Who is immediate purchaser ? Who is subsequent purchaser ? There have been cases such as Federal Court decision of Setiakon v Mak Yan Tai or the case of Kamarulzaman v Yakub Husin where the judges come up with the analysis that immediate purchaser must be bona fide before protection applies. It's a totally different judicial approaches compared to the analysis in the case of Tan Ying Hong or CIMB v Ambank. For more information on the courses I offered, please visit www.clpexam.com