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. 

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