UK: England and Wales: a proper instrument of transfer?

Judgment was given yesterday in Yusuf v Yusuf & Anor [2019] EWHC 90 (Ch) by Mrs Justice Falk. The trial judge found that a company's affairs had been conducted in an unfairly prejudicial manner for the purposes of section 994 of the Companies Act 2006. I note the decision here not because of the discussion of section 994 but because the trial judge considered the requirement, under section 770(1)(a) of the 2006 Act, for there to be a "proper instrument of transfer" where a share transfer is registered.  According to the trial judge, such an instrument was "a document that is capable of being stamped" and she held that the document at issue in the case before her - a letter - was only an instruction to transfer which contemplated the execution of a further document.  It was not, as such, a proper instrument of transfer.