As the judge put it, at Para 54, the essence of that decision was that a territorial limitation should be read into the provisions for third party debt orders in order to prevent a conflict of jurisdiction and the risk of double payment, whereas in the present case there is no good ground for limiting the words. Moreover, there the garnishee order created a security over the debt and, as that debt was governed by the law of Hong Kong, it could only be discharged in accordance with the law of Hong Kong. No such considerations apply here