there are some limitations to indefeasibility, and different jurisdictions have different laws and provisions. For example, in the Australian state of Victoria, the Torrens system is manifested in the Transfer of Land Act 1958 (Vic). Upon registration of an interest and subsequent recording on title of the interest, the registered owner's claim to that interest is superior to all other claims other than those listed in s.42 of that Act, which provides that the title of the registered interest holder is subject to, inter alia: those listed on the title, those claiming the land on a prior folio (s.42(1)(a)), where the land is included by wrong description on the part of the Registrar and the proprietor is not or has not derived title from a purchaser ‘for value’ (s.42(1)(b), “paramount interests” (s.42(2)(a)-(f)) – these interests, although even possibly unregistered, are 'superior' to interests that are registered. Additionally, there are other exceptions or circumstances that can defeat indefeasibility, such as: fraud committed by the registered interest holder [principle of immediate indefeasibility]. See, for example, the New Zealand case of Efstratiou, Glantschnig, and Petrovic v Glantschnig, judicial action, where it can be shown that there was some contractual promise or undertaking by the registered party vis-à-vis the unregistered party, inconsistent legislation (in which case the most recent legislation prevails), volunteer, where the registering party acquires the interest for no consideration (e.g. bequeathed in a will). By contrast, in New South Wales volunteers are entitled to indefeasibility. Adoption The adoption of the Torrens title registry throughout the British Commonwealth, and its legal context, was covered in depth by James Edward Hogg in 1920. Australia The first sale of land registered under the system was to pastoralist William Ransom Mortlock (later elected to the South Australian House of Assembly) on 25 August 1858. Starting with South Australia, all Australian colonies introduced the Torrens system between 1858 and 1875. Since then, each colony, and since 1901, states and territories, state or territory has maintained its own land titles register of land. The Torrens system did not replace the common law system but applied only to new land grants and to land that was voluntarily registered under the relevant Act. In Australia most land is held under the Torrens Title system, although remnants of the old system of land title still remain. All land in the Australian Capital Territory is leasehold (effectively Torrens freehold), while and