The Court held that a PPSA security interest over a grantor's 'present and after-acquired property' does not attach to mere expectancies, and where an expectancy has been equitably assigned for value before the expectancy materialises, the resulting property passes directly to the assignee without ever becoming property of the grantor — meaning the security interest never attaches under s 19(2) of the PPSA. The Court drew a distinction between 'after-acquired property' (a PPSA concept requiring actual acquisition of personal property) and 'future property' or 'expectancies' (equitable concepts), holding they are not equivalent. The Court declined to address the separate DOCA issue concerning whether s 444D(2) of the Corporations Act preserves a secured creditor's ability to enforce a security interest against after-acquired property following release of the underlying debt, leaving that question unresolved.
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