Similarly, in Chase Manhattan Bank v Israel-British Bank (London) Ltd [1981] Ch 105, Goulding J held that a person who paid money to another under a mistake of fact retained an equitable interest and the conscience of the payee was subjected to a fiduciary duty to respect that interest. The decision in Chase Manhattan was discussed in the House of Lords in Westdeutsche, where the judge’s reasoning was doubted in holding that the Israel-British Bank held the additional $2,000,000 on constructive trust when it knew of the mistake made by Chase Manhattan. Lord Browne-Wilkinson at p 715 said that mere receipt gave rise to no trust but the retention of the moneys after the receiving bank learned of the mistake ‘may well have given rise to a constructive trust’ which allowed a claim in equity, being, it seems, a personally liability to account as a constructive trustee under the knowing receipt head