In Brunz v. Smith, 3 Haw. 783 (Hawaii King. 1877), the court considered The Act of 1872, entitled, "An Act to Regulate the Issuing of Royal Patents" (Section 1 of which is identical to HRS 172-11), and decided that patents based upon award do not confer or confirm title of later holders because the latter's names do not appear in the original grant of land. 3 Haw. at 787. Rather, an award of land through royal patent operates as a quitclaim of interest by the government and other claimants must prove their interest in the land through deed or other means. 3 Haw. at 787-88; Mist v. Kawelo, 11 Haw. 587, 589 (Hawai'i Rep. 1898). Hence, titles awarded by Royal Patent may not be vested for "perpetuity," as July seems to suggest, but rather, all subsequent claimants of land must derive their title from the person to whom the original award was made. Brunz 3 Haw. at 787.