Helen can only request an abstract or copy of documents containing the prior encumbrances provided that it appears they affect the property and have survived beyond the root of title. Any other documents would be irrelevant and therefore the seller, Arthur, is under no duty to supply these when requested to do so by a buyer requesting details of those encumbrances. The principle is that the buyer should be able to ascertain any encumbrances that continue to affect the property beyond the established root of title. 

Key Point: In title investigation, a buyer can request documents showing prior encumbrances if they affect the property and survive beyond the root of title, but not otherwise.