In Hardisty v. Kay, 268 Md. 202, 213, 299 A.2d 771 (1973), Hardisty, a tax sale purchaser, obtained judgment foreclosing the rights of redemption of the property owners ("Kay"). The judgment "vested in (him) an absolute and indefeasible title in fee simple in the property." Id. at 206. "Hardisty balked at paying the balance owed," and "when more than eight months passed without Hardisty paying the balance required, Kay filed a petition in the foreclosure case to compel payment." Hardisty responded to the petition, contending that he was not required to pay the balance because payment "was merely a condition precedent to the issuance of the deed by the collector and that he 'had no wish to acquire said property and did not intend to obtain a deed thereto . . . and had elected to forfeit the amount of $1,139.87 paid on account of the purchase price.'" Id. The circuit court entered judgment against Hardisty, requiring him to pay the balance of the bid. The Court of Appeals affirmed the judgment of the circuit court and announced three key holdings: (1) the entry of the judgment foreclosing the right to redemption "makes the judgment final in all respects and binding on the plaintiff as well as the defendant"; (2) the property owners were entitled to have the bidder compelled, "through the entry of a money judgment against the bidder, to make the payments obviously contemplated by the judgment that vested title to this property in the bidder"; (3) the money judgment does not create a double recovery for the property owners whereby the bidder would be required to pay both the property owners and the collector, because the collector "would have to recognize the payment of the judgment of record as satisfying the requirement of payment to the collector himself." Id. at 209-10, 212-13. The Court of Appeals based its holdings, in part, on the stated purpose of the tax sale statute, communicated by the General Assembly through Article 81, 97, which was "'to encourage the foreclosure of rights of redemption by suits in the equity courts and for the decreeing of marketable titles to property sold by the collector.'" Hardisty, 268 Md. at 208 (quoting Md. Code (1957, 1969 Repl. Vol., 1972 Supp.), Art. 81 97). The Court in Hardisty based its second holding--that the property owners were entitled to have the certificate holder compelled to pay the surplus bid--on the language of section 101 of Article 81, which conferred "'full equity jurisdiction to give full and complete relief under the provisions of this subtitle, in accordance with the general equity jurisdiction and practice of the said court.'" Hardisty, 268 Md. at 211.