Re Stucley [1906] 1 Ch 67, a vendor of a reversionary interest in a trust fund, who sold the interest to the trustee, was held to have an equitable lien in the subject matter, although it was clearly personalty and not realty. In Barker v Cox (1876) 4 Ch D 464, the purchaser of property which was included in a matrimonial settlement paid the price in advance to one of the trustees, and the purchaser was held to have an equitable lien in investments which the trustees subsequently acquired with the purchase price. In Langen and Wing v Bell [1972] Ch 685, a director's service agreement required him to assign his shares in the company if he was terminated, and he was to receive a price calculated at a later date when the annual accounts were available; he was held to have an equitable lien over the transferred shares to secure the payment of the eventual purchase price. In Lord Napier and Ettrick v Hunter [1993] 2 WLR 42, it was held that an indemnity insurer's subrogation rights in relation to funds improperly paid directly to the insured were subject to an equitable lien. But overall, there is still perceived to be a lack of central nexus. Statutory liens and contractual liens Although arguably not liens as such, two other forms of encumbrance are sometimes referred to as liens. Statutory liens Certain statutes provide for a passive right to retain property against its owner as security for obligations. For example, section 88 of the Civil Aviation Act 1982 of the United Kingdom permits an airport to detain aircraft for unpaid airport charges and aviation fuel. Although this right has been treated as a lien under UK insolvency law, it has been argued that such statutory rights are not in fact liens, but rights analogous to liens, although an argument may be made that this is a distinction without a difference. Contractual liens It has also been argued that an agreement by contract that one party may retain the goods of another party until paid is not a lien, as under the common law, liens could only be non-consensual. However, it appears that under insolvency law, such rights will be treated as liens even if they are not expressed to be liens. Maritime liens A maritime lien is a lien on a vessel, given to secure the claim of a creditor