How have courts dealt with the issue of a fraudulent charge or mortgage in favor of a creditor?

The difficulty to be surmounted here is infinitely less (the property consisting merely of personal chattels) than it was in some of the cases I have referred to. I see no practical difference between a case like this, where the debtor has first created a fraudulent charge or mortgage in favor of a creditor by one instrument and has then by another conveyed his equity of redemption subject to such charge, and a case where, as in French v. French, he has by a single instrument conveyed ail his property, charging it with an annuity in favor of his wife or other person, except that the difficulty of dealing with the debtor’s interest, with due regard to that of the purchaser, may be greater in the latter case when he happens to be something more than a mere voluntary assignee.