521 Shaw v Commissioner of Metropolitan Police [1987] 1 WLR 1332, following Henderson Estoppel by conduct: Farquharson Bros v C King & Co Ltd [1902] AC 325 Mercantile Bank of India Ltd v Central Bank of India [1938] AC 287, upholding Farquharson Central Newbury Car Auctions Ltd v Unity Finance Ltd [1957] 1 QB 371 Mistake about identity: Shogun Finance Ltd v Hudson [2003] UKHL 62 Exceptions Sales in open markets In the eighteenth century at the time of William Blackstone, sales in an open market were an exception to the nemo dat principle in English law. However, after the growth in the UK of car boot sales led to opportunities for rogues to "fence" stolen property, the Sale of Goods (Amendment) Act 1994 abolished the "market overt" exception to the nemo dat rule in 1995. Leases In the case of Bruton v London Quadrant Housing Trust [2000] 1 AC 406, Lord Hoffman created an exception to the rule in relation to the granting of a leasehold estate in land. It is possible, though this is controversial, for a mere licensee to create a tenancy if the hallmarks of a tenancy are present. This means that the holder of a lesser right (i.e. the licensee, which is not an estate in land) can create a larger right, an estate even. Scots law As in the United States, banknotes in Scotland are an exception to the rule. This issue arose in the 1749 case of Crawfurd v The Royal Bank, where title to a banknote issued by the Bank of Scotland that had gone missing in the post and found in the possession of the Royal Bank of Scotland was disputed. See also Corpus Juris Civilis English property law References Brocards (law) Legal rules with Latin names Property law