30. Ames, Cases on Trusts (2nd Ed.) 286; Willoughby v. Willoughby, 1 Term Rep. 763; Kinicott v. Board of Sup'rs of Wayne County, 16 Wall. (U. S.) 452, 21 L. Ed. 319; Stokes v. Riley, 121 111. 166, 11 N. E. 877. Compare, Seacoast R. Co. v. Wood, 65 N. J. Eq. 530, 56 Atl. 337, criticized 17 Harv. Law Rev.

426

31. See 2 White & Tudor. Leading Cases in Eq. (8th Ed.) at p. 151.

32. Preston v. Nash, 76 Va. 1. In Buck v. Winn, 11 B, Mon.

(Ky.) 323, it was held that a purchaser at sheriff's sale, before procuring a deed, had such an "inchoate legal title" that he was entitled to protection as a bona fide purchaser.

33. Dodds v. Hills. 2 H. & M. 297. See Brewster v. Sime, 42

It has been decided, in one state, that as between equal equities, if the holder of the later equity was a bona fide purchaser for value and has actually acquired possession as such and made improvements, he will be protected as against the prior equity.34 Such a doctrine does not appear to he generally recognized.35