39 So far as grounds 1 and 2 are concerned, as I have noted, it seems to have been conceded before the Master that a bare right of appeal was not itself property and was not assignable. That concession is not surprising in the light of the decision of the High Court in Cummings v Claremont Petroleum NL [1996] HCA 19; (1996) 185 CLR 124. That case is, in my view, authority for the proposition that a bare right of appeal is not "property" within the meaning of s 5 of the Bankruptcy Act 1966 (Cth). Although the reasoning of the majority in that case (Brennan CJ, Gaudron and McHugh JJ) is primarily concerned with refuting a variety of propositions advanced in support of the contention that such a right may be "property", the underlying conception of "property" is not discussed in detail. However, as I understand it, a right of litigation may be considered to be property if it can be characterised as a "chose in action", that being a species of property. Not all rights to take action are choses in action; that expression extends only to rights "of a proprietorial or quasi-proprietorial nature which are claimable or enforceable by action" (Starke, Assignments of Choses in Action in Australia, 1972, page 2; Halsbury's Laws of England, vol 6, 4th ed, par 1). A right to sue may be incapable of assignment because it is not a chose in action (ie, not "property" capable of assignment) or for other reasons, including the prohibition on maintenance (eg, Starke, pages 62 - 66). As will appear, these considerations are not always kept distinct in the cases.