 For example, in "Williams v Bayley" (1886) LR 1 HL 200, Bayley's son forged his father's signature on promissory notes and gave them to Williams.Williams threatened Bayley with criminal prosecution, so Bayley made an equitable mortgage to get back the notes.The court set aside the mortgage, and expressed itself as doing so for reasons of undue influence; today the case would almost certainly have been treated as duress.