contracting. As an equitable doctrine, the court has the discretion to vitiate such a contract. When no special relationship exists, the general rule is whether there was a relationship of such trust and confidence that it should give rise to such a presumption. Allcard v Skinner (1887) 36 Ch D 145 Actual undue influence Williams v Bayley (1886) LR 1 HL 200, Bayley's son forged his father's signature on promissory notes and gave them to Williams. Williams threatened Bayley with criminal prosecution, so Bayley made an equitable mortgage to get back the notes. House of Lords upheld the cancellation of the agreement. Bank of Montreal v Stuart 1911] AC 120, 136) and the transaction resulted from that influence. Mutual Finance ltd v John Wetton and Sons Ltd [1937] 2 KB 389 BCCI v Aboody [1992] 4 All ER 955 CIBC Mortgages plc v Pitt [1993] 4 All ER 433 Presumed undue influence Tate v Williamson (1886) LR 2 Ch App 55 Barclays Bank plc v O'Brien [1993] 4 All ER 417 Royal Bank of Scotland v Etridge (No 2) [2001] UKHL 41 Thompson v Foy [2009] EWHC 1076 (Ch) Exploitation or unconscionable bargain Earl of Chesterfield v Janssen (1751) 2 Ves Sen 125, equity intervenes to relieve against unconscionable bargains Earl of Aylesford v Morris (1873) LR 8 Ch App 484 Fry v Lane (1888) 40 Ch D 312 Cresswell v Potter [1978] 1 WLR 255 The Medina (1876) 2 PD 5 Alec Lobb Garages Ltd v Total Oil (GB) Ltd [1985] 1 WLR 173 Backhouse v Backhouse [1978] 1 WLR 243, 251, Balcombe J could not fit in an intelligent woman into the Fry v Lane criteria but citing Bundy said, obiter dicta, that entering a contract without independent advice because of "great emotional strain" could be another way the law could develop. Burmah Oil Co Ltd v Governor of the Bank of England (1981) noted 125 Sol Jo 528, the Bank bought Burmah Oil's shares in BP on request from Burmah, who was very financially embarrassed because the share price had fallen and Burmah's borrowings were structured on the basis that BP shares would be higher. It looked like Burmah may collapse, and the Bank did not want BP shares to go foreign. But afterwards, Burmah claimed the Bank took unfair advantage of bargaining power inequality in buying the shares and making a profit. Walton J doubted Lord