<Dt> Unity of title </Dt> <Dd> The interests held by the co-owners must arise out of the same instrument . </Dd> <Dl> <Dt> Unity of interest </Dt> <Dd> Both tenants must have the same interest in the property . <Dl> <Dd> This means that the joint tenants must have the same type of interest, and the interest must run for the same duration . For example, if X and Y create a joint tenancy, both X and Y's interests must be in fee simple absolute . If, for example, X has a fee simple absolute and Y has a life estate, there is no unity of interest . </Dd> </Dl> </Dd> </Dl> <Dt> Unity of interest </Dt>

Which of the following is not one of the four unities of titles