An order for foreclosure absolute will be reopened if, after foreclosure, the mortgagee sues the mortgagor on his covenant for payment1. It will be reopened also if the mortgagee sells under his power of sale and not as absolute owner, although the effect is only to make him liable to account for the surplus proceeds of sale, and the purchaser's title is not disturbed2. Further, like any other judgment, the order can be set aside if it has been obtained by fraud
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