The sale of commercially leased land by vendors retiring from business can constitute conduct 'in trade or commerce' under s 52 of the Trade Practices Act 1974 (Cth), notwithstanding that the vendors are not in the business of buying and selling land (majority view, Stanley J dissenting). There is no principle that the vendor of domestic or vacant land does not engage in trade or commerce unless in the business of doing so. The question of whether TPA relief can override Torrens title indefeasibility under the Real Property Act 1886 (SA) remains open.
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