In October 2008, a decision was delivered in the Land Court of Queensland regarding an appeal against an annual valuation of land pursuant to the Valuation of Land Act 1944 (Qld). Apart from the valuation issue, the case, Tardent v Department of Natural Resources, Mines and Water [2008] QLC 0186 raised some interesting matters pertaining to adverse possession and a pragmatic solution to a problem regarding access by encroachment of the adjacent land owner on land gazetted as a nature conservation reserve. Each state and territory adopted the Torrens system of land registration and within individual state legislation, a degree of uniformity of solution would be expected? How many states and territories? Perhaps not surprisingly if the scenario was applied in other states and territories there are a variety of most probable solutions to the problem depending upon individual state legislation. The solutions ranging from easement creation to adverse possession to revocation of nature conservation reserve emphasise the desire for property law reform within the states and territories. This aim of this paper is to examine state legislation to determine the likely most probable solution for the states and territories across Australia pertinent to the facts of the case. The conclusion will highlight the desire for standardised state legislation and operation of the Torrens system of land registration within Australia, particularly regarding the issue of adverse possession.