LAW

Published on
KembaraXtra-Case Law-Gilmartin (1983)

Post-Dated Cheques & DeceptionI. Facts of the Case
  • Defendant (D): Owned a company.
  • Action: Signed four post-dated cheques.
    • Three for goods purchased for his company.
    • One payable to a company his business had an account with.
  • Financial Situation: Company heavily overdrawn.
  • Outcome: All four cheques were dishonoured.
  • Subsequent Action: D sold the goods bought with the cheques and received cash cheques in return.
  • Charge: Charged under ss 15 and 16 of the Theft Act 1968.
  • Defense: D claimed he intended to buy back the post-dated cheques with the cash.
II. Legal Issue
  • Whether issuing a post-dated cheque constitutes a representation regarding future ability to pay, and if a false representation can amount to deception under the Theft Act 1968.
III. Held (Court of Appeal)
  • Implied Representation: The drawer of a post-dated cheque impliedly represents to the payee:
    • Present Situation: That on the date the cheque is handed over, the situation is such that...
    • Future Honouring: ...when the cheque is presented, it will be honoured on or after the date specified.
  • False Representation & Deception:
    • If the drawer knew the bank would not honour the cheque on that date, then the representation is false.
    • This false representation could amount to deception.
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