Can an estate trustee sell a house before receiving a Certificate of Appointment from the court?

An estate trustee can often start the process before the Certificate of Appointment of Estate Trustee arrives, but generally cannot complete the sale without it. Listing the property, working with a realtor, and even signing an Agreement of Purchase and Sale, often made conditional on the certificate being obtained, is common practice while the court application is pending. Where things stop is at closing: because title to the property is still registered in the deceased's name, a buyer's lawyer and lender will require proof that the person purporting to sell actually has legal authority to convey it, and that proof is the Certificate of Appointment.

Without it, there is no reliable way for the land registry system to confirm the seller's authority, so a purchaser's lawyer will not release funds or register the transfer. This is different from property passing by survivorship in joint tenancy, which doesn't require a certificate at all, since the survivor's ownership already exists in law. Anyone administering an estate that includes real property should apply for the certificate as early as possible and coordinate the timeline with their real estate lawyer, so the sale isn't held up waiting on the court process.