 Although there have been rare cases where a transaction has been set aside even where the party exercising influence is seeking to act in the best interests of the person being influenced, and that all that is required is that the person's free will has been vitiated, the preponderance of authority notes that undue influence has a "connotation of impropriety" or requires "unconscionable conduct".In "Allcard v Skinner" (1877) LR 36 Ch D 145 Lindley LJ said