Estoppel – Issue estoppel. A Recorder had erred in finding an issue estoppel in a dispute concerning ownership of a property, where a transfer of the respondent's share in the house had allegedly been forged. The Chancery Division allowed the appellant's appeal against the Recorder's finding and held that it had been found as a fact by the adjudicator that the parties were tenants in common with equal shares, and that the transfer was a forgery.