Atkin LJ noted the argument of Hambrouck that title could not be asserted because after passing through other bank accounts, it could no longer be identified.

But In re Hallett’s Estate said that was not a problem because any transfer to an innocent donee would defeat an original owner’s claim.

...I venture to doubt whether the common law ever so restricted the right as to hold that the money became incapable of being traced, merely because paid into the broker’s general account with his banker.

But if in 1815 the common law halted outside the bankers’ door, by 1879 equity had had the courage to lift the latch, walk in and examine the books: In re Hallett’s Estate.

Whether, short of the House of Lords, it is now open to the courts to adopt it I need not consider.Ellinger's Modern Banking Law viewed the two cases as reaching substantially the same conclusion: The orthodox position, as reflected in the judgments of Bankes and Scrutton LJJ in the Hambrouck case, and in the reasoning of Millet J, as approved by the Court of Appeal, in Agip, is that money cannot be traced at common law once it gets mixed or commingled with other funds...[2]The reasoning in Banque Belge has also helped to expand the application of Norwich Pharmacal orders.