He left Iran and transferred his money from the New York to the London bank.

In February 1980 the London bank was notified that Mr Karoon was sentenced to prison by the Iranian government, and requested his assets be sent to the Iranian government.

The bank, unsure of what to do, applied for an interpleader summons and the money was eventually paid into court.

Robert Goff LJ held that it was for American law, as the forum conveniens, to determine whether the Bank of Tokyo Trust Co had committed a breach of contract, observing that it was a separate corporation from Bank of Tokyo.

In the course of his judgment Robert Goff LJ observed,[1] Counsel suggested beguilingly that it would be technical for us to distinguish between parent company and subsidiary in this context; economically, he said, they were one.