associated fraud (an illegal act). Although the purpose of the initial registration had been illegal, the purpose of the purchase itself had not. Since Tinsley, the courts have been more willing to examine the intention of the parties rather than relying on the strict maxim that "he who comes to equity must come with clean hands". The standard law on this was set out by Millett LJ in Tribe v Tribe: As seen in Tribe v Tribe, a common form of illegality is where the transferor is worried about bankruptcy or insolvency, and transfers the property to avoid having to pay his creditors. Section 423 of the Insolvency Act 1986 empowers to the courts to reverse any transfer which removes assets from creditors with the intention to avoid their claims. These creditors do not have to be creditors at the time of the transfer; it is enough that they be creditors after the transfer or sale, as in Midland Bank v Wyatt. References Bibliography English trusts law