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[1977] 1 WLR 285. H1 and W1, and H2 and W2, were two married couples; W1 and W2 were sisters. H1 and H2 jointly purchased a house, part of which was occupied by their mother in law, and part was let for rent. H2 was registered as the legal owner. Eventually H2 and W2 divorced, and H2 transferred the whole of the house to his ex-wife (W2) for £1 as settlement. The question arose whether H1 could enforce his beneficial interest in has share of the house against W2. Clearly it would have been equitable to allow him to do so; he had contributed in equal share to the cost, and a formal trust instrument had been executed by H1 and H2 indicating their respective contributions. The problem was that the interest of a beneficiary under a trust is aminor interest in RegisteredConveyancing. H1 should not have been able to enforce against H2 unless his beneficial interest was noted on the registered title. This left the judge in something of a cleft stick -- clearly H2 and W2 had knowingly acted to destroy an equitable interest of which they were well aware, and were hiding behind the protection of statute. The judge did eventually find for H1, and compel W2 to recongize his equitable interest. He did this on the basis that W2 was not a 'purchaser for value', since the definition of 'purchaser' included a requirement of 'good faith'. He also said that the court had a general jurisdiction to impose a ConstructiveTrust on a purchaser who acts in bad faith. Peffer is often cited as an example of this jurisdiction, but it is not clear to what extent it can stand alongside the House of lords decision in MidlandBankVGreen1981 (which, although an unregistered land transaction, held that although the purchaser was acting in bad faith, this did not amount to notice). It can be argued that the Peffer depends on the statutory definition of 'purchaser' in the Lra (1925), which includes a requirement for good faith. In that case, probably the Lra (2002) renders Peffer obsolete, as it does not repeat this requirement.