other law

[under development]

Under UK, New Zealand, Canadian, and US common law the buyer historically bore the risk of void or voidable title. That burden meant that the 'caveat emptor' (buyer beware) principle prevailed. However, to deal with today's business realities, mercantile laws were enacted to assist innocent purchasers and to obligate vendors to facilitate proper trade.

In the US the Uniform Commercial Code (UCC) offers protection related to warranties of title by the seller, that is, that the title being conveyed is a good title and that the seller has the right to transfer the title free of any security interest, lien, or encumbrance to an innocent purchaser for value.

In Canada, the various provincial Sale of Goods acts, Factors acts, and Personal Property Security (PPS) acts provide similar protection to innocent purchasers.





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