Is a wife's inchoate right of dower bound to remove an incumbrance from the vendor of land?

Counsel for the applicant cited the case of Shuter v. Patten, [1921] O.L.R. 428, in which the court stated that a wife's inchoate right of dower is "something in the nature of an incumbrance" that the vendor of land is bound to remove. This was an action for specific performance of an agreement for sale of land, and no doubt, in that context, a right of dower would be an "incumbrance". The sale could not be validly made without the dower right being removed. However, that is far from a finding that the incumbrance created by dower rights is equivalent to an actual interest in land.