nineteen hundred and
twenty-one, for the breach of any covenant or warranty or other
agreement therein contained, whether such instrument be sealed or
unsealed, and every estoppel which would have been created by
such writing, if sealed, shall be created by it, though it be
unsealed. Such action of covenant may also be maintained upon
any contract or agreement for the conveyance of any interest in
land, which interest, if conveyed, would be required, by said
section one, article one of this chapter, to be conveyed by deed.