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We now understand from Frazer v Walker and Breskvar v Wall that Chris cannot recover the land, what can he do?

S 45(2) RPA Despite any other provision of this Act, proceedings for the recovery of damages, or for the possession or recovery of land, do not lie against a purchaser or mortgagee bona fide for valuable consideration of land under the provisions of this Act merely because the vendor or mortgagor of the land may […]

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