Target Holdings Ltd gave £1,525,000 to Redferns solicitors, ultimately to be loaned to Crowngate Developments Ltd to buy property at 60-64 Great Hampton Street, Hockley.

Breaching the terms of the agreement, Redferns in fact released £1,490,000 to a company called Panther Ltd before the purchase was completed.

Crowngate failed to repay the loan, and went into liquidation, meaning that Target Holdings Ltd only ever recovered £500,000 from the sale of the property.

Target Holdings Ltd sued Redferns solicitors, arguing that it had a duty to account for the money it had wrongly paid away.

Although the test in the law of tort might differ, and allow remoteness limits or have dissimilar causation outcomes, some causal connection was needed between the fiduciary's breach of trust and the loss that resulted to the claimant.

So because Redfern's payment away of the trust property early had nothing to do with the ultimate losses of Target Holdings Ltd, they were not liable to repay that money.

Second, that the plaintiff is to be put "in the same position as he would have been in if he had not sustained the wrong for which he is now getting his compensation or reparation": Livingstone v Rawyards Coal Company (1880) 5 App Cas 25, 39. per Lord Blackburn.

The detailed rules of equity as to causation and the quantification of loss differ, at least ostensibly, from those applicable at common law.