The test for knowing receipt outlined in Akindele has since been confirmed by the Court of Appeal in City Index v Gawler [2007] EWCA Civ 1382 and applied most recently in Armstrong v Winnington Networks [2012] EWHC 10 (Ch) at [130]-[132] though referring to Baden types of knowledge, and by the Privy Council in Arthur v A-G of the Turks and Caicos Islands [2012] UKPC 30. However, without a clear definition of what unconscionability is, there is the risk of it being misinterpreted and misapplied by judges in future decisions. In Arthur the Privy Council held that unconscionability is ‘conduct amounting to equitable fraud’ (at [40]) but this is no less imprecise a concept.