What is the test for “actual notice” in real estate law?

At § 75 he wrote: The next question that comes to mind is actual notice of what? Is it actual knowledge of the deed to the other party or merely that another party has a claim? The law appears to be unsettled. In Marriott v. Feener, Ilsley, J., in an obiter dicta statement, raised the question but did not have to decide it in that case. However, he concluded by stating that it seems that the Courts of this province have consistently assumed that actual notice of the deed itself was necessary . . . . It would seem to me . . . it is necessary that the actual notice consist of knowledge of the legal claim and not merely facts that upon investigation could lead to such knowledge and that such knowledge would have the quality that an attempt to take in defeasance of that person’s right would amount to a fraud. (emphasis in original.)