IN Relfo Ltd. (in liquidation) v Varsani [2014] EWCA Civ 360, the defendant (Bhimji Varsani) had received US$878,469.35 which allegedly represented £500,000 of Relfo's funds that its director (Gorecia) had improperly caused to be paid away, without authority and in breach of his duties as director. Relfo's liquidator subsequently sued the defendant to recover what it had lost. Though Relfo's proprietary claim failed, the Court of Appeal held, affirming Sales J.'s judgment, that Relfo had a personal claim for the sums received by the defendant on two bases: (1) a cause of action for knowing receipt; and (2) a cause of action in unjust enrichment. In so holding, the Court faced several questions of substantial wider significance.