Rowland v Divall [1923] 2 KB 500 FACTS: The buyer of a car discovered that it had been stolen before it had come into the possession of the seller (a car dealer). As a result, the vehicle was returned to the original owner. The buyer sued the car dealer, seeking to recover the full price he had paid for the car, irrespective of the fact that he had used the car for four months. HELD by the Court of Appeal: There was a breach of the implied condition arising under s 12 of the SGA 1979. The car dealer had no title and the buyer, who had paid to become the full owner of the car, had, therefore, received nothing from him. There was a complete failure of consideration and the full purchase price was recoverable.