Johnathan Wong Futt Po v Koh Chin Wei (WA-22NCvC-367-07/2022)

KOH CHIN WEI [NO K/P: 860107-14-5753] …DEFENDAN PERTAMA

MBEST TRADING ENTERPRISE SDN. BHD. [COMPANY NO.: 1408823-W] …DEFENDAN KEDUA GROUNDS OF JUDGMENT Introduction [1] A Lamborghini Huracan is an Italian sports car. It transpired during the trial of this action that cryptocurrency was purportedly used to pay the 2nd Defendant for the purchase of a Lamborghini Huracan as well as for a Bentley Continental and a Ferrari 488 GTB. The Plaintiff’s testimony was that he and his partners decided to buy a ‘super car’ each after receiving a windfall of RM25 million in “consultancy fees” paid to them in the form of cryptocurrency. Only the Lamborghini, bearing registration number TG18 (“the said Lamborghini”) was the subject matter of this action. 16/11/2024 17:00:45 WA-22NCvC-367-07/2022 Kand. 112 [2] Had the Plaintiff been able to adduce evidence of having paid for the said Lamborghini, I would have had no hesitation to allow the Plaintiff’s claim and to dismiss the Defendants’ respective counterclaim – which was premised on the existence of a tripartite oral agreement for payment for the said Lamborghini to be made subsequently by the Plaintiff. However, during the trial, the Plaintiff adduced no evidence of payment for the said Lamborghini, and instead he gave an unsubstantiated and incoherent explanation. [3] After careful evaluation of the evidence and submissions of both sides, based on the Sale of Goods Act 1957, I decided to allow the Plaintiff’s prayer against the 2nd Defendant for specific performance to transfer the said Lamborghini to his name, and to dismiss his claim for General Damages and Special Damages against both Defendants. [4] As for the 2nd Defendant’s Counter-claim, only its prayers for judgment of RM1,050,000.00 being the purchase price for the said Lamborghini and interest on the judgment sum were allowed. [5] My reasons for allowing only part of the Plaintiff’s claim and part of the 2nd Defendant’s Counterclaim, and with each party to bear own costs, are as explained below. The Plaintiff’s Claim [6] The Plaintiff’s cause of action against the 2nd Defendant was based on a “Trust Deed” dated 9th November 2021 wherein the 2nd Defendant (MBest Trading Enterprise Sdn Bhd) had allegedly declared itself as trustee of the said Lamborghini for the Plaintiff as the beneficiary. [7] The Plaintiff sought General Damages, Special Damages of RM170,000.00 and an order for specific performance to compel the 2nd Defendant to transfer ownership of the said Lamborghini to him. [8] The said sum of RM170,000 was pleaded as Special Damages caused by the action of the 2nd Defendant in towing away the said Lamborghini on 6th May 2022 from his residence at TAR Villa, Jalan Genting Klang, Wangsa Maju, Kuala Lumpur. The Plaintiff’s evidence was that his bodyguard could not stop it from happening and police reports were lodged. Though the Plaintiff was able to regain possession of the car from the Police Station within a few hours of that incident, he pleaded that he suffered a loss of RM170,000.00 due to damage caused to the car. The Defendants’ Defence & Counterclaim [9] The Defendants filed a Defence and Counterclaim against the Plaintiff. The Defendants’ Defence narrated that the Plaintiff was introduced to the Defendants by one Tan Chee Hao (DW-2) who called himself “Marco Tan” as a potential customer looking for a Lamborghini. [10] The Defendants further pleaded that the Plaintiff wanted to buy the said Lamborghini but lacked the money to pay the agreed price of RM1,050,000.00. According to them, the Plaintiff requested Marco Tan, who was then buying a Ferrari 488 GTB for himself, to advance payment of RM1,050,000.00 to pay for the said Lamborghini. It was pleaded that the Plaintiff promised to pay the said price to the 2nd Defendant by early GUAMAN NO.: WA-22NCvC-367-07/2022 2022, whereupon the 2nd Defendant was to refund the money to Marco Tan. This arrangement was pleaded as “the oral tripartite agreement” in the Defendants’ Defence. [11] In their Counterclaim, the 2nd Defendant sought a declaration that the Trust Deed dated 9th November 2021 was invalid and void, an order for the Plaintiff to hand-over possession of the said Lamborghini to the 2ndDefendant immediately, costs involved for the repossessing of the said Lamborghini to be paid by the Plaintiff to the 2nd Defendant, General Damages to be assessed in respect of loss of the use of the said Lamborghini, interest at a rate of 5% per annum on the judgment sum, and alternatively, judgment for the Plaintiff to pay a sum of RM1,050,000.00 to the 2nd Defendant being the purchase price of the said Lamborghini with interest at a rate of 5% per annum, General Damages to be assessed by the Court and costs. [12] It was also highlighted by the Defendants that the Plaintiff was a bankrupt at the material time. The Plaintiff’s Testimony [13] The Plaintiff’s witness statement basically repeated the contents of his Statement of Claim, relying on the “Trust Deed” in support of his claim against the Defendants. He adduced a Court Order dated 25th July 2022 which annulled the Adjudication Order and Receiving Order that made him a bankrupt in year 2014. He testified that the annulment was made after he paid his creditors in full, and he therefore took the stand that the said “Trust Deed” made between him and the 2nd Defendant is valid and enforceable. [14] Whilst under cross-examination, the Plaintiff’s answers were quite intriguing. He testified that he was business partners with Tan Chee Hao who called himself Marco Tan (DW-2) and one Bryant Tan and were providing “business consultancy” to their clients. According to him, a sum of cryptocurrency equivalent to the sum of RM25 million was paid by a client from China into Marco Tan’s E-Wallet. The RM25 million was, according to him, to be their fees to obtain a digital banking licence in Malaysia for that Chinese client. He appeared to use the words venture capitalist, digital banking and investment banking interchangeably, albeit incoherently. It appeared that he was not clear himself about the nature their “consultancy business”. Under cross-examination, he admitted that he and his partners failed to obtain any digital banking licence in Malaysia for that Chinese client but they did not refund the money. [15] Based on his oral evidence, instead of refunding the money to the client from China, Marco Tan kept the cryptocurrency equivalent to RM25 million and the trio headed for the showroom of the 2nd Defendant to buy sports cars! The Plaintiff testified that he chose the said Lamborghini while his two partners chose a Ferrari and a Bentley Continental respectively. He further narrated that the trio also helped a junior partner of theirs to buy a Nissan GTR. [16] It was also admitted by the Plaintiff that he was still an undischarged bankrupt in year 2021 and that he had used his wife’s name Sabrina Mickagnes Lee Yan Cheng to be a director in a company known as JW SAB & Partners Sdn Bhd to do business with Marco Tan (DW-2) and three others whom he named as “Mr. Bryant Tan, Mr. Eng Yan Shuo and Mr. Chiew Chak Meng”. No documentary evidence was adduced regarding this company that was not mentioned in his pleadings. It was all bare averments during cross-examination. The Plaintiff was also incoherent in stating that as he had used his wife’s name to be in JW SAB & Partners Sdn Bhd, he was entitled to received profits from the said company – as if he was a shareholder himself. [17] As for the Trust Deed, the Plaintiff answered under cross-examination that the 2nd Defendant was to hold the said Lamborghini on trust for him so that there would be no need for any transfer of the motor vehicle to take place for two years, the purpose of which was to avoid paying income tax. The 1st Defendant’s Testimony [18] The 1st Defendant (DW-1) was working for the 2nd Defendant which was selling sports cars. His evidence was as pleaded in the Defendants’ Amended Defence & Counterclaim. The narrative was that around August 2021, a man who called himself Marco Tan (DW-2) had agreed to buy a Ferrari from the 2nd Defendant. Marco Tan introduced the Plaintiff to the 1st Defendant because Plaintiff was interested in buying a sports car. The Plaintiff was shown the said Lamborghini and he agreed to buy it from the 2nd Defendant at a price of RM1,050,000.00. [19] The 1st Defendant further testified that the Plaintiff said that he did not have enough money at that time to buy the said Lamborghini and requested Marco Tan (DW-2) to help him make the payment first, and for the Plaintiff to pay the 2nd Defendant in early year 2022, whereupon the 2nd Defendant was to refund the money advanced by Marco Tan. This was the “tripartite oral agreement” mentioned above. [20] It was also the 1st Defendant’s evidence that he received payment in cryptocurrency of USDT 596,137.34 for the two cars but explained that he had subsequently refunded the money paid for the said Lamborghini to Marco Tan (DW-2) upon his request. The reason that he gave was that it was the “oral tripartite agreement”. As evidence of payment, he testified that the long string of alphabets and numbers was the code for the cryptocurrency transfer. He testified that he went through an intermediary whom he found on the internet to arrange the transfer of cryptocurrency. [21] The 1st Defendant, as witness for the 2nd Defendant, basically concluded that since the Plaintiff had failed to pay the 2nd Defendant for the said Lamborghini, he ought to be ordered to return the car and pay damages to the 2nd Defendant, or alternatively, to be ordered to pay the purchase price of RM1,050,000.00 together with interest from the date the said Lamborghini was handed over to the Plaintiff in September 2021. The Testimony of the Defendants’ 2nd witness Marco Tan (DW-2) [22] Marco Tan (DW-2) testified that he used his own E-Wallet account with address ox568D13B8Ae32fdB041FD3b73b73bD165a2a2eA2DE8 to transfer payment of USDT 596137.34 cryptocurrency for the purchase of both the said Lamborghini and the said Ferrari to an E-Wallet account with address 0x0430C237478Df94c6634D8552f9BD7eA10c5438A provided by the 1st Defendant. [23] It was also in Marco Tan’s evidence that he received a refund in cryptocurrency equivalent to RM1,050,000.00 from the Defendants. In other words, he was corroborating the Defendants’ evidence that the 2nd Defendant had not been paid the purchase price for the said Lamborghini purchased by the Plaintiff. [24] Marco Tan (DW-2) was also shown excerpts of Whatsapp messages from a group but his evidence was that he had changed his mobile phone and could not confirm the contents of those messages. [25] Though Marco Tan (DW-2) admitted that the Plaintiff was his business partner, he vehemently denied receiving the equivalent of RM25 million from any client from China. Analysis of the Evidence and Applicable Law [26] Both the Plaintiff and the Defendants in this case agreed that payment for the said Lamborghini and a Ferrari was made by Marco Tan (DW-2) to the 2nd Defendant by using cryptocurrency, and to be more specific, USDT 596,137.34. [27] Cryptocurrencies are digital assets. In Malaysia, cryptocurrencies are not illegal but not legal tender. The 1st Defendant, as a witness for the 2nd Defendant, testified that the 2nd Defendant did receive payment of cryptocurrency USDT 596,137.34 from Marco Tan (DW-2), being the total price for the said Lamborghini and a Ferrari sports car purchased by Marco Tan for himself. Even though cryptocurrency is not legal tender in Malaysia and the payment was not through a commercial bank, digital currencies could be considered as valuable consideration under the Contracts Act 1950. Contract law in Malaysia does not enquire into the adequacy of consideration, and therefore, theoretically a bullock cart could be the consideration in exchange for a Lamborghini sports car, and likewise digital assets could be used to pay for goods if the seller is willing to accept it as valuable consideration. That is the fundamental rule of freedom of contract, subject to the provisions of Sections 25 to 31 of the Contracts Act 1950 which render agreements, that run afoul of those provisions, void. [28] For the purpose of curbing money laundering, the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (“AMLA”) included digital assets in its definition of “proceeds of unlawful activity” by defining it as “assets of every kind, whether corporeal or incorporeal… tangible or intangible, however acquired…”. [29] Though the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities (Amendment to the First & Second Schedule) Order 2017 had designated the operators of digital assets exchanges, i.e. those that offer services of converting digital currency into fiat money, fiat money into digital currency and digital currency into other types of digital currency, as “reporting institutions” under AMLA, it is an inherently formidable task to enforce the law in this area because such transactions could be conducted online without going through any licensed bank in Malaysia. There is a stark contrast with the traditional mode of payment for sale of goods in Malaysia which has been the currency of Malaysia, i.e. Ringgit Malaysia, issued by Bank Negara Malaysia our central bank, recognised by our law to be legal tender for the value stated. For international trade, foreign currencies have been used but it had always been the currency of a sovereign state. Taking the facts of this case as an example, if not for the dispute between the Plaintiff and the 2nd Defendant ending up as a civil suit in this Court, the sale of those two cars in September 2021 which were conducted by way of a cryptocurrency – by transferring USDT 596,137.34 as payment for two cars – would have remained unknown. No stamp duty or sales tax could be collected by the government for the transaction because it was hidden from Inland Revenue Board and Customs and Excise Department. [30] An undeniable feature of using cryptocurrencies, whether legally or otherwise, is the anonymity that they provide to the users. However, anonymity in the cryptocurrency world makes the transactions almost unverifiable. There was no name of payer or payee, just a long string of alphabets and numbers as stated in Marco Tan (DW-2)’s evidence, as follows: [31] The 1st Defendant’s evidence that the 2nd Defendant had repaid the price of the said Lamborghini to Marco Tan (DW-2) was corroborated by DW-2 who acknowledged receipt in his witness statement: [32] Now, the Plaintiff’s case was that he did pay the 2nd Defendant for the said Lamborghini through Marco Tan (DW-2 Tan Chee Hao). Since Marco Tan (DW-2) had denied the Plaintiff’s allegations, my finding must depend on the evidence adduced by the Plaintiff. How much money was Marco Tan allegedly keeping for the Plaintiff? The Plaintiff adduced no evidence whatsoever to prove that Marco Tan was allegedly holding his “share of profits” and was utilising part of it to pay for the said Lamborghini on his behalf. The Plaintiff also had no evidence to prove their “consultancy business” that allegedly convinced a gullible businessman from China to pay RM25 million to Marco Tan. [33] Further, the Plaintiff admitted under cross-examination that the digital banking licence never materialised, and therefore he had no banking licence to adduce in court to prove his allegations. With respect, this so-called “business consultancy” that allegedly enabled the Plaintiff and his partners to convince a client from China to pay RM25 million as consultancy fees sounded highly dubious – as it was upon their promise to obtain a digital banking licence for that businessman in Malaysia. Even assuming for a moment that there was such a transaction leading to the equivalent of RM25 million in crypto currency being paid to Marco Tan by a client from China, there was no evidence of the Plaintiff’s right to a share of the loot. [34] Upon Marco Tan (DW-2) denying under oath that he did not receive RM25 million as alleged by the Plaintiff and in the absence of any documentary evidence adduced by the Plaintiff, I had to find that the Plaintiff’s allegations were unproven and also unverifiable. [35] As for the “Trust Deed”, the Plaintiff testified that it was purportedly created for the purpose of avoiding income tax. His testimony under cross-examination was as follows: [36] The Plaintiff’s purpose for evasion of income tax was reconfirmed in his own words under further cross-examination during the trial, as follows: [37] In view of the Plaintiff’s own admission that the Trust Deed was created for the intention of evading income tax, should this Court lend a hand to the Plaintiff to enforce it? The law that empowers the courts to strike down sham instruments had been expounded and applied in numerous cases. In Yogananthy a/p Thambaiya v. Harta Pusaka Idris bin Osman [2020] 5 MLJ 455, the Federal Court, clarified the situations that would justify a finding that a document is a sham. The relevant passages are as follows: “[34] It had been observed that the policy considerations that underpin the concept of sham are the protection of the rule of law, to prevent abuse of fundamental legal principles and the prevention of evasion of statutes, among others. It was also commented that the Snook case had narrowed down the test for sham. … Indeed, on the authority of the case of Sri Kelangkota-Rakan Engineering JV Sdn Bhd & Ors v Arab Malaysian Prima Realty Sdn Bhd & Ors [2001] 1 MLJ 324, the courts are entitled to go behind the impugned agreement or transaction to ascertain the true nature of such agreement or transaction. In the case of Lori (M) Bhd (interim receiver) v Arab-Malaysian Finance Bhd [1999] 3 MLJ 81; [1999] 2 CLJ 997, it was there observed by our apex court that in other common law countries, courts were slow to declare commercial contracts as void on ground of illegality, but having said that if the circumstances so warrant, the courts would not shy away, from doing what would be in accord with what the law expects to be done, as a keeper of the public conscience. The fact that the apex court had done that could be seen in the recent case of Merong Mahawangsa Sdn Bhd & Anor v Dato’ Shazryl Eskay bin Abdullah [2015] 5 MLJ 619 FC (‘Merong Mahawangsa case’), among others. [36] Back to the present case, was there sufficient evidence to evince the intention of both the parties, namely the appellant and the deceased to deceive a third party as to the real intention of their enterprise by coming into this agreement? The intention of both parties could be deduced from the fact that both of them would stand to gain by having the appellant as a party to the agreement, instead of Bala. [37] Departing from where Diplock LJ left in the Snook’s case, and applying that ‘sham concept’ to the facts of our instant appeal, it is clear to us, that the agreement between the appellant and the deceased was a document executed by them which was intended by them to give to third parties or to the court the appearance of creating between the parties legal rights and obligations different from the actual legal rights and obligations (if any) which the parties intended to create. … [38] The learned JC had found it to be unconscionable and had struck it down as being against public policy under s 24(e) of the CA 1950 and illustration (g) to s 24. This finding was affirmed by the COA: … [39] Therefore, the agreement dated 8 February 1988 was a sham. Both the High Court and the COA found the agreement to be repugnant and the refused to assist the appellant. Although the sham and public policy were not specifically pleaded by the respondent, it was quite well ventilated during the examination of the relevant witness in the course of trial. In fact, Bala was cross-examined on this, and instead of objecting its introduction as a non-pleaded issue, Bala answered the same by stating that his employer was aware of his arrangement with the deceased and had no objection with it.” [38] Suntoso Jacob v. Kong Miao Ming [1986] 2 MLJ 170 was judgment of the Court of Appeal of Singapore which declined to enforce a trust that arisen out of an act which was described as having “practised a deception on the public administration”. It was held as follows: “In seeking the assistance of the Courts to enforce this equity, the appellant must come with clean hands; one of the maxims of equity is that he who comes into equity must come with clean hands. In this connection, it is necessary to examine the past conduct of the appellant immediately antecedent to the transaction that gave rise to the trust; plainly on his past conduct the appellant fails to satisfy the test required of him in equity. On the finding of fact of the learned Judge, which Mr. Hague accepted without reserve, the appellant in transferring the said shares to the respondent without any payment by the latter had practised a deception on the public administration. The part played by him in this deception had soiled his hands and he can hardly except the Court to give effect to and enforce the trust in his favour.” [39] The words of Ramly Ali J (as he then was) in Kondapuram Raghuram v. Soo Peng @ Yew Soo Peng [2006] 7 MLJ 510 lends further support to the principle that the Court would not aid a party who had intentionally created a document for the purpose of circumventing the law. More specifically, Ramly Ali J decided to follow English case laws that had struck down contracts that were intended to mislead the Revenue authorities. He held as follows: “The petitioner's purported scheme of parking his shares with the second respondent has the effect of avoiding the New Economic Policy at the very outset. This scheme controverses the purpose and intention of the New Economic Policy. Hence, so long as the scheme concerned has the effect of defeating statutes or laws and policies of Malaysia, the scheme and any agreements thereunder would be illegal and unenforceable. It is trite that no court will lend its aid to a man who found his cause of action upon an illegal act (intended or otherwise). Such a cause of action cannot be maintained and no claim or recovery pursuant thereto would be allowed. This ground alone will justify the petition be struck out by the court in limine. The court finds some authorities to support this conclusion. In Harun bin Taib v Khor Peng Song [1991] 3 CLJ 2484; KC Vohrah J, in dismissing the plaintiff's claim with costs held inter alia that: On the other hand, bearing in mind Alexander v Rayson [1936] 1 KB 169 and Napier v National Business Agency [1951] 2 All ER 264 touching on the refusal at enforce contracts intended to mislead revenue authorities as being opposed to public policy my view is that the insertion of a false figure for the consideration was intended and calculated to mislead the stamp duty authority and result in the evasion of the payment of a higher duty; and the Court has to regard that as being opposed to public policy within the meaning of s 24(e) of the Contracts Act. And that makes the agreement void too and unenforceable.” [40] As admitted by the Plaintiff/Beneficiary, the Trust Deed was created for the purpose of avoiding income tax. The Plaintiff’s intention was to proceed with his purchase of the said Lamborghini which cost more than RM1 million but to conceal the fact that he was its purchaser, by giving a false impression to third parties, including the Inland Revenue Board, Customs & Excise Department and the Insolvency Department, that the Lamborghini remains unsold by the 2nd Defendant in 2021 and was purchased at later date – when in fact the Plaintiff had purchased it and taken delivery in September

This was to avoid the Inland Revenue Board going after him for undeclared income besides avoiding sales tax. [41] The Trust Deed also had the illegal effect of hiding the Plaintiff’s purchase of the said Lamborghini from the Insolvency Department as he was still an undischarged bankrupt in year 2021. Though the Plaintiff did obtain an order for annulment of his bankruptcy by paying off his creditors in full in year 2022, he was still required by law to declare his income to the Insolvency Department at the material time. [42] I therefore rule that the Trust Deed relied on by the Plaintiff to support his cause of action was a sham instrument and ought to be struck down. It was an unenforceable instrument in a court of law. [43] Based on the evidence adduced, I was of the view that the Defendants’ version of an oral tripartite agreement was more plausible, in that the Plaintiff did agree to pay the 2nd Defendant the purchase price for the said Lamborghini by early 2022. My reason for making this finding was fortified by the fact that the Plaintiff and Marco Tan (DW-2) were in a business relationship. They have no familial relationship; for one pay for another family member on account of love and affection. As pointed out above, the Plaintiff failed to prove the existence of any money held by Marco Tan (DW- 2) for him. There was not even an iota of evidence to support his averment. Hence, even if I had not ruled that the Trust Deed ought to be struck down, my finding that the Plaintiff must have had agreed to pay for the said Lamborghini himself, would still lead to the same conclusion below. [44] I found that Section 20 of the Sale of Good Act 1957 is applicable in this situation. It states: “Where there is an unconditional contract for the sale of specific goods in a deliverable state the property in the goods passes to the buyer when the contract is made, and it is immaterial whether the time of payment of the price, or the time of delivery of the goods, or both, is postponed.” [45] The said Lamborghini was in a deliverable state and as a matter of fact, delivery was taken by the Plaintiff in September 2021. Thus, there could be no doubt that property in the said Lamborghini had passed to the Plaintiff. The issue of payment was a separate issue. [46] I also found that S.55(1) Sale of Goods Act 1957 was applicable to make the 2nd Defendant an unpaid seller that has the right to sue for the purchase price of the said Lamborghini. S.55(1) reads as follows: “Where under a contract of sale the property in the goods has passed to the buyer and the buyer wrongfully neglects or refuses to pay for the goods according to the terms of the contract, the seller may sue him for the price of the goods.” [47] Based on my above analysis and findings, I held that the 2nd Defendant had acted illegally in using force to tow away the said Lambroghini on 6th May 2022. The Plaintiff was able to take back possession of his car from the Police Station within a few hours. However, the Plaintiff had failed to prove his claim for Special Damages during the trial of this civil suit. He had pleaded Special Damages of RM170,000.00 but failed to prove payment of RM170,000.00 to repair the said Lamborghini. It is trite that Special Damages must be explained and duly proved. Thus, his claim for Special Damages must be dismissed. [48] I would allow the Plaintiff’s claim for an order for specific performance to order the 2nd Defendant to transfer the said Lamborghini to the Plaintiff, while the Plaintiff is ordered to pay the 2nd Defendant the agreed price of the said Lamborghini, which was RM1,050,000.00 – since he has been keeping and using the car for about 3 years. Counsel for the Plaintiff: Sara Rizqeen Binti Mohd Fauzi SOLICITORS FOR THE PLAINTIFF: MESSRS TANES, KHOO & PAULRAJ Advocates & Solicitors Unit No A-36-3A, Tower A, Menara UOA Bangsar, No. 5, Jalan Bangsar Utama 1, Bangsar, 59000 KUALA LUMPUR. Counsel for the Defendants: Cindy Wong Xin Tian (Lim Jin Wen with her) SOLICITORS FOR THE DEFENDANTS: MESSRS T. Y. TEH & PARTNERS Advocates & Solicitors Suite B-11-7, Megan Avenue 1, No. 189, Jalan Tun Razak, 50400 KUALA LUMPUR.

Yogananthy a/p Thambaiya v. Harta Pusaka Idris bin Osman [2020] 5 MLJ 455.

Suntoso Jacob v. Kong Miao Ming [1986] 2 MLJ 170.

Kondapuram Raghuram v. Soo Peng @ Yew Soo Peng [2006] 7 MLJ 510. LEGISLATIONS’ REFERRED:

S.20 & S.55(1) Sale of Goods Act 1957.

Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001.

Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities (Amendment to the First & Second Schedule) Order 2017.

Contracts Act 1950.