Does a Power of Attorney have a beneficial interest in a bill of sale?

A bill of sale confers property upon the grantee for his use and benefit. A power of attorney confers powers to deal with property for the use and benefit of others, not the grantee. The attorney is therefore not a party to the property transactions which he conducts for the grantor with the other persons who become parties to those transactions; the attorney is only an agent or facilitator of those transactions for the grantor. The attorney remains, however, a person named in the instrument by which he is appointed and in that sense is interested in the same way as a party to the transaction which it embodies. He very clearly has a substantial interest under the terms of that instrument in that transaction, even though he can have no beneficial interest in the dealings which he is thereby authorized to transact for the grantor. And this is clearly so where the attorney, as here, was present and witnessed the execution of the deed appointing him, thereafter accepting delivery of it from the grantor and acting upon it. The fact that the attorney is a solicitor makes no more difference in the present case than it did in Seal v. Claridge.