The Court of Appeals, in 5303 Realty Corp. v. O & Y Equity Corp. (64 NY2d 313, 315, 476 N.E.2d 276, 486 N.Y.S.2d 877 [1984]), commented that "a notice of pendency, commonly known as a lis pendens,' can be a potent shield to litigants claiming an interest in real property." The Court, at 318-320, outlined the history of the doctrine of lis pendens back to 17th century England. It was formally recognized in New York courts in 1815 and first codified in the Code of Procedure Field Code enacted in 1848. At 319, the Court stated that "the purpose of the doctrine was to assure that a court retained its ability to effect justice by preserving its power over the property, regardless of whether a purchaser had any notice of the pending suit," and, at 320, "the statutory scheme permits a party to effectively retard the alienability of real property without any prior judicial review."