An accumulation of granular cells associated with the enamel organ of a developing deciduous, incisor tooth was noted during light microscopy (LM) of serial sections from the right half of a mandible from a stillborn, female infant of 37 weeks gestations. There was a break in continuity of the enamel matrix associated with the focus of granular cells, which appeared to be continuous with, and arise directly from, the cells of the stratum intermedium.The granular cells were very similar histologically to those of a congenital epulis but it is impossible to say whether the lesion would have developed sufficiently to present clinically as an epulis. Less probably, the granular cells might eventually have been associated with the subsequent development of a granular cell ameloblastoma or ameloblastic fibroma. If the lesion does represent an early stage in the formation of a congenital epulis, it would support the odontogenic theory of origin of the granular cells.