Unnotarized Promise to Sell Real Estate vs. Subsequent Bona Fide Purchaser

A party who had entered into a promise to sell real estate, a promise which was not notarized, later sold the property to a third party with knowledge of the prior agreement; the initial promisee sought to compel the transfer of ownership based on the unilateral promise, arguing the non-notarized agreement was still valid between the parties. The court rejected the claim, reasoning that under the relevant property law, a promise to sell real property, even if only unilateral, requires notarization to be enforceable against third parties or to serve as a basis for a definitive transfer of title, especially when the property has subsequently been sold to another purchaser with knowledge of the prior commitment.