Board of Inland Revenue v Haddock: A. P. Herbert's Negotiable Cow

Board of Inland Revenue v Haddock, better known as "the negotiable cow", is a famous legal case that never happened. It was invented by the English humorist, novelist and later Member of Parliament A. P. Herbert as one of his "Misleading Cases": comic, mock-serious law reports, most of which first appeared in the magazine Punch. In the story, a taxpayer named Albert Haddock, angry about his income tax, pays his bill by leading a large white cow into the tax office with a cheque stencilled on its side.

The case was first collected in book form in More Misleading Cases in the Common Law (Methuen, 1930). It was so neatly written in the style of a genuine law report that it took on a life of its own. It has been retold as if it were true, reported in at least one newspaper as fact, mentioned by real judges, and circulated for decades as an urban legend about cheques written on strange objects.

This article explains what Herbert actually wrote, what is fiction and what is fact, who Herbert was, how his Misleading Cases worked as satire and as a tool for law reform, and how the negotiable cow escaped into real life.

The essential point: there was no real case. No court ever heard Board of Inland Revenue v Haddock. Albert Haddock, the Collector of Taxes, Constable Boot, Sir Joshua Hoot KC and the judges are all characters invented by Herbert.

At a glance

What a "Misleading Case" is

Fake law reports in a humour magazine

Lawyers learn the law partly by reading law reports: published accounts of court cases, giving the facts, the arguments and the judge's reasoning. Herbert, who had studied law at Oxford and been called to the Bar, wrote parodies of these reports. Each one takes a real feature of English law, pushes it to an absurd extreme and has a judge reason his way, with complete solemnity, to a ridiculous or pointed conclusion.

The joke works on two levels. For general readers the cases are funny stories. For lawyers they are expert parodies, full of invented precedents, mock-Latin maxims and footnotes. The 1927 collection opens with a note that "these cases (with one exception) were recorded in the legal columns of Punch."

According to David Langford's bibliography of the cases, Herbert later wrote in his autobiography, A.P.H.: His Life and Times (1970): "The first Case – I think it was The Reasonable Man – Fardell v. Potts – appeared in Punch in 1924." Langford dates that first appearance to 9 July 1924. Herbert also wrote: "Albert Haddock made his first public appearance, in Punch, in 1924. I have always understood that I invented him: but he has made some disturbing escapes into real life."

The collections

Herbert gathered the cases in a series of books. The table below follows Langford's catalogue.

In the introduction to Wigs at Work Herbert estimated that he had written about 150 Misleading Cases in all, which suggests some were never collected. Several cases were revised and renamed when they went into Uncommon Law. Board of Inland Revenue v. Haddock: What is a Cheque? became "The Negotiable Cow."

A Lord Chief Justice joins the joke

The first collection carried an introduction by Lord Hewart, then Lord Chief Justice of England. Hewart entered fully into the spirit of the book. He suggested Herbert may have decided "that it is more agreeable on the whole to suffer an 'Introduction' than to be committed for contempt of Court," and praised "the neatness, the deftness, and the dexterity—the sense, the satire, and the scholarship—of these criticisms wrapped in the pleasant disguise of parody." He predicted that the cases "will be read and quoted when Bullen and Leake and the Law Reports are obsolete," Bullen and Leake being a standard textbook of legal pleading.

That a senior judge wrote the introduction tells you something about the cases. They were satire, but satire written from inside the legal world, and the legal profession enjoyed them.

Who was A. P. Herbert?

Early life and war

Alan Patrick Herbert was born on 24 September 1890 at Ashtead in Surrey. His mother's father was Sir Charles Jasper Selwyn, a Lord Justice of Appeal, so he had a judge in the family. He was educated at Winchester College and New College, Oxford, where he switched from Classics to Law and graduated in 1914 with a first in jurisprudence. His first contribution to Punch, a set of verses called "Stones of Venus", was printed on 24 August 1910, while he was still a student.

In September 1914 he enlisted as an ordinary seaman in the Royal Naval Volunteer Reserve and was commissioned into the Royal Naval Division. He served at Gallipoli in 1915 and later on the Western Front, where he became his battalion's adjutant before being wounded in 1917. He drew on the experience for his first novel, The Secret Battle (1919).

Called to the Bar, but never a practising lawyer

Herbert was called to the Bar by the Inner Temple in 1919, but he never practised law. He later said he was "forever sorry" not to be "of the proud and faithful brotherhood who serve the laws of England." Instead he made his living as a writer. In January 1924 the editor of Punch, Owen Seaman, invited him to join the magazine's staff, and the Misleading Cases began that year.

He also wrote novels, plays, light verse and the words for musical shows. His musical Bless the Bride, written for the producer Charles B. Cochran, opened at the Adelphi Theatre on 26 April 1947 and ran for two and a quarter years.

The real lawsuit against Parliament's kitchen

Herbert's interest in law was not only literary. In 1934 he took the Kitchen Committee of the House of Commons to court for selling liquor without a licence. Lord Hewart, the same Lord Chief Justice who had introduced Herbert's book, ruled that the court would not hear the complaint because the matter fell within parliamentary privilege. Herbert later turned the House of Commons Kitchen Committee into a fictional litigant against Haddock, as described below.

Member of Parliament and law reformer

In 1935 Herbert was elected as an independent Member of Parliament for Oxford University, one of the university seats that then existed. He held it until those seats were abolished in 1950. His election address, about 5,000 words long, included the statement: "Agriculture: I know nothing about agriculture."

His maiden speech, on 4 December 1935, defended the right of ordinary MPs to introduce their own bills. Winston Churchill reportedly told him: "Call that a maiden speech? It was a brazen hussy of a speech. Never did such a painted lady of a speech parade itself before a modest Parliament."

His most important achievement in Parliament was divorce reform. His 1934 novel Holy Deadlock had attacked the absurdities of English divorce law, which in practice forced unhappy couples to fake evidence of adultery. As an MP he steered a private member's bill through Parliament, which became the Matrimonial Causes Act 1937. It allowed divorce on grounds other than adultery, although some of the odd rules Herbert attacked survived until the Divorce Reform Act 1969.

He also campaigned against the Entertainments Duty, a tax introduced as a "temporary, war-time tax" in 1916, and for the rights of private members. During the Second World War he served on the Thames in his own boat, the Water Gipsy, as a petty officer, and was the only non-commissioned officer sitting in the House of Commons. He was knighted in 1945 and died on 11 November 1971. The Times said he had done "more than any man of his day to add to the gaiety of the nation."

Albert Haddock

Albert Haddock is the hero of many Misleading Cases. He is a private citizen with a strong sense of his own rights, a sharp legal mind and an unlimited willingness to go to court. His adventures usually begin with him doing something unusual but, as he argues, not actually illegal. He then defends himself with impeccable logic, exposing how arbitrary or illogical a real rule of law is.

The Wikipedia article on Uncommon Law describes Haddock as "representing Herbert's point of view." Through him Herbert attacked, in Langford's and others' summaries, the law on copyright, divorce, libel, liquor licensing, the police's use of agents provocateurs and rules of the road. A recurring police officer, Constable Boot, often appears as the over-eager arm of the law.

The courts in the stories are equally invented, staffed by judges with names such as Lord Mildew and Mr Justice Swallow, and barristers such as Sir Joshua Hoot KC and Sir Ethelred Rutt. Judges in the stories cite non-existent precedents, like "Moocat v. Radley (1883)" and "Williams v. Dogbody (1841)", in perfect legal citation style.

The case of the negotiable cow

The account below follows the text printed in More Misleading Cases in the Common Law (1930), where the case appears as number XVI under the heading "Board of Inland Revenue v. Haddock; Rex v. Haddock: What is a Cheque?" Herbert revised some cases for Uncommon Law, so details differ between editions. Wikipedia's summary, based on the 1935 omnibus, names the judge as Sir Basil String; in the 1930 text the judgment is given by "The Stipendiary", that is, a paid magistrate, at Bow Street.

The opening

The report begins mid-hearing, with laughter in court. Someone has asked whether the cow was "crossed", in the banking sense of a crossed cheque, and the reply comes: "No, your worship, it was an open cow." The reporter notes: "These and similar passages provoked laughter at Bow Street to-day when the Negotiable Cow case was concluded."

The facts, as the prosecution tells them

Sir Joshua Hoot, K.C., appearing for the Public Prosecutor, explains that two summonses are being heard together. Mr Albert Haddock, he says, has for many months been "unable to establish harmonious relations between himself and the Collector of Taxes." The Collector maintains that Haddock "should make over a large part of his earnings to the Government." Haddock replies "that the proportion demanded is excessive, in view of the inadequate services or consideration which he himself has received from that Government." After "an exchange of endearing letters, telephone calls, and even cheques," the sum demanded was reduced to fifty-seven pounds.

Then, on 31 May, the Collector "was diverted from his respectable labours by the apparition of a noisy crowd outside his windows." The crowd had been attracted by Haddock, "who was leading a large white cow of malevolent aspect." On the back and sides of the cow were stencilled in red ink the words of a cheque, made out to the London and Literary Bank:

"Pay the Collector of Taxes, who is no gentleman, or Order, the sum of fifty-seven pounds (and may he rot)."

It was signed "Albert Haddock" and marked £57/0/0.

Haddock "conducted the cow into the Collector's office, tendered it to the Collector in payment of income-tax and demanded a receipt."

The stamp, the endorsement and the arrest

The magistrate asks: "Did the cow bear the statutory stamp?" Sir Joshua replies: "Yes, your worship, a twopenny stamp was affixed to the dexter horn." ("Dexter" is the heraldic word for right.)

The Collector declined the cow, "objecting that it would be difficult or even impossible to pay the cow into his bank." Haddock, who "maintained the friendliest demeanour," pointed out that the Collector "could endorse the cow to any third party to whom he owed money, adding that there must be many persons in that position."

The Collector then tried to endorse the cheque. "Where?" asks the magistrate. "On the back of the cheque, your worship, that is to say, on the abdomen of the cow. The cow, however, appeared to resent endorsement and adopted a menacing posture." The Collector gave up and refused the cheque. Haddock led the cow away "and was arrested in Trafalgar Square for causing an obstruction." He was also summoned by the Board of Inland Revenue for non-payment of income tax.

Haddock's defence

In the witness box Haddock argued that he had tendered a cheque, and "if the Commissioners did not like his cheque they could do the other thing." A cheque, he said, "was only an order to a bank to pay money," and "there was nothing in statute or customary law to say that that order must be written on a piece of paper of specified dimensions." He continued:

"He himself had drawn cheques on the backs of menus, on napkins, on handkerchiefs, on the labels of wine-bottles; all these cheques had been duly honoured by his bank and passed through the Bankers' Clearing House. He could see no distinction in law between a cheque written on a napkin and a cheque written on a cow."

He added that there were funds in his bank "sufficient to meet the cow," and that "the Commissioners might not like the cow, but, the cow having been tendered, they were estopped from charging him with failure to pay." He cited three invented authorities, including "Spowers v. The Strand Magazine."

On the arrest, he said "it was a nice thing if in the heart of the commercial capital of the world a man could not convey a negotiable instrument down the street without being arrested." He had started proceedings against Constable Boot for false imprisonment.

Cross-examined about his motive, Haddock said he had no cheque forms available and had used "the only material to hand." He then admitted "that there might have been present in his mind a desire to make the Collector of Taxes ridiculous. But why not? There was no law against deriding the income-tax." A mock footnote cites Magna Carta: "Jus ridendi nulli negabimus", invented Latin meaning roughly "to no one will we deny the right to laugh", a parody of Magna Carta's real promise not to deny or delay justice.

The judgment

The magistrate finds entirely for Haddock, in a judgment that is partly a legal parody and partly a political rant. He describes Haddock as "a citizen who is unusual both in his clarity of mind and integrity of behaviour," and then attacks the income tax itself:

"No thinking man can regard those parts of the Finance Acts which govern the income-tax with anything but contempt."

He sets out a view that taxation should pay only for services the taxpayer receives, "the Police, the Navy, the Army, the public sewers, and so forth," and complains that the law now commands "Citizen A, who has earned money" simply to give it "to Citizens B, C, and D, who have not." This passage is Herbert speaking through his judge, and the Inland Revenue was one of his favourite targets: Haddock fights the tax authorities in several other cases. Readers should treat it as the opinion of a satirical character, not as legal reasoning.

He then turns to the cow. "Paper was not available, so he employed instead a favourite cow. Now, there can be nothing obscene, offensive, or derogatory in the presentation of a cow by one man to another." He notes that "payment in kind is the oldest form of payment," and that, as Haddock had told the court, Saxon law described cattle as viva pecunia, "living money." So, he concludes, "whether the cheque was valid or not, it was impossible to doubt the validity of the cow," and the Collector should at least have accepted the animal and credited its value. Echoing Haddock, he says that "an order to pay is an order to pay, whether it is made on the back of an envelope or the back of a cow." The tax summons is "adjourned sine die", meaning put off indefinitely.

On the obstruction charge he holds that Constable Boot did wrong: "It cannot be unlawful to conduct a cow through the London streets." Horses and motor cars appear in the streets without protest, and the cow is "invested (as I have shown) with all the dignity of a bill of exchange." If crowds gather "upon the apparition of Mr. Haddock with a promissory cow, then Constable Boot should arrest the people, not Mr. Haddock." The charge is dismissed, and the magistrate ends by saying that Haddock "has behaved throughout in the manner of a perfect knight, citizen, and taxpayer," and hoping Haddock wins his action against Constable Boot.

A note on the amount

Some retellings, including Wikipedia's, say the Collector demanded "£57 and 10 shillings." In the 1930 text the sum is reduced "to fifty-seven pounds," and the cow is marked "£57/0/0". Herbert's revisions for Uncommon Law may account for the difference. Either way, the amount is part of the fiction.

The legal jokes explained

Much of the humour depends on real banking and legal terms. Here is what they mean.

The story is clever because Haddock's argument is not completely silly. It is true that English statute defines a cheque as an "order in writing" without specifying paper. Banks have occasionally honoured cheques written on unusual materials. What the story does is take a technically open question and answer it in the most absurd direction possible, with full legal seriousness.

Would a cow-cheque be valid?

Herbert never claimed that his conclusions were correct law, and the case should not be relied on as legal advice. Banks set their own rules about the cheques they will accept, and in practice a bank is very unlikely to process a cow.

Real courts that have mentioned the case have treated it as a joke that helps make a point:

• Victor Chandeler International Ltd v Commissioners of Customs and Excise (1999). In this English High Court case about the meaning of "document" under the Betting and Gaming Duties Act 1981, Mr Justice Lightman said that a document "must be inanimate: neither a person nor A. P. Herbert's 'negotiable cow' can constitute a document." In other words, a real judge used the cow to illustrate what does not count as a document.
• Messing v Bank of America (2002 to 2003). In this case about a bank refusing to cash a cheque, the Maryland Court of Appeals opened its opinion by observing: "The circumstances which gave rise to the case before us are, in terms of its genesis, reminiscent of those described in the case of Board of Inland Revenue v. Haddock."

Real documents on strange surfaces

The negotiable cow has endured partly because real people have, now and then, written legal documents on odd materials. Wikipedia lists several examples:

• Wills on eggshells. In Hodson v Barnes (1926), a will written on an empty eggshell was rejected from probate.
• A will scratched on a tractor. A Canadian farmer, Cecil George Harris, trapped under his own tractor, scratched a will into its fender. The fender was accepted as his will and is displayed at the law library of the University of Saskatchewan College of Law, as reported in the university's On Campus News in 2009.
• Protest cheques. In the United Kingdom in the 1970s some taxpayers protested by writing cheques on large rigid boards, about 3 feet by 1½ feet, according to a Guardian reader's answer cited by Wikipedia.
• Divorce on a cow's horn. In Jewish law a get, the document of divorce, may be written on any durable material, including a cow's horn. The Mishnah (Gittin 2:3) discusses this, and if the horn is still attached to the cow, the whole cow must be given.

These examples are real, but they are not evidence that Herbert's story happened. They show why readers found it plausible.

From satire to urban legend

"A Check Can Be Written on a Cow"

The negotiable cow was so realistic in form that it was sometimes mistaken for a real case. On 31 July 1967 the Memphis Press-Scimitar, a Tennessee newspaper, ran a United Press International item from New York under the headline "A Check Can Be Written on a Cow," treating the case as factual. This was noted in the introduction to a later edition of Uncommon Law.

Herbert was well aware of his creations' tendency to escape. His remark that Haddock "has made some disturbing escapes into real life" refers to this. According to Langford, Herbert's new introduction to the 1969 edition of Uncommon Law mentions another case from 1967 that Punch refused "because they had recently made a resolution to have no more jokes about mini-skirts." It was printed instead in the Evening Standard and "reported as straight news in America, France and Italy."

How the legend spread

The story has the classic features of an urban legend:

• A plausible frame. It is written exactly like a law report, with names, dates, counsel and citations.
• A grain of truth. Cheques really are defined as written orders without reference to paper, and odd cheques really have been cashed.
• A satisfying moral. The little man defeats the tax office with wit.
• A memorable image. A cow with a cheque painted on its side is hard to forget.

Over time the story was repeated without its source, sometimes told as having happened to a farmer in America or as a lesson in banking law. Wikipedia classifies it under both "Fictional lawsuits" and "Urban legends."

Fact or fiction: a summary

Other Misleading Cases

The negotiable cow is the best known, but it is one of more than a hundred cases. Several others help show how the series worked.

Fardell v Potts: The Reasonable Man

The first case, from 1924, is a classic of legal humour and still quoted by law teachers. A Mrs Fardell, steering a motor launch on the Thames, collides with a man in a punt, who falls in and catches cold. Her lawyers argue that the law judges negligence by the standard of "the reasonable man," and that in all the case law "there is no single mention of a reasonable woman." Lord Justice Morrow's judgment includes a long, comic portrait of the reasonable man as someone "who invariably looks where he is going," "who never swears, gambles, or loses his temper," and who is, "devoid, in short, of any human weakness, with not one single saving vice," a figure Herbert calls "this excellent but odious character." Beneath the comedy is a real point about the law's assumptions and the absence of women from its imagined standard.

Rex v Haddock: Is It a Free Country?

Haddock jumps off Hammersmith Bridge into the Thames for a bet and is charged with a string of offences. His general defence is that "this was a free country and a man can do what he likes if he does nobody any harm." The court rejects this outright:

"It cannot be too clearly understood that this is not a free country, and it will be an evil day for the legal profession when it is. The citizens of London must realize that there is almost nothing they are allowed to do."

And later: "People must not do things for fun. We are not here for fun. There is no reference to fun in any Act of Parliament." The appeal fails. The satire is aimed at the growth of regulation and at a legal system that treats the absence of a rule as suspicious.

Rex v Haddock: Is a Golfer a Gentleman?

Haddock is charged under the Profane Oaths Act 1745 for swearing on a Cornish golf course: more than four hundred oaths, uttered while hacking his ball out of a sea inlet called the Chasm at the 12th hole at Mullion. The Act really did set different fines by social class: one shilling for labourers, soldiers and seamen, two shillings for other people below the rank of gentleman, and five shillings for gentlemen. The prosecution asks for the gentleman's rate. Haddock argues that while playing golf he is not a gentleman. The magistrate, who admits "I am a golf-player myself," accepts that golf is a provocation so extreme that "the habitually gentle man may become in a bunker a violent, unmannerly oaf," and in the 1927 text finds he cannot punish Haddock at all.

Tinrib, Rumble and Others v The King and Queen: Fish Royal

A dead whale washes up at the Dorset village of Pudding Magna. Under an old rule, whales are "fish royal" and belong to the Crown, so the Crown should remove it. The Ministry of Agriculture and Fisheries points out that a whale is a mammal, not a fish. Meanwhile the whale rots. Lord Hewart's introduction to the first collection singles out this case, adding that "the tail of the animal, by the way, seems to appertain to the Queen Consort."

Other tax cases

Herbert returned to the Inland Revenue several times. Langford's list includes "Haddock and Others v. Board of Inland Revenue: Wear and Tear" (Punch, 30 July 1930), "Board of Inland Revenue v. Haddock: Why is the House of Lords?" (Punch, 9 August 1933) and "Board of Inland Revenue v. Haddock: The Judges' Reply", new in Uncommon Law. Wikipedia reports that one of these Haddock tax cases was cited in a House of Lords debate on 14 July 2004. In that story, it says, Haddock argued that while judges' salaries had been cut during a financial emergency, they could not hear tax cases because they had a personal interest in the outcome.

The Egg of Exchange

A later case continues the cheque theme. "House of Commons (Kitchen Committee) v. Haddock: The Egg of Exchange", dated by Langford to 16 February 1949 and collected in Codd's Last Case (1952), concerns a cheque written on an egg. According to Wikipedia's summary, the question is whether such a cheque could be paid into a bank, given the risk of the egg breaking or going bad, and it is suggested that the cheque could be boiled. The fictional plaintiff is a pointed choice: the Kitchen Committee was the real body Herbert had sued in 1934.

Haddock as a company

In another case summarised by Wikipedia, Haddock turns himself into a limited company so that his copyright will never expire, since a company does not die. Every time the prosecution calls him "Mr. Haddock," he corrects them: "You mean the Managing Director." The case satirises the different treatment of people and companies in law.

Satire as law reform

Herbert's Misleading Cases were more than jokes. Wikipedia's article on Uncommon Law describes them as "vehicles for law reform": through them Herbert "aired, initiated and sustained debate" on copyright, divorce, defamation, liquor licensing, police methods and road rules.

The method was simple and effective. A real rule would be stated accurately. A sympathetic citizen would run into it. A judge would apply it with perfect logic to an absurd result. Readers, including lawyers and politicians, would laugh and then ask whether the rule made sense.

The connection with Herbert's real political work is clear:

His tax satire in the negotiable cow should be seen in the same light. The judge's speech against income tax is exaggerated for comic effect, but it expressed a real frustration that Herbert shared, and it uses humour to make readers think about what taxation is for.

The BBC television series

The BBC adapted the cases for television as A. P. Herbert's Misleading Cases, made in three series in 1967, 1968 and 1971, totalling 19 episodes. Roy Dotrice played Albert Haddock and Alastair Sim played the judge, Mr Justice Swallow, whose task was to untangle Haddock's logic. "The Negotiable Cow" opened the first series in 1967.

Popularity and how to read the cases today

The Misleading Cases sold well from the start. The first collection was published in the autumn of 1927 and, according to its own printing history, was reprinted in November 1927, December 1927 and March 1928. A first American edition, published in New York by G. P. Putnam's Sons, followed in 1930, the same year More Misleading Cases appeared in London.

A few points help a modern reader:

• Every case is invented, including the parties, the judges and the precedents they cite. The statutes, however, are often real, and part of the fun is spotting where the real law ends and the invention begins.
• The cases are products of their time. They were written between the 1920s and the 1960s and reflect English society and politics of those decades. Some jokes depend on rules that have since changed, and some attitudes have dated.
• Editions differ. Herbert revised and retitled cases for Uncommon Law, so quotations from one edition may not match another. This article quotes the 1927 and 1930 texts.
• The judges' opinions are characters' opinions. Herbert often gives his judges extreme views for comic effect. They should not be read as statements of the law, then or now.

Why the negotiable cow endures

Nearly a century after it first appeared, the negotiable cow is still retold. Several reasons stand out:

1. It is genuinely funny. The image of a tax official trying to sign a cow's stomach while the cow takes offence works for any reader.
2. It is legally clever. The joke turns on a real gap in the definition of a cheque, so lawyers enjoy it as much as anyone.
3. It speaks to a universal feeling. Few people enjoy paying tax, and Haddock's polite, insolent defiance is satisfying.
4. Its form is convincing. It reads exactly like a real report, which is why it slipped so easily into the stock of urban legends.
5. It has been taken up by real courts. Judges who mention it keep it in circulation among lawyers.

Key points

• Board of Inland Revenue v Haddock is a fictional case by A. P. Herbert, first collected in More Misleading Cases in the Common Law (1930) and later titled "The Negotiable Cow."
• In the story Albert Haddock pays £57 of income tax with a cheque stencilled on a white cow; the tax office refuses it, Haddock is arrested in Trafalgar Square, and a sympathetic magistrate finds for him on both charges.
• The joke rests on the real legal definition of a cheque as a written order, with no requirement that it be on paper.
• Herbert (1890 to 1971) was a Punch writer, novelist, independent MP for Oxford University from 1935 to 1950 and a successful law reformer, best known for the Matrimonial Causes Act 1937.
• The case is satire, but it has been mistaken for fact, reported as true by a US newspaper in 1967 and mentioned by real judges in England and Maryland.

Sources

• Board of Inland Revenue v Haddock (Wikipedia)
• More Misleading Cases in the Common Law, A. P. Herbert, Methuen 1930 (Internet Archive)
• Misleading Cases in the Common Law, A. P. Herbert, with an introduction by Lord Hewart (Internet Archive)
• A.P. Herbert's Misleading Cases: bibliography by David Langford (Ansible)
• Uncommon Law (Wikipedia)
• A. P. Herbert (Wikipedia)
• Bills of Exchange Act 1882, section 3 (legislation.gov.uk)
• Bills of Exchange Act 1882, section 73 (legislation.gov.uk)
• [Victor Chandeler International Ltd v Commissioners of Customs and Excise [1999] EWHC 214 (Ch) (BAILII)](https://www.bailii.org/ew/cases/EWHC/Ch/1999/214.html)
• Matrimonial Causes Act 1937 (Wikipedia)