In Batchelder v. Planning Bd. of Yarmouth, 31 Mass. App. Ct. 104, 575 N.E.2d 366 (1970), the proponent of the subdivision plan had no record ownership in the property. His status was based on his claim of adverse possession that had not been adjudicated, but was alleged in a pending Land Court registration case. The Board approved the plan, even though the name of the record owner was not disclosed. The question was whether the applicant could obtain subdivision approval, given his lack of record title, and, if so, whether the board could waive its requirement that the owner sign the application. The Appeals Court held that the applicant did not have standing to obtain subdivision approval. In holding that the Board could not waive its requirement that the owner of record sign the application, the court stated: "If the owners of record are not fully identified or if the planning board has been misled as to record owners, the public would not be protected because the board would be unable to ensure that it would receive a properly executed covenant, or . . . a properly executed consent." Batchelder v. Planning Bd. of Yarmouth, 31 Mass. App. Ct. at 109 (1970).