vast majority of land in Ireland (by acreage) is held under Torrens title as compulsory registration in the land registry upon sale has been a requirement in rural areas for many years. Compulsory registration was extended to the (more urban) counties of Cork, Dublin, Galway, Limerick and Waterford in 2010, thus extending mandatory Torrens title to every part of the Republic of Ireland. Israel A Torrens title system was implemented by the British in Mandatory Palestine, and has continued in use since Israel's foundation in 1948. As of 2016, about 4% of the country's land area is still registered under a pre-Torrens, deeds registration system. Malaysia Malaysia has adopted three versions of the Torrens system: For Peninsular Malaysia, this is enacted in the National Land Code, Act 56 of 1965. For the state of Sarawak, this is enacted in the Sarawak Land Code, Chapter 81 of 1958. For the state of Sabah, this is enacted in the Land Ordinance (Sabah Chapter 68). Unlike the National Land Code and the Sarawak Land Code, the Land Ordinance (Sabah Chapter 68) does not provide any indefeasibility of title. New Zealand New Zealand adopted a similar system from 1870 under the Land Transfer Act, 1870 The Land Transfer (Compulsory Registration of Titles) Act 1924 brought most of the remaining land in the country under the Torrens system and by 1951 the register was considered complete, although small remnants of land may still exist under the deeds system. The Land Transfer Act 1952 further implemented the Torrens system. In the 20th century, academics and judges disagreed about whether to interpret indefeasibility as "deferred" or "immediate". In 1967, the Privy Council in Frazer v Walker decided that a registered owner will obtain an indefeasible title to an interest or estate as soon as they become the registered owner of the interest or estate (the principle of immediate indefeasibility). The 1952 Act was superseded by the Land Transfer Act 2017. The 2017 Act introduces a judicial discretion to cancel an owner's registration of title in cases of "manifest injustice", which arguably frustrates the certainty of title considered fundamental to the principle of immediate indefeasibility. In New Zealand most land is held under the Torrens Title system, although remnants of the old system of land title still remain. Māori customary title (native title) is recognised as a separate form of ownership. Some land remains as Crown Land (i.e.