"...the defendant is really 'charged' upon the
equities resulting from the acts done in execution
of the contract, and not (within the meaning of
the statute) upon the contract itself. If such
equities were excluded, injustice of a kind which
the statute cannot be thought to have had in
contemplation would follow. Let the case be
supposed of a parol contract to sell land,
completely performed on both sides, as to everything
except conveyance; the whole purchase-money
paid; the purchaser put into possession;
expenditure by him (say in costly buildings) upon
the property; leases granted by him to tenants.
The contract is not a nullity; there is nothing in
the statute to estop any court which may have to
exercise jurisdiction in the matter from inquiring
into and taking notice of the truth of the facts.
All the acts done must be referred to the actual
contract, which is the measure and test of their
legal and equitable character and consequences.
If, therefore, in such a case a conveyance were
refused, and an action of ejectment brought by the
vendor or his heir against the purchaser, nothing
could be done towards ascertaining and adjusting
the equitable rights and liabilities of the
parties, without taking the contract into account.
The matter has advanced beyond the stage of
contract; and the equities which arise out of the
stage which it has reached cannot be administered
unless the contract is regarded. The choice is
between undoing what has been done (which is not
always possible, or, if possible, just) and
completing what has been left undone. The line
may not always be capable of being so clearly
drawn as in the case which I have supposed; but it
is not arbitrary or unreasonable to hold that when
the statute says that no action is to be brought
to charge any person upon a contract concerning
land, it has in view the simple case in which he
is charged upon the contract only, and not that in
which there are equities resulting from res gestae
subsequent to and arising out of the contract. So
long as the connection of those res gestae with
the alleged contract does not depend upon mere
parol testimony, but is reasonably to be inferred
from the res gestae themselves, justice seems to
require some such limitation of the scope of the
statute, which might otherwise interpose an
obstacle even to the rectification of material
errors, however clearly proved, in an executed
conveyance, founded upon an unsigned agreement".