Recovery from the Corrupt Available to Purchase

A further illustration of the increasing grip of the law of equity in enabling monies that are part of a fraud to be recovered by the victim is provided by the Privy Council decision in Attorney‐General for Hong Kong v Warwick Reid. Previous decisions of English and Commonwealth courts based on the old established principles of equity have employed a constructive trust to recover monies that are the proceeds of fraud or are part of a fraudulent design. AG for Hong Kong v Reid showed how the constructive trust would operate to enable the Crown to recover bribes that had been paid to a Hong Kong public officer.