[1] After a period of legal uncertainty, this case was finally and unquestionably accepted and adopted into domestic English jurisprudence by the UK Supreme Court in FHR European Ventures LLP v Cedar Capital Partners LLC [2014] UKSC 45.

The Privy Council advised the bribe money received by Reid, and the land acquired after, was held on constructive trust for the Hong Kong government.

This meant that the land bought by Reid and his wife was held on trust, and had to be given over to the Hong Kong government.

[...] It has always been assumed and asserted that the law on the subject of bribes was definitively settled by the decision of the Court of Appeal in Lister & Co v Stubbs (1890) 45 Ch.D.

One consequence, of course, would be that, if Stubbs were to become bankrupt, this property acquired by him with the money paid to him by Messrs. Varley would be withdrawn from the mass of his creditors and be handed over bodily to Lister & Co. Can that be right?

Another consequence would be that, if the appellants are right, Lister & Co. could compel Stubbs to account to them, not only for the money with interest, but for all the profits which he might have made by embarking in trade with it.

In Sinclair Investments (UK) Ltd v Versailles Trade Finance Ltd [2011] EWCA Civ 347 the Court of Appeal declined to rely on this particular case from the Privy Council as precedent and instead preferred the original English legal position set out in Lister & Co v Stubbs (1890) LR 45 Ch D 1.

However the Court of Appeal judgement was partially overturned by FHR European Ventures LLP v Cedar Capital Partners LLC [2014] UKSC 45.

Reid served a four-year prison sentence for the criminal charges relating to the bribes, after which he was deported to his native New Zealand.

Although he was barred from practising as a lawyer, he set up a legal consultancy in 2013 which provoked anger in both New Zealand and Hong Kong.