Section 2 applies only to contracts for the future disposition of an interest in land

In Rollerteam Ltd v Riley [2016] EWCA Civ 1291 the Court of Appeal held that s2 of the Law of Property (Miscellaneous Provisions) Act 1989 applies only to executory contracts for the future sale or other disposition of an interest in land and does not apply to a contract which itself effects such a disposition. In other words, there is a distinction to be drawn between a contract for the sale or other disposition of an interest in land, to which the 1989 Act applies, and documents which actually create or transfer legal estates or interests in land, to which the 1989 Act does not apply.