A debenture holder has no better title than the company to goods in the company's possession that are owned by somebody other than the company itself. Consequently, the owner of goods that are hired to the company may recover them if they have been seized by the debenture holder or a receiver acting on the latter's behalf.1 The same principle will apply to a 'title retention' clause in a sale of goods contract. Such clauses are known as Romalpa clauses from the leading case2 in which their validity was upheld. They provide that the goods purchased shall remain the property of the seller until the purchase price is paid (as well, sometimes, as money outstanding in other contracts between the buyer and seller). In consequence the unpaid purchaser will be able to recover goods still in the company's possession3 against the claims of a floating charge holder. Retention of title is a rock against which many claims by debenture holders