seen this before as well, it wasn't on the vcar it was finance
didn't happen to me personaly, was at my old work, we used to do sales there,
guy came in wanting to sell his rover 200(was a few years ago when these were worth something), salesman made him an offer, guy accepted, so sales did an hpi check, came back clear, gave the guy cash, guy promptly fooked off, couple weeks later car gets sold, when trying to arrange finance foe new owner it came back as having outstanding finance
turned out that the guy had only just bought it and it wasn't showing as being financed yet, we tried legal action against the hpi company but got nowhere, they said it was clear when it was checked
the work ended up a few grand out of pocket after having to clear the finance aswell so they could sell it, so its true the hpi checks aren't 100% garantee'd to be right