Transfers by delivery only necessarily gave rise to many disputes. There being no written record of the transaction, false statements permitted gross frauds. Possession was forcibly taken and held. The "Statute of Frauds" was finally adopted. This prevented fraud by declaring that no transfer should be enforcible unless in writing. From this statute flows the present system of transferring title by means of written instruments; the deed, mortgage, lease, etc. The Statute of Frauds in substance has been enacted into the law of all the States.