It was held that the fraud defence in section 9(z)(d) of the 1920 Act had to be construed in the light of the common law as understood when the 192.0 Act was passed following the Sumner Report (1919) (Cmd 151), and therefore it embodied the principle in Abouloff v Oppenheimer &Co. Lord Bridge of Harwich said, at p 487, that he saw the force of the submission that Abouloff v Oppenheimer &Co should be overruled, and recognised, at p 489, that “as a matter of policy, there may be a very strong case to be made