A finding of fraud sufficient to displace the indefeasibility of a registered mortgage requires evidence establishing actual dishonesty — not merely knowledge of a prior unregistered interest or delay in registration. Circumstantial evidence of meetings, inquiries, and absence of file notes is insufficient to support an inference of participation in a fraudulent scheme where the inferred conduct would be inherently improbable and contrary to the alleged fraudster's own interests. The question whether a registered proprietor may lodge a caveat over their own land to protect a separate equitable interest remains open in Victoria.
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