Which of the following would not create an estate in property?

A trust deed primarily functions as a security instrument in real estate transactions rather than as a means to create an estate in property. It is an agreement or a document used to secure a loan on real property, effectively transferring the property title to a trustee who holds it on behalf of the lender until the debt is paid off. This means that the trust deed itself does not confer ownership or possessory rights in the property, which are essential components of an estate.

In contrast, leaseholds, life estates, and fee simple ownership are all forms of estates in property. A leasehold provides a temporary right to occupy and use a property; a life estate grants rights to a person for their lifetime, after which the property reverts to another party; and fee simple is the most complete form of property ownership, granting full rights to the property holder. Each of these options establishes a distinct and defined interest in the property, defining how it can be used, transferred, or inherited.