 section 53(1)(a) said "no interest in land can be created or disposed of except by writing signed by the person creating or conveying the same, or by his agent thereunto lawfully authorised in writing, or by will, or by operation of law".Two cases, "Re Baillie" and "Ottaway v Norman", have concerned secret trusts over land.In neither case the formality requirements are said to be neglected, but neither judgment expressly considered why 53(1)(a) and 53(1)(b) made an impact that an prima facie express trust could be set up.