Lipkin Gorman v Karpnale Ltd
English case
Lipkin Gorman v Karpnale Ltd [1988] UKHL 12 (6 June 1991) is a foundational English unjust enrichment case. The House of Lords unanimously established that the basis of an action for money had and received is the principle of unjust enrichment, and that an award of restitution is subject to a defence of change of position. This secured unjust enrichment as the third pillar in English law of the law of obligations, along with contract and tort. It has been called a landmark decision.
Although the case is most famous for the transformative judgment handed down by the House of Lords in relation to restitution and unjust enrichment, the decision of the Court of Appeal is also an important banking law decision in its own right, setting out key principles relating to the duty of care owed by bankers to their customers. There was no appeal against that part of the decision to the House of Lords.
Facts
Norman Barry Cass was a partner in a solicitors' firm called Lipkin Gorman. He was an authorised signatory at the firm’s Lloyds Bank account. He took out £220,000 and used it for gambling at the Playboy Club, 45 Park Lane, London which was owned by Karpnale Ltd. Between March and November 1980, the club won £154,695 of the stolen money (the rest paid back to Mr Cass in ‘winnings’).
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