Re Kayford [1975] 1 All ER 604 A mail-order company fearful that it might go into liquidation may pay customers’ moneys into a separate bank account opened for the purpose of protecting them from merely being debtors of the company if not receiving their ordered goods. This will amount to a trust of the moneys for the customers. Of course, a customer on sending his cheque to such a company to buy goods could himself by covering letter require the company to hold the cheque money (as soon as cleared) on trust for himself.