D had abused his public office to receive huge amounts of bribes to prevent criminal prosecutions. The AG brought an action for the crown to reclaim the bribe money. PC allowed the claim, holding that Lister had been wrongly decided.
Lord Templeman: As soon as a bribe is paid the fiduciary becomes in equity the debtor of his principal for the amount of the bribe which should be transferred to the principal. Because equity views that as done which ought to be done, the bribe becomes the subject of a constructive trust in favour of the principal as soon as it is received.
