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Lloyd's Maritime and Commercial Law Quarterly

OBLIGATIONS AND PROPERTY IN EQUITY: LISTER v. STUBBS IN THE LIMELIGHT

A.-G. for Hong Kong v. Reid

The purpose of this short comment is only to give readers notice that the Judicial Committee of the Privy Council seems likely to have the opportunity this year to review one of the most disputed issues in equity. The narrow question is whether, if a recipient of a bribe makes a successful investment, the victim-principal can claim a proprietary interest in the assets bought or is, as was held in Lister v. Stubbs,1 confined to a personal claim for the amount of the bribe. An intermediate position is not to be ruled out, namely that the recipient is accountable and as such personally liable for the profits made through the bribe even though the victim-principal can claim no property in specific assets purchased with it. The wider question is

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