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" The title of a person who negotiates an instrument is defective within the meaning of this act when he obtained the instrument, or any signature thereto, by fraud, duress or force and fear or other unlawful means, or for an illegal consideration or when... "
The New York Supplement - Page 496
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Principles of Law Relating to International Trade

Nicholas Kouladis - 2006 - 301 pages
...negotiates the bill has obtained the bill, by fraud, duress, or force and fear, or other unlawful means, or an illegal consideration, or when he negotiates it...or under such circumstances as amount to a fraud. 'A holder in due course is a holder': This implies that no-one can be holder in due course after forgery...
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