Tai Hing Cotton Mill Ltd v. Liu Chong Hing Bank Ltd and Others

Read the full judgment text of CACV 103/1983 on BabelCite. This Court of Appeal judgment.

1. This appeal raises issues of considerable importance to the banking world, in particular, how far does a customer who maintains a current account with a bank owe a duty of care to the bank with regard to the operation of the account. Is that duty limited to particular circumstances which are now well established, i.e. not to draw a cheque in such a manner as may facilitate fraud by a third party : London Joint Stock Bank v. MacMillan [1] ; and to inform the bank immediately of any forgery of

Cited by 12 cases

Case No.CACV 103/1983[1987] HKLR 1041[1988] AC 80[1986] 1 AC 80[1982] HKLR 387[1984] AC 80
Court
Court of Appeal
Date
Judge
Case Document
100%Judiciary

Headnote

A person who maintains a current account with a bank is required, in the operation of that account, to take reasonable care to protect the interests of the bank on, "to ensure the proper working of the account".

On the facts of the case banks had a good defence to an action by a customer for a declaration that they were not entitled to debit his accounts with cheques forged by his own staff.

Dates of hearing: 12th - 16th & 19th - 22nd December, 1983

Date of handing down of judgment: 27th January, 1984

IN THE COURT OF APPEAL

Civil Appeal
No. 103 of 1983

BETWEEN

TAI HING COTTON MILL LIMITED Plaintiff
and
LIU CHONG HING BANK LIMITED 1st Defendant
THE BANK OF TOKYO LIMITED 2nd Defendant
CHEKIANG FIRST BANK LIMITED 3rd Defendant
LEUNG WING LING 4th Defendant
WANCE CHENG 5th Defendant

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Coram: Hon. Cons, Fuad, JJ.A. & Hon. Hunter, J.

Date of Judgment: 27th January, 1984

__________

JUDGMENT

__________

Hon. Cons, J.A.:

1. This appeal raises issues of considerable importance to the banking world, in particular, how far does a customer who maintains a current account with a bank owe a duty of care to the bank with regard to the operation of the account. Is that duty limited to particular circumstances which are now well established, i.e. not to draw a cheque in such a manner as may facilitate fraud by a third party : London Joint Stock Bank v. MacMillan[1]; and to inform the bank immediately of any forgery of which he becomes aware : Greenwood v. Martins Bank Ltd.?[2] Or is it the more general duty for which the banks now, contend "to take such precautions as a reasonable customer in his position would take to prevent forged cheques being presented to his bank for payment" (the "Wider ditty")? Or if not that, is it at least "to take such steps to check his monthly bank statements as a reasonable customer in his position would take to enable him to notify the bank of any items debited therefrom which were not or may not have been authorized by him" (the "narrower duty").

2. The learned judge below - in a judgment which, if I may say so, dealt clearly and concisely with all the submissions put forward - rejected both duties. He found nothing to support them in principle and felt that the weight of authority was against them. However he concluded that if in fact, or rather in law, there were such duties, then on the particular facts of the case the plaintiff was in breach of both duties in relation to all three defendant banks. That conclusion has not been challenged.

3. The plaintiff is a modern, medium sized and reasonably successful textile company which has been in business in Hong Kong since 1957. In September of that year the plaintiff opened an account with the third defendant, The Chekiang First Bank Ltd. Cheques were authorized to be signed by a Mr. Chen, the Managing Director, or by any two of four nominated signatories. In November 1961 another account was opened, this time with the second defendant, The Bank of Tokyo Ltd., having similar arrangements for the drawing of cheques. One year later, i.e. in November 1962, a third account was opened with the first defendant, The Liu Chong Hing Bank, again with similar provisions for the signing of Cheques. We are told that these accounts were net the main bank accounts of the company, these being held in yet other banks not party to these proceedings, nor for the most part subject to the malpractices from which these proceedings have arisen.

4. The plaintiff's banking arrangements operated smoothly until 1972. In that year the company took into employment the fourth defendant, a young accounts clerk by the name of Leung. He was given responsibility for the books of two divisions of the company, divisions whose accounts were kept to the greater extent with the first and second of the banks I have just mentioned. Mr. Leung was quite dishonest, and within a few months of his engagement was using his position for his own benefit. He would either obtain cheques from Mr. Chen by way of forged documents or would get Mr. Chen to sign cheques on which the words "or bearer" had not been deleted. These he would pay into accounts which he had opened for himself in names similar to those of genuine suppliers to the company. Later on, in November 1977, when his superior, a Mr. Wang, retired on account of ill health and he was given similar responsibility with regard to the Liu Chong Hing Bank, Mr. Leung extended his depredations into that account. By this time he had abandoned his earlier methods in favour of the more simple forgery of Mr. Chen's signature.  So he carried on until May of 1978, when his dishonesty was exposed by the new chief accountant who, very properly, carried out routine checks which had been ignored by his predecessor.

5. All told Mr. Leung made away with some $7,000,000 by fraud and forgery together. We understand that a small amount has been recovered through a compromise reached with his wife regarding certain properties which had been purchased with the monies taken. This has been applied to the claim against them in fraud. We are concerned here only with the forged cheques. They amount to roughly $5,500,000. The question is whether the three banks were entitled to debit those cheques, as they innocently did, to the plaintiff's current accounts.

6.I turn then to the submissions of law advanced in support of the "wider" and "narrower" duties set out at the beginning of this judgment. They may be conveniently considered under the headings of "Implied Contract" and "Tort". I will come later to the effect of express terms which had been agreed between the plaintiff and the banks.

Implied Contract

7. It is not uncommon for a court to imply into a contract terms which have not been expressly included by the parties. The two most common instances were set out by Lord Wilberforce in Liverpool City Council v. Irwin and Another[3] : -

"Where there is, on the face of it, a complete, bilateral contract, the courts are sometimes willing to add terms to it, as implied terms : this is very common in mercantile contracts where there is an established usage : in that case the courts are spelling out what both parties know and would, if asked, unhesitatingly agree to be part of the bargain. In other cases, where there is an apparently complete bargain, the courts are willing to add a term on the ground that without it the contract will not work - this is the case, if not of The Moorcock (1889) 14 P.D. 64 itself on its facts, at least of the doctrine of The Moorcock as usually applied. This is, as was pointed out by the majority in the Court of Appeal, a strict test - though the degree of strictness seems to vary with the current legal trend -"

Lord Cross, in the same case, at page 258 adopted what is usually called the "officious by-stander test" : -

"Here it is not enough for the court to say that the suggested term is a reasonable one the presence of which would make the contract a better or fairer one; it must be able to say that the insertion of the term is necessary to give - as it is put - "business efficacy" to the contract and that if its absence had been pointed out at the time both parties - assuming them to have been reasonable men - would have agreed without hesitation to its insertion. "

8. Although the substantial submission of Mr. Morrit for the Liu Chong Hing Bank, whose arguments were adopted by counsel for the other two, is that the two duties are derived from a principle of law independent of those just set out, he does nevertheless submit that a properly informed by stander would give an unhesitating answer in his favour for both. By "properly informed" he means that the by-stander would be appraised of the accepted implications of MacMillan and Greenwood, together, in this instance, with the express obligation of the banks to render monthly statements, which by reason of Lloyds Bank Ltd. v. Brook[4] have to be prepared with reasonable care as to their accuracy.

9. For myself I do not, see it that way. It is the presumed intention of the parties that is material and I do not think that the average customer would testily suppress the officious by-stander who proposed either or both terms. I think he would at least say "I shall have to think about that".

10. The case of Liverpool City council v. Irwin(3) itself was one of landlord and tenant. The council had, in 1966, erected several tower blocks, 15 storeys high, each containing some 70 dwelling units.  Access to these was provided by a staircase and two electrically operated lifts. Another facility provided was an internal chute into which tenants in the block could discharge rubbish or garbage for collection at ground level. There had unfortunately been a consistent history of trouble in one of the blocks, due in part to vandalism, in part to non-cooperation by tenants and in part, it was said, to neglect by the corporation. Eventually some of the tenants refused to pay their rent, pleading inter alia by way of defence to proceedings brought by the corporation that the corporation was in breach of an obligation implied by law to keep the "common parts" in repair.

11. There was no express obligation of this kind imposed upon the council. Such documents as there were imposed obligations only upon the tenants. Nevertheless their Lordships held that there was an implied obligation on the part of the council, an obligation that arose, independently of any presumed intention, as a legal incident of the particular relationship. It was not an absolute obligation, but was to take reasonable care to keep the lifts, staircase and chutes in reasonable repair and usability. The test was not one of business efficacy. All their Lordships directly or indirectly rejected the submission counsel had based upon The Moorcock. The test instead was what was required in the particular circumstances. Lord Wilberforce, with whom Lord Fraser agreed, put it this way (at page 254):-

"In my opinion such obligation should be read into the contract as the nature of the contract itself implicitly requires, no more, no less : a test, in other words, of necessity. The relationship accepted by the corporation is that of Landlord and tenant : the tenant accepts obligations accordingly, in relation inter alia to the stairs, the lifts and the chutes. All these are not just facilities, or conveniences provided at discretion : they are essentials of the tenancy without which life in the dwellings, as a tenant, is not possible. To leave the landlord free of contractual obligation as regards these matters, and subject only to administrative or political pressure, is, in my opinion, inconsistent totally with the nature of this relationship. The subject matter of the lease (high rise blocks) and the relationship created by the tenancy demand, of their nature, some contractual obligation on the landlord. "

Lord Cross spoke more generally (at page 257) :-

"When it implies a term in a contract the court is sometimes laying down a general rule that in all contracts of a certain type - sale of goods, master and servant, landlord and tenant and so on - some provision is to be implied unless the parties have expressly excluded it. "

Lord Salmon commented (at page 261) that :-

"... all the surrounding circumstances must be taken into account.

Amongest the most important surrounding circumstances are the following. This was a block 15 storeys high which was built to be let to parents with young children. The lifts and staircases were obviously provided by the council as being necessary amenities for their tenants which they impliedly gave the tenants and their families and visitors a licence to use. "

and then, after referring to remarks of Bowen L.J. in Miller v. Hancock[5],

"... it would render the whole transaction inefficacious and absurd if an implied undertaking were not assumed on the part of the (council) ..."

Finally he concluded (at page 263) :-

"I find it difficult to think of any term which it could be more necessary to imply than one without which the whole transaction would become futile, inefficacious and absurd as it would do if in a 15 storey block of flats or maisonettes, such as the present, the landlords were under no legal duty to take reasonable care to keep the lifts in working order and the staircases lit. "

Lord Edmund-Davies, who also relied upon Miller v. Hancock(5), quoted what he called a "new approach" from the speech of Viscount Simonds in Lister v. Romford Ice and Cold Storage Co. Ltd.[6]: - (at page 267)

"For the real question becomes, not what terms can be implied in a contract between two individuals who are assumed to be making a bargain in regard to a particular transaction or course of business; we have to take a wider view, for we are concerned with a general question, which, if not correctly described as a question of status, yet can only be answered by considering the relation in which the drivers of motor vehicles and their employers generally stand to each other. Just as the duty of care, rightly regarded as a contractual obligation, is imposed on the servant, or the duty not to disclose confidential information (see Robb v. Green (1895) 2 Q.B. 315), or the duty not to betray secret processes (see Amber Size and Chemical Co. Ltd. v. Menzel (1913) 2 Ch. 239), just as the duty is imposed on the master not to require his servant to do any illegal act, just so the question must be asked and answered whether in the world in which we live today it is a necessary condition of the relation of master and man that the master should, to use a broad colloquialism, look after the whole matter of insurance. "

12. It is this "new approach" which is the foundation of Mr. Morritt's submission. It applies, he suggests, not merely to master and servant of landlord and tenant, but to all contracts which establish such a relationship as by its very nature and subject matter demands particular obligations. Banker and customer is one of those relationships and indeed, although not expressly acknowledged as such, the approach has, he says, been already adopted in several banking cases in the past.

One of these cases is the London Joint Stock Bank v. Macmillan(l) which confirmed that there was a special duty imposed on the customer to exercise reasonable care in the drawing of his cheques to prevent the banks being misled, or not to draw them in such a manner as would facilitate fraud. This was no question of business efficacy or presumed intention of the parties. Lord Finlay L.C. relied upon Young v. Grote[7], a decision of the Court of Common Pleas in 1827, the authority of which had at times been doubted but which had, in his view, correctly applied an established principle of law. Viscount Haldane (at page 814) regarded the duty as an obligation directly reciprocal to that of the bank to honour its customers' cheques : -

"The banker contracts to act as his mandatory and is bound to honour his cheques without any delay to the extent of the balance standing to his credit. The customer contracts reciprocally that in drawing his cheques on the banker he will draw them in such a form as will enable the banker to fulfil his obligation, and therefore in a form that is clear and free from ambiguity. The correlative obligation is thus complementary to the obligation of the mandatory to apply the balance in paying without delay the cheques as and when presented to him. "

Lord Shaw spoke to similar effect at page 824.

13. In Joachimson v. Swiss Bank Corporation[8], which decided that monies standing to the credit of a customer with his bank are payable to him only on demand, Warrington L.J. appears to have had the same idea in mind when he said at page 125:-

"... it is well settled that a banker is not at liberty to close an account in credit by payment of the credit balance without giveing reasonable notice, and making provision for outstanding cheques. This restriction on a banker's liberty to discharge his debt, seems to me inconsistent with an obligation on his part to pay without demand. "

However, the other two lord justices relied upon the more traditional approach (page 121 & 129).

14. Greenwood v. Martins Bank Ltd. (2) was a case where a wife forged her husband's signature on cheques drawn against a joint account and subsequently against an account opened in his name alone. The husband became aware of the forgeries but did not notify the bank for well over six months. When he did, or was about to do so, his wife committed suicide. His subsequent claim against the bank was rejected on the ground of estoppel :- (at page 58)

"The appellant's silence, therefore, was deliberate and intended to produce the effect which it in fact produced - namely, the leaving of the respondents in ignorance of the true facts so that no action might be taken by them against the appellant's wife. The deliberate abstention from speaking in those circumstances seems to me to amount to a representation to the respondents that the forged cheques were in fact in order, and assuming that detriment to the respondents followed there were, it seems to me, present all the elements essential to estoppel. "

..........

The course of conduct relied upon as founding the estoppel was adopted in order to leave the respondents in the condition of ignorance in which the appellant knew they were. It was the duty of the appellant to remove that condition however caused. It is the existence of this duty, coupled with the appellant's deliberate intention to maintain the respondents in their condition of ignorance, that gives its significance to the appellant’s silence. "

Scrutton L.J. in the Court of Appeal, had put it this way[9] :-

"It seems to me that the banker, if a cheque was presented to him which he rejected as forged, would be under a duty to report this to the customer to enable him to inquire into and protect himself against the circumstances of the forgery. This, I think, would involve a corresponding duty on the customer, if he became aware that forged cheques were being presented to his banker, to inform his banker in order that the banker might avoid loss in the future. If this is correct there was in the present case silence, a breach of a duty to disclose, which may give rise to an estoppel. "

15. It is upon the mutuality of the obligations that Mr. Morritt places particular emphasis. As I understand his arguments, one of them is that the wider duty for which he now contends is the direct reciprocal of the duties imposed upon banks by the next two authorities.

16. In Selangor United Rubber Estates Ltd. v. Cradock[10], the directors of a company abused their position as signatories of the company's bank account. Their dealings with the company's monies ought to have put the bank on enquiry. It was submitted however on behalf of the bank, that even so the bank's duty extended no further than to see that the signatories on the particular cheques concerned were those of the authorized signatories. Ungoed-Thomas J. rejected that submission (at page 1608)

"If this were so then it seems to follow that, even if the bank actually knew that the authorised signatories were misapplying the company's funds, it could nevertheless rely on the signatures. This could be so outrageous as to lie outside the intention and true construction of the mandate. "

.............

"As between the company and the bank, the mandate, in my view, operates within the normal contractual relationships of customer and banker and does not exclude them. These relationships include the normal obligation of using reasonable skill and care. And that duty, on the part of the bank, of using reasonable skill and care, is a duty owed to the other party to the contract, the customer, who in this case is the plaintiff, and not to the authorised signatories. And it extends over the whole range of banking business within that contract. So the duty of skill and care applies to interpreting, ascertaining, and acting in accordance with the instructions of a customer; and that must mean his really intended instructions as contrasted with the instructions to act on signatures misused to defeat the customer's real intentions. Of course, omnia praesumuntur rite esse acta, and a bank should normally act in accordance with the mandate – but not if reasonable skill and care indicate a different course. "

17. That standard of care was adopted by Brightman J., as he then was, in Karak Rubber Co. Ltd. v. Burden[11], a case where authority to sign had been similarly misused and a similar argument had been put forward on behalf of the bank.  He disposed of it in this way : (at page 628)

"In my view the Achilles heel of the bank's argument, both in the Selangor case (1968) 1 W.L.R. 1555, and in the case before me, is that it is not, and never reasonably could be, asserted that a paying bank with certain knowledge that the authorised signatories are misapplying the company's funds may nonetneless rely on their signatures. If that is axiomatic, and it was conceded so to be in the case before me, it seems utterly irrational to suppose that a bank has an absolute unqualified duty to pay and no duty to inquire despite a deep suspicion, approaching but falling short of a certainty, that the funds are being misapplied. Once a bank disclaims the untenable position of being in all cases an automatic cash dispenser, whatever the circumstances, there is no rational stopping place short of a contractual duty to exercise such care and skill as would be exercised by a reasonable banker in similar circumstances. "

18. The direct reciprocal of the duties imposed upon the banks by these two cases would appear to be a contractual duty upon the customer to exercise such care and skill as would be exercised by a reasonable customer in similar circumstances. I do not think it can go that far, for skill is expected only from those who possess it inherently or by training and profess to exercise it. A "customer" does not fall within that category. But I see no reason why he should be absolved from taking care. If a banker, as well as being skillful, is required to be reasonably careful of the interests of its customer, why should not the customer be equally careful of the interests of the bank?

19. It cannot be said that the imposition of a duty of care on the customer is absolutely essential to the relationship. The banks could I think manage to service current accounts without that assistance. So could, I think, the tenant of the high rise flats have managed to live there without the benefit of lifts, lights on the staircase or garbage chutes. But that did not deter Their Lordships. They took a more practical view of necessity. They inquired if the transaction would become "futile, inefficacious or absurd" if these amenities were not maintained. For my part I can think of little more futile than for the operator of an active bank account to throw his monthly statements in the waste paper basket without ever bothering to looking at them; little more inefficacious than to leave the operation of that account to a clerk whose work is never checked; and little more absurd than to expect the bank to insure the honesty of the customer's clerk when the customer deliberately puts into the clerk's hands the weapons with which he can plunder and rob the bank.  It cannot be economically feasible nowadays for a bank to subject the signature on each and every cheque presented to a thorough examination or comparison with the specimen signature card. Banks must look to other protection. Thus, after a great deal of hesitation, I find myself finally led to the conclusion that, in the world in which we live today, it is a necessary condition of the relation of banker and customer that the customer should take reasonable care to see that in the operation of the account the bank is not injured.

20. I do not think this conclusion necessarily conflicts with the recent decision of MacNeil J. in Wealdon Woodlands (Kent) Ltd. v. National Westminster Bank (unreported March 1983) where the exercise of reasonable care by the directors would not in any event have revealed the defalcations of their colleague. There is no mention in the judgment of either Selangor or Karak and the argument put to us does not seem to have been advanced before the learned judge there. The same may be said of the New Zealand case of National Bank of New Zealand v. Walpole & Patterson[12]. Nor was any argument on these lines put in the earlier case of Kepitigalla Rubber Estates Ltd. v. National Bank of India Ltd.[13] on which NacNeil J. heavily relies.  There too, like in Wealdon Woodlands, there was nothing to alert the directors to the dishonesty of their secretary and the learned judge expressly found that they had not been negligent.

Tort

21. I turn then to a consideration of the position in tort, but I must first deal with a submission that is relevant if the contractual duty that I have assumed is too wide.

22. Mr. Yorke, who appears for the plaintiff, argues that where proximity arises between two parties by reason of contract, as it does in this case, then as matter of law the only possible duty of care that can arise is such duty as is expressed or implied in the contract itself. He concedes that there may be an independent tortious duty concurrent and coterminous with the contractual duty, but he contends that the tortious duty cannot be in any circumstance more extensive.

23. It seems to me that there may be good sense in that argument so far as it concerns acts or omissions in the actual performance of the contract itself, for it would be strange that two branches of law, so closely allied in this circumstance, should lead to different results. But I am unable to grasp any reason why there should in principle be any restriction upon liability for conduct which, although it would or may not have occurred without the existence of the contract, is otherwise independent of it. Such liability may, of course, be limited or excluded by the contract, but that is a different matter.

24. The question then is, what is the duty in tort? The answer to that depends primarily on the questions put by Lord Wilberforce in Anns v. Merton London Borough Council[14]:-

"Through the trilogy of cases in this House - Donoghue v. Stevenson [1932] A.C. 562, Hedley Byrne & Co. Ltd. v. Heller & Partners Ltd. [1964] A. C. 465, and Dorset Yacht Co. Ltd. v. Home Office [1970] A.C. 1004, the position has now been reached that in order to establish that a duty of care arises in a particular situation, it is not necessary to bring the facts of that situation within those of previous situations in which a duty of care has been held to exist. Rather the question has to be approached in two stages. First one has to ask whether, as between the alleged wrongdoer and the person who has suffered damage there is a sufficient relationship of proximity or neighbourhood such that, in the reasonable contemplation of the former, carelessness on his part may be likely to cause damage to the latter - in which case a prima facie duty of care arises. Secondly, if the first question is answered affirmatively, it is necessary to consider whether there are any considerations which ought to negative, or to reduce or limit the scope of the duty or the class of person to whom it is owed or the damages to which a breach of it may give rise : see Dorset Yacht case [1970] A.C. 1004, per Lord Reid at p. 1027."

25. Mr. Morritt submits that the answer to the first question is an obvious "Yes", but with respect I do not think it can necessarily be answered that simply, because the carelessness with which we are concerned involves the actions of a third party. Altematively the answer is "Yes", but the actions of the third party fall to be decided under the second question. The considerations are the same.

26. The nature of the carelessness was neatly set out by the judge below:-

"The plaintiff's system of internal control had been devised by their first chief accountant, a Mr. So. Its operation has been shown on a chart. I do not think that it is necessary to analyse the system further than to say that an accounts clerk with responsibility for a particular division had almost total control of the receipts and payments side of the accounts including the handling of incoming cheques, the recording of receipts and, subject to being able to produce supporting vouchers, the making and recording of payments. Leung was always able to produce vouchers if needed by forging them. He forged them in advance if he was presenting a cheque to Mr. Chen for signature and at sometime before the annual audit in every other case. When the plaintiff's external auditor, Mr. Tam, had pointed out to him in cross-examination the lack of any proper division of function, he agreed that such a division was elementary to a proper system of internal control. "

...........

"Given the shortcomings of the system, it was essential that there should be a high degree of supervision. There was not. Indeed it appears that there was none. Cheque books were left in a unlocked steel cabinet. Cheque counterfoils were not completed as a matter of course. It was not necessary for cheques to be used sequentially or even to be taken from one cheque book at a time. In the case of Mr. Chen, a second signature was not necessary. But most important, I find, was the failure to check what Leung was doing and in particular, the failure to check or supervise his reconciliations of the monthly bank statements. Until he retired, Mr. Wang was supposed to do it. He was the chief accountant and office manager and was, no doubt, very busy, but Mr. Chen had given him the job of supervising the accounts clerks and one of the checks he ought to have made was of the monthly reconciliations. Perhaps, he did check from time to time but he cannot have done it properly becuase if he had, the frauds would have shown up immediately. Mr. Clutterbuck told me that a proper bank reconciliation is carried out line by line and a proper check of a bank reconciliation must be done in the same way. Mr. Clutterbuck, who is an experienced chartered accountant and was called by the plaintiff, also said that the system which the plaintiff employed was not reasonably sound and that it was inadequate for any company. From the point of view of preventing or detecting fraud, I agree. "

27. General speaking a person is not liable for the conduct of a third party. In Smith v. Leurs[15] Dixon J. said :-

"It is, however, exceptional to find in the law a duty to control another's actions to prevent harm to strangers. The general rule is that one man is under no duty of controlling another man to prevent his doing damage to a third. There are, however, special relations which are the source of a duty of this nature. "

28. As an example he instanced the duty of a parent to take reasonable care to control his young child so as to avoid exposing the person or property of others to unreasonable danger. Another example is to be found in the Dorset Yacht Co. itself[16], where the passage I have just quoted is expressly relied upon by three of their Lordships. Lord Diplock referred to the need also for a special relationship between the person in control and the person to whom the duty is owed, exposing the latter to a particular risk of damage.

29. In my view such a special relationship exists in the present situation. The plaintiff could have controlled Mr. Leung either directly or by the introduction of a suitable accounting system. Moreover the position of the bank was one of danger. It was peculiarly liable to suffer from the misbehaviour of Mr. Leung.

30. Was there then a high degree of foreseeability that in the circumstances Mr. Leung would resort to forgery? Mr. Yorke would say "No", becuase the law which applies to commercial dealings does not require merchants to be on their guard against dishonesty. He refers us to remarks of Bowen L.J. in Saunders Brothers v. Maclean[17] relied upon by McNair J. in Pringle of Scotland Ltd. v. Continental Express Ltd.[18]:-

"But the practice of merchants, it is never superfluous to remark, is not based on the supposition of possible frauds. The object of mercantile usages is to prevent the risk of insolvency, not of fraud; and anyone who attempts to follow and understand the law merchant will soon find himself lost if he begins by assuming that merchants conduct their business on the basis of attempting to insure themselves against fraudulent dealing. The contrary is the case. Credit, not distrust, is the basis of commercial dealings; mercantile genius consists principally in knowing whom to trust and with whom to deal, and commercial intercourse and communication is no more based on the supposition of fraud than it is on the supposition of forgery. "

31. However, Macmillan shows that in certain circumstances dishonesty must be expected. And for myself, I find it impossible to draw any meaningful distinction between the facts of that case and of the present. Mr. Klantschi was a confidential clerk who had been with the firm for some years, keeping the books and filling in the cheques for the partners to sign. They had no reason at all to distrust him, yet his forgery was held to be the "very natural consequence" of negligence which was "almost an invitation to forgery". Mr. Leung was an untried junior accountant. He was put immediately into the situation described in the passage from the judgment that I have set out earlier. Human nature being what it is, it seems to me that that was tantamount to an open invitation to dishonesty and fraud. It does not then take a high degree of foreseeability to realize that if that fraud and dishonesty were left unchecked for over 18 months, as in fact they were, forgery is very likely to be the next step taken.

32. Mr. Yorke suggests that the distinction between Macmillan and the present lies in the initial validity of the cheques. In the earlier case, there was from the very beginning a genuine mandate to the bank, only the amount of the mandate being fraudulently altered. In the present case there has been no valid mandate to the bank at any stage. The cheques were at all times nothing but nullities, a factor which carried weight with the judge in Asien-Pazifik Merchant Finance Ltd. v. The Shanghai Commercial Bank[19].

33. With the greatest of respect I do not see the importance of the distinction. If the forgery is reasonably skillful there is every likelihood that the bank will pay out money when the cheque is presented, and it is the fact of payment, not the intrinsic invalidity of the cheque, which causes the loss. And it is the probability that payment will thus be made which imposes the liability on the account holder.

34. There are many references in Macmillan and in other authorities to "negligence in the immediate transaction" or similar phrases. It is suggested that these indicate that the duty is confined to the actual drawing of cheques and it cannot, therefore, extend to other facets of the banker/customer relationship. The counter-suggestion is that this construction imposes too restricted a meaning upon the words "immediate transaction" and relies upon the words of Scrutton L.J. in Greenwood : - (at page 380)

"But the relation does not merely refer to one cheque; it is a continuing relation in which the customer may draw cheques from time to time, and the banker is under a continuing duty to honour mandates. This, in my view, involves a continuing duty on either side to act with reasonable care to ensure the proper working of the account. "

35. I find some attraction to the latter view. I do not think it a distortion of language to call a current account an "immediate transaction". But more importantly I think that three matters have to be borne in mind when reading the words of their Lordships. Firstly, that at the time they were spoken a defendant was liable for all natural or direct consequences of his negligence whether these were reasonably foreseeable or not. There was naturally then a greater emphasis on causation than there is today. Secondly, that their Lordships were concerned only with one particular act of carelessness which did lead, in fact, to the alteration of a cheque already drawn. There was nothing before them by way of what might perhaps be called "systematic negligence". Thirdly, I do not think that the practice 75 years ago of handing in pass books for the purpose of being written up can bear any relation to the modern practice of issuing regular statements.

36. Reading them in the light of all these factors, I do not take the various dicta of their Lordships to be intended to do more than indicate that they were not sanctioning an open-ended liability upon the customer; he could not be expected to be looking over the shoulders of his staff all the time that he was conducting his business. But this does not mean he can throw all precautions to the winds and expect the bank to make good the inevitable damage. As Lord Finlay put it, at page 811, "if the customer chooses to dispense with ordinary precautions because he has complete faith in his clerk's honesty, he cannot claim to throw upon the bank the loss which results". He was of course only speaking of the drawing of the cheque. But in my view those words are apposite to circumstances like the present.

37. For these reasons I have come to the conclusion that there is no qualification upon the affirmative answer to Lord Wilberforce's first question, nor any consideration which ought to negative, or to reduce or limit the scope of the duty which that affirmative answer evidences.

38. I have approached this question from the practical view of contract and then tort because it was argued in that manner and because I have found it a convenient way to attempt to distinguish the underlying principles. It may well be that from a juristic point of view there is a great deal of overlapping or indeed no difference at all. Be that as it may, it seems to me that whether the account is that of an individual concerned only with his own personal affaris, or that of a large and busy commercial undertaking, the customer is required, in the operation of that account, to take reasonable care to protect the interests of the bank. What is reasonable will depend upon the particular circumstances of each case. It is a question that may not perhaps need a frequent answer. But there can be no doubt, both from the judge's unchallenged finding, and from the evidence to which we were referred, that it was a standard which the plaintiff failed to meet in the present instance.

Other Jurisdictions

39. The conclusion I have reached on this difficult matter reflects the gradual development of what I take to be established principles of English law. Courts on the other side of the Atlantic seem to have advanced more quickly. Mr. Morritt's "narrower duty" was established in the United States of America as long ago as 1885 : Leather Manufacturers National Bank v. Morgan[20]. It has been applied many cases to which ore have been referred. In Arrow Transfer Co. Ltd. v. Royal Bank of Canada,[21] Laskin J. was in favour of importing the principle into Canadian law. Montgomery J. adopted the suggestion in Canadian Pacific Hotels Ltd. v. The Bank of Montreal[22] :

"I cannot see that a large sophisticated bank customer who receives daily statements of account from its bank, whose daily bank transactions amount to many thousands of dollars, can be absolved of responsibility for checking the accuracy of thos statements in respect of cheques bearing forged signatures. If the bank is to beheld liable to its customer for honouring cheques bearing forged signatures surely it must be considered a part of commercial custom that the customer take steps to identify forgeries and prevent their recurrence as part of normal business practice. The Price Waterhouse report indicated unequivocally that had CP Hotels followed proper accounting practices and procedures, Sigulim would not have been able to succeed in his scheme. Such practices and procedures necessarily include proper bank reconciliations. "

40. Also included in his view were "proper internal controls", indicating support for Mr. Morritt's wider duty. A factor that seems to have carried great weight with the learned judge is that the customer was a large and "sophisticated commercial customer". With every respect, it seems to me that the existence or otherwise of a general duty of this kind ought not to depend upon the nature or size of the customer's bunsiness.

41. Morgan v. The U.S. Mortgage & Trust Co.[23] is said to have taken the law that far much earlier and a passage at page 224 has been drawn to our attention :-

"Negligence in this case means the neglect to do those things dictated by ordinary business customs and prudence and fair dealing toward the bank which, if done, would have prevented the wrongdoing which resulted from their omission. "

42. I have some doubts whether this gives the support for the wider duty that is suggested, for Hiscock J. seems to have been speaking in the context of "examination and verification of their account with the bank when the pass book and vouchers were returned".

43. Screenland Magazine Ltd. v. The National City Bank of Near York[24] gives perhaps more assistance, for the learned judge there does mention the failure of the customer to complete the cheque counterfoils in addition to his failure to check the statements or returned cheques. Yet the following passage (at page 290), seems to indicate that the underlying concept was that the customer should have "cured” the malpractice rather than have "prevented" it (the emphasis is my own):

"The law applies the rule of reason in dealing with a situation such as is here presented. The bank starts with the burden of strict liability. In the first instance it is virtually the insurer of the validity of its depositor's signature. That strict liability is modified when it appears that the depositor himself has been guilty of a breach of duty owed to the bank, when because of the carelessness or fault of the depositor a long continued repetition of the forgeries is made possible. "

44. We are told that the question in America is now, at least in most jurisdictions, regulated by legislation. But that apart, it seems to me that none of the authorities to which we have been referred conflicts significantly with what I have ventured to suggest is the result of established principles of English law. There is therefore no need, as I see it, to make a choice. Even had it been otherwise, I would respectfully have declined the invitation so charmingly extended by Mr. Morritt. This court should apply what we take to be the common law of England unless "the circumstances of the Colony or its inhabitants make it inappropriate". As to maintaining current accounts with a bank, it seems to me that the circumstances and inhabitants of Hong Kong are identical with those of England.

The Express Conditions

45. Contrary to what we understand to be the custom in England and of some of the major banks in Hong Kong, the three banks with which we are concerned impose express conditions upon the operation of current accounts. The assent of the customer is obtained in each case by means of the formal letter of request to open the account. The plaintiff made that request to the 1st defendant "subject to your Rules and Regulations for the conduct of such accounts. The letter to the 2nd defendant includes "We hereby agree to observe the Provisions of the Agreement on the back hereof ........ and undertake to hold your Bank free from any loss whatsoever resulting through our failure to abide by such Provisions .............". The agreement with the 3rd defendant was to "comply with your bank's rules and procedures in force from time (sic) governing the conduct of such account". Mr. Yorke suggests that the conditions thus introduced are not intended to have legal effect, that they are only precatory or directory. He relies on the case of Lam Yin-fei v. Hang Lung Bank Ltd.[25] where the "Rules for Current Accounts" of that bank were held not to contain contractual terms. For myself I do not read that case as laying down any general principle. In addition the learned judge was strongly influenced by the fact that the rules were subject to change at any time without notice to the depositor. However the comments of this court in Lam Luk-ming and Others v. The Attorney General[26] indicate that an express term to that effect in a set of regulations is not fatal to their contractual nature as a whole.

46. Mr. Yorke further likened the rules of the banks to those of a Private club, the only sanction being that the member might be asked to leave, or in the case of the banks, that the customer be asked to take his business elsewhere. The learned judge below did not accept the analogy. He took into account the commercial nature of the relationship and held that the plaintiff was bound by the terms of the agreements so far as they could be given contractual effect. I respectfully agree. The question then is, what is the true effect of the individual conditions with which vie are concerned. They read as follows : -

As to the lst defendant :

Rule 12 -  A statement of the customer's account will be rendered once a month.  Customers are desired to examine all entreis in the statement of account and to report at once to the Bank any error found therein. In the absence of any objection to the statement within seven days after its receipt by the customer, the account shall be considered as correct.

As to the 2nd defendant :

Rule 10 - The Bank's statement of our current account will be confirmed by us without delay. In case of absence of such confirmation within a fortnight, the Bank may take the said statement as approved by us.

As to the 3rd defendant :

Rule 7 - A monthly statement for each account will be sent by the Bank to the depositor by post or messenger and the balance shown therein may be deemed to be correct by the Bank if the depositor does not notify the bank in writing of any error therein within ten days after the sending of such statement. Except for the months of June and December, no monthly statement for an account will be sent if there is no entry passed through it in the month.

47. In the construction of these clauses the judge below adopted the approach of Laskin J. as it appears in the following passage from his judgment in the Arrow(21) at page 97 case :-

"Forgery and unauthorized debits to a customer's account owing to the forgery or fraud of third persons or of employees do not exhaust a bank's liability. There is the quite ordinary case of arithmetic error, of failure to credit sums to an account, of wrongful albeit innocent attribution of debits to an account. These are possible, even if infrequent; perhaps as infrequent as forgery and fraud. These instances of breach of obligation to a customer relate directly to what the bank has sought to achieve through the verification agreement. In my opinion, the principal question is not whether the bank has sought to protect itself against its breach of a fundamental term of its relationship with its customer, but rather what is the scope of protection which it has achieved under a document which is more a contract of adhesion than a bargained arrangement.

Neither forgery nor fraud are expressed as risks of the customer. The key words are 'verify the correctness' of statements of account received from the bank; notify the bank in writing ........ of any alleged omissions from or debits wrongly made to or inaccurate entries in the account'. It is in respect of these, unless there, is timely notice, that 'the account as kept by the bank shall be conclusive evidence' that it is correct, and that, subject to what is excepted (this includes 'payments made on forged or unauthorized endorsements'), the bank is to be free 'from all claims in respect of the account'.

I find it strange that a bank which seeks by contract to throw the risk of all forged drawer signatures upon its customer should be so reticent about referring expressly to such an eventuality. It is not as if its verification form lacks subject-matter without it. The verification form, as a matter of words, encompasses the situation which arose in Union Bank of Canada v. Wood. Beyond this or related situations, it surely is, to say the least, 'ambiguous' (to use the term applied by Duff, J., in the Steward case) in any suggested application to forgery or fraud. There is every reason to construe it contra proferentem, and I would therefore conclude that its words do not provide protection against the forgery of the drawer's signature.

The construction that I would put on the verification agreement is consistent with the approach to contractual limitations of liability in other kinds of relationships, such as bailee and bailor, carrier and consignor, retailer and purchaser. Risks that are by contract to be passed by a party, upon whom they would otherwise rest, to the other party to the relationship must be brought home expressly if they are to be effective; at least this is so when the limitation would still have subject-matter if unespressed risks be found to be outside its general language. "

48. Applying that approach to the present circumstances the judge concluded:-

"....... in none of the terms of rules which I have to consider are forgery or fraud expressed to be risks of the plaintiff. Each of the rules or terms has subject-matter without reference to fraud or forgery. Not one of the rules or terms refers to the account becoming 'conclusive evidence'. No reference is made in any of the rules or terms to the items which are to be included in the account. In my judgment, there is, in each case, every reason to construe the rule or term contra proferentem and so doing in each case, I conclude that it provides no defence to the plaintiff's claim in this action. "

49. This approach appears to have its foundation in a passage from Alderslade v. Hendon Laundry, Limited[27] which was applied by the Privy Council in Canada Steamship Lines Ltd. v. The King[28]. The principles there set out still hold good today but their ambit has been restricted:-

"In my opinion these principles are not applicable in their full rigour when considering the effect of clauses merely limiting liability. Such clauses will of course be read contra proferentem and must be clearly expressed, but there is no reason why they should be judged by the specially exacting standards which are applied to exclusion and indemnity clauses. "

Per Lord Fraser in Ailsa Craig Fishing Co. Ltd. v. Malvern Fishing Co. Ltd. v. Malvern Fishing Co. Ltd. and Another[29], applied by Lord Bridge in George Mitchell (Chesterhall) Ltd. v. Finney Lock Seeds Ltd.[30]

50. Mr. Bromley who appears for the 3rd defendant argues that the rule on which his bank seeks to rely is not an exclusion clause at all, but rather what he would call, if a name is necessary, a "conditional, correlated, account stated clause"; alternatively, if it is such a clause as might fall within the general category, it is a limitation rather than exclusion clause. With all respect to an ingenuous and skillfuly presented argument I am not disposed to accept either of his propositions. The clause, if effective, will relieve the bank of what would otherwise be its liability and that, to my mind, is conclusive of its nature.

51. Nevertheless I do not find the English authorities applicable in this respect. They are all concerned with liability for negligence. The question of negligence, however, does not arise in the present instance. The bank would be liable whether its failure to discover the forgeries was negligent or not. Indeed the same authorities might be used to present the reverse argument. Suppose, for example, the bank attempted to rely upon the clause in respect of arithmetical errors or debits made to the wrong account. These would be matters of negligence and it might be well argued upon those same authorities that as the clauses would have subject matter apart from negligence, i.e. dishonesty by the bank staff or forgery, the clauses should be thus restricted.

52. The reason for distinguishing between exclusion and indemnity clauses on the one hand and limitation clauses on the other was given by Lord Fraser in Ailsa Craig(29) at page 970 :

"The reason for imposing such standards on these clauses (i.e. exclusion and indemnity clauses) is the inherent improbability that the other party to a contract including such a clause intended to release the proferens from a liability that would otherwise fall upon him. But there is no such high degree of improbability that he would agree to a limitation of the liability of the proferens, especially when, as explained in condition 4 (i) of the present contract, the potential losses that might be caused by the negligence of the proferens or its servants are so great in proportion to the sums that can reasonably be charged for the services contracted for. It is enough in the present case that the clause must be clear and unambiguous. "

Lord Wilberforce used similar words at page 966:-

"Clauses of limitation are not regarded by the courts with the same hostility as clauses of exclusion : this is because they must be related to other contractual terms, in particular to the risks to which the defending party may to exposed, the remuneration which he receives, and possibly also the opportunity of the other party to insure. "

Apart from the question of insurance, which seems to have no part in this type of situation, the factors mentioned are to my mind appropriate. The liability of a bank upon its customer's cheques is very special. It turns entirely upon the signature. And if a person has an original signature to imitate or practice from it is by no means difficult to make a copy that will pass muster upon a routine inspection. That is all that can be expected from a bank if it is to keep pace with the requirements of modern business. The risks to which banks are thus exposed are substantial. It may, at first glance, be thought that the risks must necessarily be limited to the amount standing to the customer's credit or the agreed limit of his overdraft, but the present case illustrates that if the forgeries continue undetected over a length of time, these amounts may be well exceeded.

53. On the other hand, banks seem to reap little advantage. So far as I am aware no bank in Hong Kong imposes a direct charge for the service it provides by way of current account. Its remuneration is derived only from the use to which it may be able to put the monies held therein, which individually cannot be expected to be great, and perhaps from the goodwill which the accounts engender.

54. In my view therefore, we should adopt a similar approach to the clauses with which we are concerned. They are contained in standard form contracts imposed by the banks and therefore, to adopt the words of Lord Wilberforce, "if they are to exclude liability they must be most clearly and unambiguously expressed and must be construed contra proferentem". At the same time we "must not strive to create ambiguities by strained construction" but give the relevant words "if possible their natural plain meaning".

55. It has been suggested that the recent decisions in the House of Lords have been influenced by the passage of legislation, in particular the Unfair Contract Terms Act of 1977. see Lord Denning M.R. at page 1045 of Finney Lock Seeds(30). Similar legislation has not yet been enacted in Hong Kong. However, with the very greatest respect, I can find no indication of this in the actual speeches of Their Lordships.

56. It is not easy to set aside the ingrained teaching of many years. Nevertheless I do my best to interpret these clauses as I think they would be read by an ordinary person looking for no subtle distinctions, seeking no refined shades of meaning. Such a person would, I think, take "errors" to mean anything wrong, whatever happened to be the cause. He would not strain to distinguish "correct" from "correct but not conclusive". He would take "approved by us" as meaning that the customer accepted the statement as correct. In fine he would say that if the customer did not object within the specified period then the clauses made the statements final between the customer and the bank.

Estoppel

57. If I am correct in the conclusions I have drawn as to the matters already mentioned those matters are clearly grounds on which the banks can base an estoppel. They have acted to their detriment by continuing to operate the accounts with the attendant risk of further forgeries. Two further matters need to be mentioned :-

(1) Audit Requests -

58. A further ground of estoppel is suggested to lie in the annual requests for confirmation of the balance in the account for audit purposes. These were sent by the plaintiff to each of the banks on what appears to be a standard form prepared by the plaintiff's auditors. The form provides for fourteen possible items which may have an outstanding balance between the customer and the bank, including of course the current account. It requests the bank to confirm that the balance listed as at a particular date is correct, or should the bank disagree, to enter the bank's own figures. A form of certificate is provided for the bank to sign and return and I think we may assume that all the requests made in this way had been regularly complied with. In support of these requests as sufficient representation it is emphasized that they are not casual requests, that they are not limited to just the one item, and that they are a formal statement of the plaintiff's figures. It is said that it is not material that the procedure is undertaken solely for the plaintiff's own benefit.

59. I find myself unable to accept this submission. For a representation, or conduct amounting to a representation to be sufficient to support an estoppel, it must be intended to induce a course of conduct on the part of the other party. That of course the annual request does. It intends that the bank shall check the balance and return the certificate. But that is all. And no detriment to the bank results from that. The request in no way induces the bank to continue its services to the customer after the date of the balance shown therein. Indeed, in the particular instance to which we were referred during the course of argument, the bank had already done so for 4 months before it received the request.

(2) Monthly Confirmations -

60. In the case of the 3rd defendant alone, included with the monthly statement sent to the plaintiff was a document marked at the head "Kindly sign and return the certificate". The certificate reads "I/We acknowledge receipt of your monthly statement of my/our current account with you showing the following balance which has been examined and found correct" and then the actual details are inserted.

61. This is very different from a request to the customer that the bank check its books for a balance several months in the past. It is a representation that the latest balance has been "examined and found correct" and a clear indication to me that the customer is content that the bank shall carry on from there on that basis.

62. Certificates in this form had been returned by the plaintiff regularly every month from the time that the account was opened in 1957 until the trouble arose. In my view, the plaintiff cannot, now, go behind them.

63. For my part, then I am satisfied that the banks have a complete answer to the plaintiff's claim by way either of the failure of the plaintiff to discharge a duty cast upon him by law, by the express terms of their agreements, or by way of estoppel. It is not necessary therefore for me to express a firm opinion upon the other issues raised, but in defence to the arguments of counsel I ought, I think, to deal briefly with them.

Proof of Forgeries

64. It was argued in the court below, and again before us, that as the plaintiff's claims depended in the ultimate on a number of forgeries, those forgeries had to be proved beyond the reasonable doubt. The judge below rejected the submission. He sought to apply, as he put it, "the civil standard as defined in Khawaja[31] bearing in mind at all times the aphorism of Lord Denning in Blyth v. Blyth[32] 'in proportion as the offence is grave so ought the proof to be clear"'.

65. That the civil standard of proof can at times be more than a mere balance of probabilities was noted by Lord Denning in Bater v. Bater[33] when after referring to the requirement of proof beyond reasonable doubt in criminal cases, he said at page 37:-

"So also in civil cases, the case may be proved by a preponderance of probability, but there may be degrees of probability within that standard. The degree depends on the subject-matter. A civil court, when considering a charge of fraud, will naturally require for itself a higher degree of probability than that which it would require when asking if negligence is established. It does not adopt so high a degree as a criminal court, even when it is considering a charge of a criminal nature; but still it does require a degree of probability which is commensurate with the occasion. "

66. He said much the same six years later in Hornal v. Neuberger Products Ltd.[34], with the express approval of Hodson & Marris LL. J and this approach has been applied in many cases since. That it is correct was confirmed last year by all five of their Lordships in the case to which the learned judge below referred.

67. There may be special considerations with regard to marine insurance claims where scuttling is alleged : see "The Cold Sky"[35] and the comments of Lord Denning in Horn(34) at page 254.

68. The strict criminal standard of proof has been demanded by the Privy Council in two instances. The first was in 1939, in New York v. The Heirs of Phillips, Decd.[36], a claim based on an alleged conspiracy where this passage appears at page 955 :-

"The only complaint made of his judgment in point of law is that he laid down that there was a heavy onus on the plaintiffs and that it was necessary for them to prove their case as clearly as they would have to prove it in a criminal proceeding. Their Lordships consider this criticism to be ill-founded. The proposition of the judge has been laid doom time and again in the courts of this country : and it appears to be just and in strict accordance with the law. "

69. The second came two years later in an appeal from Rangoon, Narayanan Chettyar v. Official Assignee[37] when this was said : -

"Fraud of this nature, like any other charge of a criminal offence, whether made in civil or criminal proceedings, must be established beyond reasonable doubt. "

70. It is not easy to reconcile these passages with the words of Their Lordships in Khawaja(31), or with the much earlier comments of the Privy Council in Doe d Devine v. Wilson[38]. It is to be observed, however, that in the first case the main submission was on a completely different point, and in the second the evidence put forward seems to have been of very poor quality. In neither case were Their Lordships required to examine the question to the depth that was necessary in Khawaja.(31) In my view the judge below adopted the correct approach.

71. It is then complained that even so he failed to indicate the exact standard, between the extremes of mere balance of probabilities and beyond reasonable doubt, which he thought would be appropriate in the particular circumstances. With respect I 'find no merit in this point. The judge indicated most that would not be satisfied by the former. I do not think he is required to go further and analyse his feelings to ascertain, and express if he can in suitable language, the precise degree of his conviction.

72. The evidence was in my view sufficient to support his conclusion as to the particular signatures that were not admitted to be forgeries. It is said that he misapprehended or failed to evaluate correctly the evidence of the handwriting experts. I am not persuaded that this is so. We have been taken through their evidence in some detail and, taking it overall, I think the judge was justified in preferring the evidence of Mr. Chen.

Interest

73. The banks succeeded on their defence of estoppel below save in respect of six cheques in the account with the 1st defendant, amounting in a total to $187,195.74. The judge therefore made a declaration that the 1st defendant was not entitled to debit those cheques to the plaintiff's account and awarded interest on that amount from the 1st January, 1978 until the date of judgment.

74. Objection to an award of interest in these circumstances is made on several grounds. First it is said that as the claim was for a declaration there is no jurisdiction in the court, either by way of statute or in equity, to make an award of interest at all. Reference is made to the comments of Richmond J. in the National Bank of New Zealand v. Walpole(l2). However the plaintiff's claim is not for a declaration alone. There is also a claim for payment, even though there may have been little emphasis upon this aspect of the case during the trial.

75. Then it is said that, by reason of the well-established principle to be found in Joachimson(8), the plaintiff had no right to payment of the monies in his account until demand had been made. Therefore interest ought not to be awarded.

76. The answer to that criticism is, as Mr. Yorke pointed out, to be found in the same case.  Atkin L.J., at page 132, observed that any repudiation by the bank of the customer's right to be paid would be waiver of the demand; Warrington L.J., at page 126, thought that demand was made by the issue of the writ itself. Mr. Yorke concedes that the plaintiff would not, in any event, be entitled to interest prior to the date of the writ.

77. Finally it was objected that a current account is a non-interest bearing item. In my judgment that was a consideration relevant only at common law. There is no restriction in Sec. 48 of the Supreme Court Ordinance, Cap. 4. Even if the plaintiff had not realized it at the time, he did in fact lose the opportunity of putting those monies to good use and it is not unreasonable that he should be compensated for the loss. It was, I agree, a loss that was brought about by the plaintiff's own negligence. Yet, if, contrary to my conclusion, that negligence carries no consequence with regard to the monies themselves, I would have thought it a wrong exercise of discretion to use that negligence to deprive the plaintiff of interest that would otherwise have been awarded.

78. For these reasons, I would dismiss the appeal of the plaintiff and allow the cross-appeal of the 1st defendant bank.

(D. Cons)
Justice of Appeal

Hon. Fuad, J.A. :

79. I have had the advantage of reading the judgments of Cons, J.A. and Hunter J. in draft, and share their conclusions that that the appeal of Tai Hing Cotton Kill should be dismissed and that the 1st defendant bank should succeed in its cross-appeal. I agree in general with the reasoning in both judgments but with regard to the proper construction of what Cons, J.A. has termed "The Express Conditions", and Hunter J. "The Banking Contracts", I respectfully incline towards the approach and conclusions of Hunter, J.

(K.T. Fuad)
Justice of Appeal

Hon. Hunter, J. :

80. Mantell, J. set out his findings of fact very clearly in his judgment, and they have been conveniently summarised by Cons, J.A. I shall therefore go straight to the most important question raised in this appeal which is the extent of the duty owed by a customer to his banker and whether the plaintiff owed to the defendant banks either the wider or the narrower duty contended for.

81. It is a basic obligation of a bank to honour its customer's cheques, if first there are sufficient funds in the account or a prior agreement exists for overdraft; and secondly the cheque accords with the customer's mandate. A bank honouring such a cheque acts within its mandate and is entitled to debit the customer's account. If however the drawer's signature is forged, the bank has no effective mandate and cannot debit the drawer's account. As it is sometimes put, the bank pays with its own money, and unless it acts in time to recover from the payee the bank bears the loss; National Westminster Bank Limited v. Barclays Bank Limited[39]. But should the forgery have been caused by the negligence of the customer in the drawing of the cheque these roles are reversed. Such negligence on the part of the customer operates as a defence to the bank, and precludes the customer from challenging the material debit: London Joint Stock Bank Ltd. v. Macmillan & Others(1)

82. So much is common ground. The disputed issue is whether in the words of Richmond J. in the New Zealand Court of Appeal in National Bank of New Zealand v. Walpole and Patterson (12):

"The only type of negligence on the part of a customer which will remove from the banker the risk of paying on a forged cheque is negligence in or immediately connected with the drawing of the cheque itself. "

That learned judge, thought that this principle had been laid down in Macmillan. Mr. Richard Yorke, Q.C. for the plaintiff does seek to support this reading of Macmillan, but he invited us to reach the same conclusion in reliance upon a line of authority starting with the decision in Kepitigalla Rubber Estates Limited v. National Bank of India Limited(13) and what he called an unbroken line of authority since. Mr. Andrew Morritt, Q.C. for the 1st defendant, whose argument was adopted by the remaining defendants, disputes this. These early cases, he submits, were bedevilled by an outmoded view of causation and remoteness. Discard this, he says, and the direct application of modern principles lead inevitably to the conclusion that both in contract and in tort the customers owes to his banker what might be called an ordinary not some circumscribed duty of care.

83. At the outset therefore it seems to me necessary to do two things, namely :-

(1) To consider what was decided in Macmillan and in the cases which preceded it, and how far concepts of causation affected or controlled concepts of duty - 1827 - 1918.

(2) To consider what the applicable modern principles in contract and in tort now are and how they have developed since 1918 : 1918-1983.

1827 - 1918

84. Ones starting point here must be Young v. Crote(7). This was a case of a cheque, ineptly completed by the wife of the customer and fraudulently raised by an hitherto trusted clerk. Best C.J. thought that the prima facie rule that a banker paying out on a forged cheque such as this paid without authority was "perfectly well established, yet if it be the fault of the customer that the banker pays more than he ought, he cannot be called on to pay again." Since want of "ordinary precautions" induced the banker to pay on this forged cheque, the loss for having "improperly trusted" the clerk fell on the customer. The basis for the implication of the duty of care was not adverted to, but it seems implicitly to have been an implication of law.

85. The next most significant case is Bank of Ireland v. Trustees of Evans Charities[40]. The defendant trustees, a corporation, held stock registered with the plaintiff bank. They gave possession of their corporate seal to their secretary. He with the assistance of some apparently innocent attesting witnesses, used the seal to execute powers of attorney and obtain delivery for himself of parcels of stock from the bank. The direction of the trial judge, Blackburne L.C.J. to the jury was to this effect:

(1) If they found forgery their verdict should be for the trustees unless;

(2) The improper use of the seal was "caused exclusively by the negligence or default" of the trustees in which case they should find for the bank unless;

(3) There was any negligence on the part of the bank which "contributed in any degree" to the fraud in which event they should find for the trustees.

86. The House of Lords adopted the advice of the judges delivered by Parke B. which was to the effect that the direction was wrong because there was no sufficient evidence of negligence to go to the jury. The negligence (if any) "was very remotely connected with the act of transfer. ........ The transfer was not the necessary or ordinary of likely result of that negligence". The "very extraordinary event" which intervened was the conduct of the attesting witnesses. The only relevant negligence in such circumstances was "negligence in or immediately connected with the transfer itself". This was truly causative. This was the position in and explanation of Young v. Grote(7). Anything short of that only "enabled" the secretary to forge : it was only what was later to be described as a "causa sine qua non".

87. The significance of this case to my mind is that it demonstrated the contemporary reluctance of the Courts to hold anyone civilly responsible for the criminal act of another. The phrase thereafter most quoted from Parke B.'s advice is not "the necessary or ordinary or likely result" but the words "negligence in or immediately connected with the transfer itself". This phrase defined the concept of likelihood in legal terms : it marked the confines of what the law then recognised as proximate cause, with which phrase it was to become synonymous. This view of causation and remoteness was for many years to govern and confine the duty.

88. This is well illustrated by another seal case, Mayor Constable & Company of Merchants of the Staple of England v. Governor of Bank of England[41]. There both the Divisional Court and the Court of Appeal held themselves bound by the Bank of Ireland case to say that the negligence was not the proximate cause of the loss although in the opinion of Wills J. at least "It was eminently calculated to facilitate if not to invite the commission of forgery" p. 169. Then in 1906 came the decision of the Privy Council in Colonial Bank of Australasia Limited v. Marshall and another[42] which virtually deprived the Young v. Grote(7) duty of any content.

89. It is, therefore, hardly surprising that in the three decisions between Marchall and Macmillan and in Macmillan in the Court of Appeal, the Courts were able to found their decisions wholly or substantially on causation. In Lewes Sanitary Steam Laundry (Limited) v. Barclay Bevan & Co. Ltd.[43], Kennedy J. said :-

"It is not enough for the banker to show that the conduct of his customer wilful, careless, or wasteful, or all, enabled the fraud to be committed. He must show that the customer caused him to pay the money upon the forged instrument. " p. 267.

In Walker v. Manchester and Liverpool District Banking Company Limited[44], Channell J. dismissed the Bank's attempted negligence defence in the words: "at most it was a cause sine qua non".

90. In Kepitigalla, Bray J. said that the cases "can be summed up by saying that they lay down most clearly that the negligence must be in or immediately connected with the transaction itself and must have been the proximate cause of the loss." p. 1025. Indeed the judge regarded himself as bound by the Lewes decision. He also negatived negligence in fact. His rejection of Mr. Scrutton K.C.'s submission of continuing duty (in words very similar to those later used in Greenwood), in the passage cited by Mantell J. may well be obiter. But in this jurisdiction the point is insignificant. What matters is its persuasiveness and to that I will return later.

91. Macmillan was a case of a cheque raised by a trusted but dishonest clerk who was then found to have been committing dishonest acts for some time. The Court of Appeal :-

(1) Unanimously adopted a view on causation which Scrutton L.J. reformulated as : "Neglect of precautions by A which enable C to commit a crime causing loss to B, can never in my view give rise to a claim by B against A, for the loss is not the proximate or even natural consequence of the neglect" p. 460.

(2) Sought to confine the Young v. Grote(7) duty to such cases as the giving of ambiguous instructions.

(3) "Per Scrutton L.J. and Bray J. held that Young v. Grote(7) had lost all its authority. Bray J. dubbed as "absurd" any suggestion that "a customer owes a duty to his banker to take precautions to test the honesty of his clerk" p. 465.

92. The ratio of the decision of the House of Lords reversing the Court of Appeal can I think be expressed in the following four propositions:

(1) The authority of Young v. Grote(7) was restored. Lord Finlay L.C. regarded this duty as "beyond dispute" and as an "obvious" consequence of the contractual relationship, P.789, Viscount Haldane expressed the same concept at 814 in the following words : "the correlative obligation is thus complementary to the obligation of the mandatory". Lord Shaw spoke of "reciprocal obligations" p. 824.

(2) This duty was not fulfilled by employing a clerk believed to be honest. "If the customer chooses to dispense with ordinary precautions because he has complete faith in his clerk's honesty, he cannot throw upon the banker the loss which results", Lord Finlay p. 811.

(3) On causation, which Lord Finlay regarded as the only issue in the case, p. 789, I think that their Lordships did two things. First the narrow formulation of Scrutton L.J. was rejected. "Forgery is the very thing against which the customer is bound to take reasonable precautions" said Lord Finlay at p. 811 and the effect of the contrary view was to "eviscerate the duty". Secondly they followed and applied Parke B.'s test of negligence in the transaction as the only negligence which did more than "facilitate" and which could be a proximate cause. It was in this context that statements on causation by Kennedy J. in Lewes and Bray J. in Kepitigalla were approved by Lord Finlay p. 800, 801 and by Viscount Haldane p. 816.

(4) Such negligence in a customer operates as a defence to the bank. It was immaterial whether it was put as a cross-claim or as an estoppel. "The ground is really one and the same - as the negligence of the customer caused the loss he must bear it" Lord Finlay p. 794.

93. There are two passages in the speech of Lord Finlay at pages 795 and 801 which are capable of being read as approving Bray J.'s rejection of any wider duty in Kepitigalla. I do not regard this as the correct reading, putting the words in their context : and if it is, the observations were obiter. I think that all their Lordships were simply expressing the then policy of the law on causation and remoteness where third party criminality was involved.  It follows that I agree with Mr. Yorke in thinking that the New Zealand Court of Appeal in Walpole read more into the Morrison decision than is justified. This means that the reasoning in Kepitigalla must stand or fall on its own merits.

Modern Principles 1918 - 1983

1. Causation/remoteness

94. It was not in issue that perhaps as a result of a wide-spread increase in criminality, the policy of the law has changed since 1918. The governing authorities are now generally The Wagon Mound[45], and in the particular context of criminality Dorset Yacht v. Home Office(16), which decision has recently been considered by the Court of Appeal in England in two cases concerning Camden Council namely Lamb v. Camden Council[46] and Perl Exporters Limited v. Camden Council[47] to which we were referred. But here the judges adverse findings against the plaintiff and in favour of all three banks were not challenged. Had they been I would for my part have concluded that the fourth defendant, Leung was not an independent third party in the sense that that phrase is used in the Camden cases. I would have regarded this as a case of special contract or relationship such as Dorset Yacht itself, and within Lord Sumner's exception in Weld-Blundell v. Stephen[48]. The plaintiff throughout had the power to control Leung both directly and by the system within which he worked; "and control imports responsibility" per Lord Pearson in Dorset Yacht at p. 1055.

2. Tort

95. Again there was no issue here but that for modern principles we need not look much beyond his speeches of Lord Wilberforce in Anns v. Merton London Borough Council(14) and of Lord Roskill in Junior Books v. Veitchi[49].  As Lord Roskill said, what has to be asked is not "whether the proper remedy should lie in contract or in tort" but the two questions posed by Lord Wilberforce in Anns namely :-

"First, one has to ask whether, as between the alleged wrongdoer and the person who has suffered damage, there is a sufficient relationship of proximity or neighbourhood such that, in the reasonable contemplation of the former, carelessness on his part may be likely to cause damage to the latter - in which case a prima facie duty of care aroses. Secondly if the first question is answered affirmatively, it is necessary to consider whether there are any considerations which ought to negative or to reduce or limit the scope of the duty or the class of persons to whom it is owed or the damages to which a breach of it may give rise. "

3. Contract

96. Somewhat surprisingly the issue of principle arose here. In common with all the judges who have rejected any wider duty in contract, Mantell J. expressed himself in the traditional terms of the presumed intentions of the parties : of business efficacy in the sense used in the Moorcock[50] and Reigate v. Union Manufacturing Co.[51]: and of Mackinnon L.J.'s "interfering bystander" Shirlaw v. Southern Foundries[52]. A helpful modern summary appears in two of Lord Simon's qualifying conditions in the B.P. Refinery[53] namely : -

"(2) It must be, necessary to give business efficacy to the contract, so that no term will be implied if the contract is effective without it:

(3) It must be so obvious that 'it goes without saying' ".

97. Mr. Morritt challenges this approach. The true test he submits does not depend primarily or to any significant extent upon the presumed intentions of the parties to the contract. The question is what terms do the law impose as necessary incidents of the banker/customer relationship in all ordinary banking contracts. This he submits is the test which the Courts have in truth applied in many banking cases and that which we should apply here.

98. It seems to me that this is a submission of considerable importance which merits careful examination. Its significance goes beyond the ascertainment of the true test in contract. It goes to the reality and significance of any surviving differences between contract and tort in this field. There is a real difference concealed in the use of the word implied, between a term implied for reasons personal or peculiar to the contract in question and to a term implied - I prefer to use the word "imposed" - by law. The use of this word suggests that the classic differences between contract and tort start to disappear. If the duty of care (if any) resting on a banker or customer originating out of the banking contract between them is imposed it is pertinent to ask two further questions.

99. First can the duty be said to be truly contractual at all? This may depend upon emphasis and savour of a matter of semantics. If one looks only to the individual the answer may be no. Neither party may consciously have considered, accepted or relied upon any such duty. Indeed the party if asked might indignantly have denied it. But if one looks at the effect of the contract the answer may well be affirmative because a duty does not cease to be contractual if it is a legal and not a consensual incident of the contract.

100. Secondly, and possibly of greater significance, is the question why is the duty imposed? One possible answer is that it results from the conscious or unconscious application of what can now be called tortious principles of proximity to those who have entered into a special or proximate relationship by reason of their banking contract, and by reason of the reciprocal obligations undertaken by each. If this should prove on authority to be the reason, then it seems to me that the difference between contract and tort in this sphere is very marginal indeed. It may well be correct to say that the duty (if it arises) is both contractual and tortious. But if the tortious duty arises by reason of the contractual proximity; and if the contractual duty is imposed on tortious grounds; one is left with two different routes to the same conclusion. In both cases the relevant questions would be those proposed by Lord Wilberforce.

101. Mr. Morritt's submission is initially based upon two decisions of the House of Lords, Lister v. Romford Ice and Cold Storage Limited(6) and Liverpool Corporation v. Irwin(3), and upon a most useful summary of their principles in Mears v. Safe Car Security Limited[54] per Stephenson L.J. at p. 383.

102. In Lister, a master and servant case, the majority considered the question whether "the implied term (in issue) is imposed by law, not in respect of a particular contract but as a legal incident of this type of contract" per Viscount Simonds at p. 579. Lord Tucker included in his examples of "contractual terms implied by general rules of law" contracts of guarantee. This does not limit the principle to status. Two other points are worthy of note. First, all their Lordships regarded the servant's duty of care to his master as contractual, Viscount Simonds 573. But it was also imposed for at page 575 he said : "Just as the duty of care, rightly regarded as a contractual obligation, is imposed on the servant". Secondly in his dissenting speech Lord Radcliffe used words which I regard as particularly apposite to the present problem :-

"The existence of the duty arising out of the relationship between employer and employed was recognized by the law without the institution of an analytical inquiry whether the duty was in essence contractual or tortious. What mattered was that the duty was there. A duty may exist by contract, express or implied. Since, in any event, the duty in question is one which exists by imputation of law and not by virtue of any express negotiation between the parties, I should be inclined to say that there is no real distinction between the two possible sources of obligation. But it is certainly, I think, as much contractual as tortious. Since in modern times the relationship between master and servant, between employer and employed, is inherently one of contract, it seems to me entirely correct to attribute the duties which arise from that relationship to implied contract p. 587.

103. In the Liverpool Corporation case the business efficacy route having led to failure in the Court of Appeal, the House of lords followed Lister and in the words of Lord Fraser's summary at p. 270 : "Implied, as a legal incident of the kind of contract between these landlords and these tenants, an obligation on the landlord to take reasonable care to maintain the common stairs" etc. Their Lordship differently expressed the circumstances in which they regarded it as right for such implication to be made. For my part I gratefully accept Stephenson L.J.'s summary in Mears : "The obligation must be a necessary term : that is required by the relationship p. 383.

104. On these authorities Mr. Morritt in my judgment makes good the first part of his submission. The law does impose obligations as incidents of particular relationships and I can see no reason to exclude the relationship of banker and customer for this purpose simply because it was not specifically mentioned in either authority. It, therefore, seems to me necessary briefly to consider some of the leading banking cases decided in and since 1918 for three purposes namely : -

(1) To see how the law has developed generally in this period.

(2) To see how far the reasoning points to contract or to tort; and if to contract to presumed intention or legal incident.

(3) Whatever answer is suggested under (2) whether the duty has been implied or imposed apparently for reasons other than proximity namely the clear foreseeability of loss to one or other party arising from the banking relationship if care was not taken.

105. The duty was recognised in Young v. Grote(7) "without analytical inquiry" as Lord Radcliffe put it. This could be true of the cases up to Macmillan, where particular emphasis was laid on the contractual obligation and upon reciprocity of duty. But I have found in the speeches no reference to the parties' intentions implied or presumed. This could, therefore, be regarded as the first legal incident case. But whether this be right or not the basis of the implication or imposition was legal and its apparent cause was contractual proximity.

106. Mr. Morritt was in greater difficulty in trying to fit Joachimson v. Swiss Bank(8), and Atkin L.J.'s famous implied contract formulation into his legal incident framework. One of the problems is that a case for implication argued from the other terms of the contract, which is the burden of the judgments, may equally be the basis of a business efficacy implication. That, and the presumed intentions of the parties, I regard as the basis of this decision. Two points in it can be noted. First the banking evidence played only a supporting not a decisive role. Secondly Atkin L.J. was glad to notice that the Court's view coincided with those expressed in the United States.

107. In the present context the same Court's views in Hilton v. Westminster Bank Limited[55] are more instructive, and not affected by the decision in the House of Lords. There Bankes L.J. said of the banker/customer relationship : "In essence it is a contractual relationship which involves I think the duty on the bank to take reasonable care in the carrying out for its customer of its customer's business" p. 358. Atkin L.J. said : I think it is the duty of the bank arising out of the contract to exercise reasonable care and skill in dealing with the communications which the customer sends to them in relation to his banking business" p. 362.  It is interesting to compare these words with those of Collins M.R. in Sachs v. Henderson[56], where in drawing a "difficult" dividing line between contract and tort, he said : "But where it is only necessary to refer to the contract to establish a relationship between the parties and the claim goes on to aver a breach of duty arising out of that relatioship the action is one of tort." Like Bankes L.J., Atkin L.J. probably regarded his duty as contractual rather than tortious. But he does not allude to presumed intention. His duty seems to be based on proximity and upon an implication (or imposition) or law.

108. In Greenwood v. Martins Bank (9) in the Court of Appeal, Scrutton L.J. emphasised the mutuality of the obligations of banker and customer which he said involved "a continuing duty on either side to act with reasonable care to ensure the proper working of the account", p. 381. Naturally the banks relied upon this concept of mutuality as leading to the same duty, with the differences in performance according to the parties different functions.   But beyond giving rise to a duty to report known forgeries sufficient to support an estoppel, Scrutton L.J did not seek to extend the Macmillan formulation; he re-emphasised the causation limitation, and pointed to the differences between the English and the United States Courts. Greer L.J. founded the customer's obligation to speak upon "the rules of fair dealing between man and man" p. 388. This is surely a tortious test originally based upon the proximity of being parties to the same bill of exchange; see Fung Kai Sun v. Chan Fui Hing[57]. In his speech in the House of Lords well known for its formulation of the principles of estoppel, Lord Tomlin did not have to deal with the basis of this duty, whose existence was conceded.

109. In Lloyds Bank v. Brooks(4), Lynskey J. held that a banker owed a duty of care to its customer in relation to the preparation of its customer's statements. The basis would seem to have been legal proximity. Mr. Morritt's narrower duty is the direct reciprocal of this In Woods v. Martins Bank[58], Salmon J. held that a bank manager owed a duty of care to a potential customer in giving advice on investment. The basis seems to me to have been tortious (a fiduciary relationship): "As he chose to advise ..... the law imposes an obligation...... to advise with reasonable care and skill" p. 72. When in Hedley Bryne v. Heller[59] the House of Lords held that the duty of care in tort extended to the spoken work, Lord Devlin included the banker and customer alongside the solicitor and client as an example of a "general relationship" giving rise to a duty of care p. 530. The dual significance of these two decisions to bankers is illustrated by cases like Box v., Midland Bank[60].

110. In Selangor United Rubber Estates Limited v. Craddock(10) Ungoed Thomas J., after a full review of the authorities, concluded that "A banker has a duty under its contract with its customer to exercise 'reasonable care and skill' in carrying out its part which regard to operations within its contract with its customer", p. 1608. This duty he said "Extends over the whole range of banking business within that contract" p. 1609. In the absence of any reference in the judgments to the presumed intentions of the parties, it seems to me reasonable to conclude that the judge regarded this duty as implied or imposed by law on proximity grounds.  The absence of any reference to intention and to the Reigate test (Reigate v. Union Manufacturing (51)) was one of the foundations of the challenge to the decision to Selangor in Karak Rubber v. Burden(11). Brightman J. rejected this on two grounds : First because the Selangor contractual duty of care "seems to be rational" : and secondly because the implied duty passed the test "without trouble" p. 629. This seems to put the matter on both grounds.

111. Mr. Morritt relies heavily on these two decisions. First he submits that if the law implies or impales this duty on a banker by reason of his contract with his customer, it must impose as a reciprocal obligation the same duty on the customer. Secondly he prays in aid Brightman J.'s Achilles Heel argument. Once the causation limitation is discarded, and once a duty of care in the drawing of a cheque is accepted, there is, he submits, "no rational stopping place short of a contractual duty to exercise such care and skill" as a reasonable customer would exercise in his own interests.

112. Finally in two areas of ancillary activity common to bankers, a tortious duty of care has been held to exist. In Cuckmere Brick v. Mutual Finance[61] Salmon L.J. based his conclusion that on a realisation of mortgaged property the mortgagee was under a duty to take reasonable care to obtain the true market value upon the concept of proximity. "The proximity between them could scarcely be closer. Surely they are neighbours" p. 966. His conclusion would appear to have been approved by the privy Council in Tse Kwong Lam v. Wong Chit San[62]. In Standard Chartered Bank v. Walker[63] a receiver was said to owe a like duty to both the borrower and to a guarantor of the debt.

113. In his speech in Hedley Byrne, Lord Devlin likened the position of banker and customer to that of solicitor and client p. 530. Lord Denning M.R. did the same in Dutton v. Bognor Regis[64], treating them both as professional men. Again in relation to professional men and after referring to the solicitor cases Lord Denning M.R. had this to say in Esso Petroleum v. Marden[65]at 819 :

"In the case of a professional man, the duty to use reasonable care arises not only in contract, but is also imposed by the law, apart from the contract, and is therefore actionable in tort. ........ A professional man may give advice under a contract for reward; or without a contract in pursuance of a voluntary assumption of responsibility gratuitously without reward. In either case he is under one and the same duty to use reasonable care. ......... In the one case it is by reason of a term implied by law. In the other it is by reason of a duty imposed by law. " (my emphasis)

In his masterly judgment in Midland Bank v. Hett, Stubbs and Kemp[66], Oliver J. showed that a solicitor under retainer could, and in the absence of some express or implied contractual limitation did owe a duty of care to his client both in contract and in tort. I believe that much of his reasoning can equally be applied to the banker/customer relationship. If in that case Oliver J. can be said to have closed the limitation gap between contract and tort, the Court of Appeal may be said to have done the same for remoteness of damage in parsons v. Uttley Ingham[67] See also Lord Denning M.R. in Photo Productions Ltd. v. Securicor[68] in the Court of Appeal, (not affected by the House of Lords decision).

114. Finally we must not forget Lord Macmillan's dictum in Donoghue v. Stevenson[69] itself. "The fact that there is a contractual relationship between the parties which may give rise to an action for breach of contract, does not exclude the co-existence of a right of action founded on negligence as between the same parties, independently of the contract, though arising out of the relationship in fact brought about by the contract. "

115. The effect of these decision can, in my judgment, be summarised thus :-

(1) The banker now owes to his customer a duty to take reasonable care extending "over the whole range of banking business within the contract" and in relation to most (if not all) of the ancillary activities commonly associated with banking.

(2) In relation to the former the duty is usually said to arise in contract : in relation to the latter the more usual formulation is tortious. But both routes lead to the same duty.

(3) The contractual duty formulations have in the main owed little or nothing to the presumed intention test. The basis has generally been implication or imposition of law. This in turn seems to me implicitly to have been founded upon the proximity created by the relationship and by the mutual obligations arising thereunder.

(4) It is unnecessary to determine whether the vestigial differences between contract and tort have significance or little more than historic interest. The duty is "one and the same". If I am right in regarding proximity as being the real test for both, then the only relevant questions are those posed by Lord Wilberforce.

To these I shall now turn.

Question 1

116. On these authorities this question seems to me to admit of only one answer. If the banker/customer relationship is sufficiently special to give rise to a duty of care in the banker, then it is difficult to see how in a contract which creates mutual obligations the converse proposition can be otherwise than true. As Mr. Morritt put it both are operating the bank account for their mutual benefit. It is in the interest of each that it should be properly conducted. From this mutual interest a duty if it arises should be mutual. More particularly any customer ought reasonably to contemplate that carelessness on his part both in and beyond the drawing of a cheque might be likely to cause damage to the banker if it caused him to honour a forged cheque or otherwise to act contrary to the customer's true wishes or outside the mandate. There is in my judgment a "sufficient relationship of proximity".

Question 2

"Whether there are any consideration which ought to negative or reduce or limit the scope of the duty" is the real issue on this part of the appeal. Here Mr. Yorke made two submissions. His major premise was to invite us to follow Kepitigalla and those cases where it had been approved; not disturb as he put it 70 years of unbroken authority; and limit the customer's duty to the drawing of the cheque itself. His second and minor premise (which made a substantial inroad into the first) was to urge us to limit the duty to circumstances where damage was "very likely" to be caused, founding on the use of this phrase in the two Camden Council cases of Lamb and Perl, see for example perl at p. 775. Thus he submitted no duty would arise if a cheque book was simply lost; but it would arise if it was known to have been stolen because it would then be known to be in criminal hands. Again a duty to guard against lack of integrity in staff would only arise in an exceptional case e.g. of the employment, perhaps as an act of charity of a man with a criminal record : otherwise it would not. Conversely Mr. Morritt urges us to adopt his narrower duty formulation if we rejected his wider duty.

117. Before attempting to answer this question I propose separately to consider four matters namely :

(1) The solution which might prima facie be suggested by the recent English decisions alone.

(2) The reasoning in the authorities in the United States and Cananda in favour of a wider duty.

(3) The reasoning in the authorities against any widening of the duty especially Kepitigalla and Walpole.

(4) The argument on settled practice, which also involves a consideration of the cases on narrower duty.

(1)  Recent English Decisions

118. What immediately stands out from these is the peculiar, if not unique, position of a customer, if his duty of care is limited to the drawing of the cheque. Beyond that he can be as careless as he likes. If he operates his account through others he need take no step to control or check their work or their integrity. If he operates his account himself he can ignore obvious wrong entries in his pass-sheets and throw them away unread. The consequences of either course may be as damaging to his bank as a carelessly drawn cheque. But the risk is exclusively their's. In respect of one particular field of dishonest conduct on the part of a servant, he enjoys free fidelity insurance. Counsel was unable to suggest any other situation in modern jurisprudence where such a selective duty, or where a duty of care short of one to take such care as was reasonable in all the circumstances, had been imposed by law, and none has come to my mind. For once any duty is accepted there is much force in the suggested application of Brightman J.'s dictum that there is "no rational stopping place" short of the usual duty. The Macmillan limitation was not based on reason but on "proximate cause". Indeed the emphasis there on reciprocity is now a potent factor against limitation.

119. Nor is there any novelty in asking a man to bear the consequences in whole or in part of his own carelessness. Independently of any actionable duty the law of contributory negligence imposes on any man complaining of a breach of a duty of care owed to him, an obligation to have due regard for his own interests and to bear losses occasioned by his own carelessness. "where a man is part author of his own injury, he cannot call on the other party to compensate him in full. " per Viscount Simon, Nance v. British Colombia Electric Railway Co. Ltd.[70] This defence is open to any banker sued for breach of any of the duties considered in the recent authorities. It has been assumed not to be available to the banks here for procedural reasons only, arising from the nature of the claim and the wording of the Ordinance. If it had been available its effect is not readily distinguishable from Lord Finlay's observation in Macmillan : "As the negligence of the customer caused the loss he must bear it".

120. These considerations are sufficient in my judgment to negative Mr. Yorke's minor premises. Any duty stemming from the banking contract must as I see it arise when the contract is made, and take effect according to circumstances during its subsistence. It cannot behave like some alternator and live and die according to circumstances e.g. on the actual signing of a cheque or the appearance of some particular risk. Secondly I reject the underlying reasoning. The Camden cases have in my judgment no application to a servant whose work and working environment is under his master's control. Since Mr. Yorke's minor premise was advanced in mitigation of what I have called the peculiarity of the customer's position, its rejection is itself a pointer to a negative answer. My prima facie conclusion from these authorities and these considerations therefore is, that they lead to the rejection of Mr. Morritt's narrower duty, and to a negative answer to this question, unless very convincing reasons to the contrary emerge from other authorities.

(2) The United States and Canadian Cases

130. The Courts in the U.S. had at least by 1913 developed a principle best described by two citations from authority. The first is a decision of the Supreme Court of California in Pacific Coast Cheese Inc. v. Security First National Bank of Los Angeles[71] where the applicable principle (cited by Laskin J, in Arrow Transfer Co. Ltd. v. Royal Bank of Canada(21) p. 101 is said to be : -

"The general rule is that a bank may not charge its depositor's account with payments made on altered or forged cheque unless some conduct of the depositor falling under the principles of negligence or estoppel contributed to the loss and the bank was itself free from negligence. ... This rule has been applied where, as here, the alteration or forgery was committed by an employee of the depositor. .... When it appears that the bank has made payment on the basis of an altered or forged cheque, the burden is on the bank to justify the charge by establishing, as an affirmative defence, both that it was free from negligence and that the depositor was negligent or was estopped to deny the correctness of the payments."

131. The second authority is the decision of the Supreme Court of New York in Screenland Magazine Inc. v. National City Bank of New York(24) where after stating a series of propositions to the same effect as those in the Californian case, Shientag J. summarised the position as follows, p. 290 :-

"The law applies the law of reason in dealing with the situation such as is here presented. The bank starts with the burden of strict liability. In the first instance it is virtually the insurer of the validity of its depositor's signature. That strict liability is modified when it appears that the depositor himself has been guilty of a breach of duty owed to the bank, when because of the carelessness or fault of the depositor a long continued repetition of the forgeries is made possible. When the depositor is so at fault the liability of the bank ceases to be that of an insurer; it becomes liable to the negligent depositor only if the bank itself has also been negligent in failing to detect the forgery. A strict liability imposed by the law in the first instance is then transformed into an obligation on the part of the bank to use reasonable care - that degree of prudence which could reasonably be expected of a bank. "

I said this principle goes back at least to 1913 because it finds expression in a case decided in that year namely Trustee of Morgan v. U.S. Mortgage and Trust Company[72]

132. A singular feature of this principle is its striking similarity to Blackburne L.C.J.'s direction to the Dublin jury in 1847 in the Bank of Ireland case. Although I cannot pretend to have researched the matter, this seems to me to suggest that the English and U.S. principles have the same origin : that the U.S. Courts were able to develop the principle without the same "proximate cause" limitation which once controlled the English Courts; and that if this Court were now to adopt the second part of the U.S. formulation it could be said to be drawing upon ancient authority in both jurisdictions, as well as moving towards a beneficial harmonization of English/Hong Kong and United States banking practice.

133. Secondly as early as 1886 the U.S. Supreme Court in Leather Manufacturer's Bank v. Morgan(20), held that a customer had a duty to examine his pass-book. The contrary view did not seem to the Court "to be consistent with the relations of the parties or with principles of justice". Founding on both U.S. and English authorities the Court deduced : "The general principle that, where a duty is cast upon a person by the usages of business or otherwise, to disclose the truth - which he has the means by ordinary diligence of ascertaining - and he neglects or omits to discharge that duty, whereby another is misled in the very transaction to which the duty relates, he will not be permitted, to the injury of the one misled, to question the construction rationally placed by the latter upon his conduct." p. 112. The Court further entered a caveat against pushing this duty too far : "We must not be understood as holding that the examination by the depositor of his account must be so close and thorough as to exclude the possibility of any error whatever being overlooked by him. ..... While no rule can be laid down that will cover every transaction between a bank and its depositor, it is sufficient to say that the latter's duty is discharged when he exercises such diligence as is required by the circumstances of the particular case, including the relations of the parties and the established or known usages of banking business." p. 116.

134. This duty formulation is similar to that of "fair dealing between man and man" referred to by Greer L.J. in Greenwood. This decision was referred to but distinguished on the facts in Kepitigalla.

135. This and later cases suggest that the U.S. Courts have had no difficulty :-

(1) In applying to customers a reasonably acceptable standard of care; and

(2) In reaching substantially the same conclusion as did Lord Finlay in Macmillan at p. 811 that the customer cannot shelter behind an examining clerk's dishonesty and is affixed with the knowledge that a reasonable inspection would have revealed.

136. In Canada the two particularly relevant authorities are the dissenting judgment of Laskin J. in Arrow Transfer Co. Ltd. v. Royal Bank of Canada(21); and the judgment of Montgomery J. in Canadian pacific Hotel Limited v. Bank of Montreal(22) which, having been upheld on appeal, is shortly, we were told, to be considered by the Supreme Court of Canada. The two significant features of these decisions are :-

(1) Laskin J.' regretted past "judicial reluctance to impose upon a depositor a duty to examine bank statements" p. 99. This had led in Canada to the increasing use of verification agreements in Draconian terms which the learned judge plainly disliked because of their very great width. His view was that it was not too late and more desirable to "impose" or "fasten" such a duty upon bank customers.

(2) In his closely reasoned judgment Montgomery J. emphasised the matters I have referred to above as peculiarities, before concluding as a matter of imposition of duty, that : "A customer owes a duty to the bank to operate an acceptable internal control system so that both the bank and its customer are jointly engaged in prevention and minimization of losses occurring through forgery. "

(3) The cases against widening the duty

137. I shall concentrate here on Kepitigalla and Walpole because in Wealdon Woodlands (Kent) Ltd. v. National Westminster Bank (unreported) 11th March 1983 (a somewhat special case on its facts) McNeill J., without the benefit of the full argument we have heard, followed Kepitigalla : and in Asien-Pazifik Merchant Finance Limited v. Shanghai Commercial Bank Limited(19) (a 1979 decision) Leonard J. founded his decision very largely on Kepitigalla and Walpole. In so far as he negatived any wider duty situation I must respectfully disagree.

138. In rejecting any wider duty formulation in principle in Kepitigalla at p. 1025 Bray J. relied upon four grounds namely :-

(1) That no term could clearly be said to be within the presumed intentions of the parties. Recent authorities show this not to be the only or the primary test.

(2) "What is to be the standard". A similar problem exercised the mind of Parke B. in the Bank of Ireland case. But the standard of the reasonable man has since been almost universally adopted. I can see no reason for assuming that exceptionally it will fail to provide a reasonably workable standard for the customer, and U.S. experience is to the contrary. This standard would require no more of the customer than what was basic or elementary for his own protection. For the typical corporate customer who relies upon the integrity of those who manage and control its accounts, it would require the imposition of a reasonable system of control designed to prevent and detect fraud and not least the conduct of proper bank reconciliations. For the private customer who handles his own account, it would probably require no more than the sort of check on the balance shown in his pass-sheets, when received, which many now make as a matter of course.

(3) The banks can obtain this protection by express stipulation in their contract and should look for it in this way. This statement of capacity is true. But the Canadian experience has shown this approach to be much less attractive in practice than it may have appeared in prospect. It could equally have been said of many of the duties recently imposed on banks. It did not deter the Courts because with the erosion of the differences between contract and tort it has become a somewhat outmoded concept. It is an example of the sort, of approach which Lord Roskill said in Junior Books at p. 545 : "Ended in 1932".

(4) The risk of the bank is small : that to the customer is very great : and "the profits of banking are sufficient to compensate them for this very small risk". It is questionable whether all these factual assumptions were justified then or now. But even if they were, they do not in my judgment constitute a sufficient policy consideration which would justify the law in affording special protection to customers who neglect elementary precautions.

139. In Walpole, the Court of Appeal in New Zealand did not have the benefit of as full an argument as we have enjoyed, and particularly of considering very recent English authority. If for example they had had the Anns decision before them, I think that Woodhouse J. would have posed a different question and would have spoken of "limiting" not of "extending" the negligence concept p. 21 (33). Nor do I think that Macarthur J. would have advanced his third reason on p. 22 (36) which seems to me unsustainable on recent authority. I have already expressed my disagreement with the Court's views of Macmillan upon which it particularly founded, and have made my comments upon the reasoning in Kepitigalla which the Court substantially repeated. I shall defer consideration of their last ground of decision namely settled practice.

140. Finally in this context I must note the decision of the High Court of Australia in Commonwealth Trading Bank of Australia v. Sydney Wide Stores Pty Limited[73] upon which both parties relied. The decision finally rid the Australian Courts of the binding authority of Marshall in favour of the decision in Macmillan. It reversed a striking out decision and restored a defence containing on allegation of negligence against the plaintiff customer (whose statement of claim itself charged negligence against the bank) which contained two heads of particulars. Head C(1) alleged negligence in the drawing of the cheque - what might be called pure Macmillan. Head C(2) alleged a failure "to discover the continuing fraud" of its employee - which seemed to assert a wider duty. Mr. Yorke relies particularly upon the reasoning of Murphy J. to the effect that modern principles and current social conditions justified the imposition of a duty going up to, but not beyond, the drawing of the cheque. Mr. Morritt relied upon the majority judgment in two ways. First he said the reference to "the existence of the contractual relationship" as "the foundation for imposing a duty on the customer" supported his basic contention. Secondly the rejection of Marshall as not conforming "to modern notions of the duty and standard of care expected of the reasonable man", which now included taking account "of the possibility that others will break the law" p. 578, inevitably led not simply to, but beyond Macmillan. I think he is right, unless Murphy J.'s limitation can be justified as a matter of policy.

(4)  The Argument on Settled Practice and the Decisions on the Narrower Duty

141. The last ground of decision in Walpole relied upon by Macarthur and Woodhouse J.J. was that "customers and banks have long conducted their relationship on the footing" that beyond the drawing of the cheque the risk of forgery falls on the banker.

142. First I beg to doubt whether any inhibiting settled practice principle exists in the field of imposition of duties upon particular classes of person generally, as opposed to purely personal rights arising from particular contracts or common form agreements. It is easier to point to authority against than in favour in this context. The suggested principle did not impede the development of the law, or aid professional classes generally, in Hedley Byrne; solicitors in Midland Bank v. Hett; (66) customers (at least up to Macmillan limits) in Sydney Wide; mortgagees in Cuckmere Brick; or barristers in Rondel v. Worsley[74]. Counsel could refer to no other case in this field where this principle had been applied, and I know of none.

143. Equally I beg to doubt the premise behind it. I do not believe that people generally "conduct their relationship" upon the basis that they can be wholly careless, and still expect others to save them from harm. Rather I believe that people aim to exercise care both in their own affairs and where relevant in the affairs of others. I doubt whether the standards of those classes of persons, the subject matter of the decisons above referred to, were materially affected thereby. Before them, those conscious of their immunity were unlikely to exploit it : afterwards the most likely consequence was a policy of insurance.

144. The lines of authority on a wider duty have already been traced.  Those on narrower duty have not. Since on one view the narrower is not a distinct duty, but a particular application of the wider, this has some bearing upon the settled practice point. As Dr. Milnes Holden shows in his article in 17 M.L.R. 41 the authorities here are confused and inconclusive. One of the difficulties to my mind is that this problem became interwoven with the parallel but distinct account stated problem, and in consequence this led to confusion arising from the ambiguities in the use of that phrase. Any implied obligation to check the accuracy of a pass book, was not readily separable from an implication of an account stated of one kind or other.

145. In relation to inspection, the law in England and the U.S. had the same source, Devaynes v. Noble[75](75), where the Master in his report records a custom or practice which included inspection by the customer. It is difficult to determine when the paths diverged. It may have been the reference to "lack of evidence" of the implied contract showing neglect of the customer's duty (again in an account stated context) in the judgment of Bowen L.J. in Vagliano v. Bank of England[76]  in the Court of Appeal; which now appears somewhat outdated. Or it may have been the ex tempore observations of Lord Esher M.R. in Chatterton v. London County Bank,[77] which so incensed Sir John Paget, but which seemed to have been given weight by their adoption by Bray J. in Kepitigalla, again in an account stated context. If together these constitute authority against any obligation to inspect, the law is precariously perched in the uncertain area of presumed knowledge. Both strangers and customers have a duty to inform if they know of a forgery, Fung Kai Sun v. Chan Fui Hing(57) and Greenwood v. Martin's Bank(2). But notwithstanding the purpose of returning pass-sheets to the customer, he can close his eyes unless it should be held to be a "suitable case" to attribute knowledge Wealden Woodlands at page 21. The passage in Paget's Law of Banking 9th edition 113 from which this phrase is taken, contains a useful summary of the cases and anticipates my conclusion. I find the reasoning in Leather Manufacturer's Bank v. Morgan (20) both persuasive and more fitting. I find it very difficult to reconcile this limitation with modern principles of negligence, and impossible to discover any policy considerations in favour of its retention.

146. In his well known speech in Camillo Tank Steamship Co. v. Alexandria Engineering[78]. Viscount Cave identified three types of accounts stated. The first, which could equally be called an admitted statement of account, has only evidential effect. The second and third, which could equally be called accounts settled for valuable consideration, since the presence of consideration is the vital difference, have substantive effect; can only be re-opened like any other agreement e.g. for fraud or mistake; and create a new cause of action. We have the authority of Lord Wight in Firm Bishum Chand v. Seth Girdhari Lal[79] for the proposition that there can be a true "settlement of account between banker and customer". But no single case can be found where this has apparently happened. I believe the explanation to be that the admitted statement of account concept fits the normal banker/ customer relationship; whereas the account settled concept does not. It seems to me both artificial and unreal to say that because any bank account has both debit and credit entries, that when it is considered by the customer the parties in the words of Blackburn J. in Laycock v. Pickles[80] (quoted in Firm Bishum Chand at p. 468) "mutually agreed the several amounts of each and .....go on to agree the balance". Prima facie acceptance by the customer is likely : mutual discussion the exception. This approach accords with the usual banking practice of crediting accounts with uncleared effects with adjustment following where necessary. If therefore there was ever thought to be a risk that an acceptance of an obligation on a customer to inspect his pass-sheets might have led to a strict account settled conclusion, such risk in my judgment ought now to be regarded as not well founded.

147. I come back to the answer to the second question. In my judgment, in Hong Kong, the governing and highly persuasive authority is in general that of the recent English decisions, and in particular the United States and Canadian authorities. I am not persuaded that the arguments in the contrary authorities are convincing or entitle us to give other than an negative answer to this question. In my judgment therefore a customer owes to his banker both in contract and in tort a duty to take reasonable care "to ensure the proper working of his account" in the words of Scrutton L.J. in Greenwood. Mantell J. having found such duty to have been broken (if it existed) in relation to all three defendant banks, for my part I would allow the 1st defendant's cross appeal against the plaintiff and dismiss the plaintiff's appeals against the 2nd and 3rd defendants.

148. As the remaining issues were most carefully argued by counsel I shall deal with them shortly.

The Banking Contracts

150. I agree with Mantell J. that the various rules relied upon had contractual effect, but that in no case did they constitute conclusive evidence clauses. For my part I reach this conclusion on the basis that nowhere are the words used sufficiently clear to have that effect; and particularly to bring home to the customer the intended importance of the inspection he is being expressly or impliedly invited to make, and its alleged conclusiveness. As Mantell, J. emphasised : "Not one of the rules or terms refers to the account becoming 'conclusive evidence'". The words used in all cases are consistent with the common law duty I have found to exist. This duty and they at most lead only to an agreed statement of account; not to an account settled for valuable consideration. It is unnecessary to determine whether they are sufficient alone to create any such duty.

151. I reach this conclusion without having to determine whether we should in Hong Kong adopt the approach of Laskin J. in Arrow Transfer to the construction of such contracts, or the yet more difficult and important question whether we should follow and apply the principles of construction recently stated by the House of Lords in George Mitchell v. Finney Lock Seeds Ltd.(30); Ailsa Craig Fishing v. Malvern Fishing (29); and Photo productions v. Securicor Transport(68): or whether we should hold that a different statutory position and especially the absence here of any legislation equivalent to the Unfair Contract Terms Act 1977 justifies Hong Kong Courts under section 3 of the Application of English Law Ordinance in retaining the full rigour of the principles of Canada Steamship Co. v. The King (28).

Estoppel

152. Upon my conclusion on duty and the judges' findings, an estoppel arises in favour of all the banks. I would have reached the same conclusion in any event in favour of the 3rd defendant upon the terms of the certificates provided to it monthly by the plaintiff : but not upon the accountancy - audit documents.

Standard of Proof of Criminal Conduct in Civil Proceedings

153. The industry of counsel has revealed two conflicting lines of the highest authority. Twice in expressing the opinion of the Privy Council Lord Atkin said expressly or by necessary implication that the standard was proof "beyond reasonable doubt" : People of the States of New York v. Phillips (36), and Navayanan v. Official Assignee, Rangoon(37). The contrary view that the civil standard applies with due regard for the importance and seriousness of the conduct charged has the support of the privy Council in Doe d. Devine v. Wilson(38); of the House of Lords in Blythe v. Blythe(32) approving the decision of the Court of Appeal in Hornal v. Neuburger(34); and again very recently of the House of Lords in Reg. v. Home Secretary ex parte ex parte Khawaja(31). I can only say that I find the latter approach the more persuasive. I think that the trial judge was right to apply this standard, and I can see no grounds whatever for challenging any of his factual findings so based.

Interest

154. Upon this it is sufficient to say that I agree with the reasoning and conclusions of Cons, J.A.

(D.S. Hunter)
Judge of the High Court

Hon. Cons J.A.

155. This judgment is handed down in accordance with Order 42 Rule 5A of the Rules of the Supreme Court; the appeal of the Plaintiff is dismissed; the cross appeal of the lst Defendant is allowed; in the court below the 1st Defendant was ordered to pay part of plaintiff's costs, and it may be that counsel wishes to argue for a variation of that order, in which case we shall be pleased to hear him in due course; subject to that we make an ordernisi that the 1st, 2nd and 3rd Defendants are to have their costs in this court.

(D. Cons.)
Justice of Appeal

Representation:

R. Yorke, Q.C., C. Ching, Q.C. & R. Tang (Therese P.F. Chow & Co.) for the Plaintiff

Andrew Morritt, Q.C., Oswald Cheung, Q.C. & A. Li (Deacons) for the 1st Defendant

D.Chang, Q.C. & Raymond Faulkner . (D.W. Ling & Co.) for 2nd Defendant

Leonard Bromley, Q.C., K. Bokhary, Q.C. & Miss Josephine pinto (F.Zimmern & Co.) for the 3rd Defendant



[1] [1918] A.C.777

[2] [1933] A.C. 51

[3] [1977] A.C. 239 at page 253

[4] [1950] 6 L.D.B. 161

[5] [1393] 2 Q.B. 177 at 181

[6] [1957] A.C. 555 at 576

[7] 130 E.R. 764 (1827) 4 Bing 253

[8] [1921] 3 K.B. 110

[9] [1932] 1 KB 371 at 381

[10] [1968] 1 W.L.R. 1555

[11] [1972] 1 W.L.R. 602

[12] [1975] 2 N.Z.L.R. 7

[13] [1909] 2 K.B. 1010

[14] [1978] A.C. 728 at 751

[15] [1945] 17 C.L.R. 256 at 261

[16] [1970] A.C. 1004

[17] [1883] 11 Q.B.D. 327

[18] [1962] 2 Lloyds List Reports 80 at 87

[19] [1982] H.K.L.R. 273

[20] 117 U.S. 96

[21] [1971] 27 D.L.R. 81

[22] [1981] 122 D.L.R. 32. 519 at 532

[23] [1913] 208 N.Y. 21

[24] [1943] 42 N.Y.S. (2nd) 286

[25] [1982] H.K.L.R. 215

[26] [1980] H.K.L.R. 815 at 830

[27] [1945] K.B. 189

[28] [1952] A.C. 192

[29] [1983] 1 W.L.R. 964 at 970

[30] [1983] 3 W.L.R. 163

[31] R. v. The Home Secretary Ex. parte Khawaja, [1983] 2 W.L.R. 321

[32] [1966] A.C. 643 at 669

[33] [1951] Probate 35 

[34] [1957] 1 Q.B. 247

[35] [1972] 2 L.L.R. 187 at 192

[36] 1939] 3 All E.R. 952

[37] (28 A.I.R. 1941 PC. 593

[38] [1855] X Moore 502 at 531

[39] [1975] 1 Q.B. 654

[40] 5 H.L.C. 389, 10 E.R. 950

[41] 21 Q,B.D. 160

[42] [1906] A.C. 559

[43] [1906] 11 Commercial Cases 255

[44] [1913] 108 LT 728

[45] [1961] A.C. 388

[46] [1981] Q.B. 625

[47] [1983] 3 W.L.R. 769

[48] [1920] A.C. 956 at 986

[49] [1983] A.C. 520 at 545

[50] [1889] 14 P.D. 64 at 68

[51] [1918] 1 K.B. 592 at 605

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[53] [1978] A.L.J.R. 20 at 26

[54] [1982] 3 W.L.R. 366

[55] [1926] 135 L.T. 358

[56] [1902] 1 K.B. 612 at 616

[57] [1951] A.C. 489 at 503

[58] [1959] 1 Q.B. 55

[59] [1964] A.C. 465

[60] [1979] 2 L.L.R. 391

[61] [1971] Ch. 949

[62] [1983] 3 All E.R. 54 at 60

[63] [1982] 1 W.L.R. 1410

[64] [1972] 1 Q.B. 373 at 394

[65] [1976] Q.B. 801

[66] [1979] Ch. 384

[67] [1978] 1 Q.B. 791

[68] [1973] 3 All E.R. 146 at 150

[69] [1932] A.C. 562 at 610

[70] [1951] A.C. at page 611

[71] [1955] 286 P. (2d) 353

[72] 208 N.Y. 218

[73] [1981] 55 A.L.J.R. 574

[74] [1969] 1A.C. 191

[75]

[76] 23 Q.B.D. 243 at 263

[77]

[78] [1921] 38 T.L.R. 134 at 143

[79] [1934] 50 T.L.R. 465

[80] 33 L.J.Q.B. 43