In Shogun Finance Ltd v. Hudson 1 a rogue fraudulently posed as a Mr Durlabh Patel of Leicester and obtained possession of a Mitsubishi Shogun motor car from a dealer for an agreed price of £22,250 pursuant to a hire-purchase agreement ostensibly concluded with Shogun. The rogue subsequently sold the vehicle for £17,000 to Mr Hudson, a good faith private purchaser. The facts of Shogun classically illustrate the uncomfortable intersection of contract and property law and the intractable (and enduring) problem of how to allocate between two innocent parties who have been the victim of fraud, the risk of that fraud. The failure of English property law to regard the transfer of possession of property from the original owner to a rogue as creating an estoppel in an action against a good faith purchaser may be contrasted with the position of such persons in other jurisdictions.2 The vulnerability of innocent third party purchasers under English law3 has been the subject of regular judicial critique4 and a Law Reform Committee Report.5 In practice, in cases such as Shogun , competing interests in property are decided through an application of principles of contract as opposed to property law. In Shogun itself, Mr Hudson’s right to keep the vehicle depended on whether the contract between the rogue and Shogun was void for a mistake of identity or merely voidable for fraud.