The Chippewas entered into a treaty with the Crown in the 1820s, surrendering a large part of their territory but retaining four reserves. Fifteen years later, part of one of these reserves was sold to a private speculator. The Ontario Court of Appeal decided that the sale was invalid, but declined to exercise its discretion to set aside a subsequent Crown grant of the land. The Court also applied the equitable bona fide purchaser for value without notice rule to uphold the titles of the current non-Indigenous landowners.