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Generally, in consonance with equity’s treatment of a mortgage as essentially a security for the payment of the debt, foreclosure by judicial sale supplanted strict foreclosure as the more equitable mode of effectuating the mutual rights of the mortgagor and mortgagee; and there is at the present time, in the majority of the American states, no strict foreclosure as developed by the English courts – either at law or in equity – by which a mortgagee can be adjudgd absolute owner of the.
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