In addition to, and as an alternative to, an allegation that a document falls to be construed otherwise than in accordance with its true terms, or the true relationship of the parties is other than the document itself suggests, founded on an allegation of contracting out or sham, there is a third case that draftsmen of documents relating to agricultural holdings should bear in mind when determining the nature and terms of the documents that they prepare: namely the question of mislabelling. Where a sham is alleged, it is necessary for the court to consider whether the documents
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