Pilcher v Rawlins

判决理由

事实

Trustees of a settlement lent trust money to Rawlins on the security of a mortgage of his land. Later, in breach of trust, the surviving trustee joined with Rawlins in a scheme by which the mortgage was discharged and reconveyed, and Rawlins then re-mortgaged the same land to new mortgagees who advanced money and took the legal estate without any notice of the beneficiaries' equitable interest. The beneficiaries under the original trust sought to enforce their interest against the land in the hands of the new mortgagees.

判决摘要

The Court of Appeal in Chancery held that the new mortgagees, who had acquired the legal estate for value and without notice of the trust, took the land free of the beneficiaries' prior equitable interest, so the beneficiaries could not enforce their interest against them. James LJ gave the classic statement of the bona fide purchaser doctrine — 'equity's darling' — describing the plea of a purchaser of the legal estate for valuable consideration without notice as an absolute, unqualified, and unanswerable defence to a claim by the holder of a prior equitable interest. Once such a purchaser has obtained the legal estate honestly and for value, without actual, constructive, or imputed notice of the earlier equity, the court will not interfere with them at all. The beneficiaries' remedy lay against the defaulting trustee, not against the innocent purchaser of the legal estate. The case remains the definitive statement of the doctrine of the bona fide purchaser for value without notice.

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