Kerr J. Occidental Worldwide Investment Corporation v Skibs A/S Avanti, {The Sibeon and The Sibotre} [1976] 1 Lloyds Rep 293. To view the purposes they believe they have legitimate interest for, or to object to this data processing use the vendor list link below. This eBook is constructed by lawyers and recruiters from the world's leading law firms and barristers' chambers. Steyn LJ said that the nature of the demand only required examination, by virtue of the acts lawfulness. Representor induced Relying Party to believe that he would pay a certain sum of The claimant then sought to enforce the guarantee and the defendant sought to have the agreement set aside for economic duress. What are the 4 factors from the Pao On case which make it more or less likely that there has been economic duress? DURESS Duress to the Person Barton v Armstrong [1976] AC 104 Duress to Goods Skeate v Beale (1840) 11 Ad&El 983 Maskell v Horner [1915] 3 KB 106 The Sibeon and TheSibotre [1976] 1 Lloyd's Rep 293 Economic Duress The Sibeon and TheSibotre [1976] The Atlantic Baron [1979] QB 705 Pao On v Lau Yiu Long [1980] AC 614 B&S Contractors v Victor Green Publications [1984 . This article affords a contextual, exploitation-based account of the doctrines of undue influence and unconscionable dealing in the law of contract. One new video every week (I accept requests and reply to everything!). Once the metal was delivered the hirers went back to the ship owners saying the original contract was voidable due to economic duress they argued that the take it or leave it offer was lawful, but in these circumstances it was duress. difficulty and the bank wished to find security for the company debts. that desire were known to those to whom the undertaking was given. Stilk v Myrick (1809) 2 Camp 317 However, where the promisor goes beyond the existing contractual duty this will amount to good consideration for an additional promise from the promisee. charge set aside. This is controversial. Become Premium to read the whole document. One of my few ships with an inside. Facts: R was a member of the SAS who wanted to write about his experiences, but was told to sign a confidentiality agreement to say that he wouldnt write a book. Susan had promised to pay him if he delivered the, Bill downloaded an antivirus software from the Internet. [1992].1.All.ER.453 supplier of wheat in South Australia, the plaintiff paid under protest and then sued He held that undue influence was a category of a wider class where the Occidental Worldwide Investment Corp v Skibs A/S Avanti, Skibs A/S Glarona, Skibs A/S Navalis (The 'Siboen' and the 'Sibotre') . Sibeon and Sibotre. Economic Duress The doctrine of economic duress was first created by Kerr J in (Occidental Worldwide Investment Coporation V Skibs (The Sibeon & Sibotre), 1976)3. They later sought to have the renegotiated contract set aside. Only full case reports are accepted in court. Due to this the plaintiffs therefore, agreed to renegotiate the contract to lower the cost of charter. ; . They made, several demands in relation to pay and conditions and also demanded the ship owners pay a large sum, of money to the Seafarers International Welfare Fund. Occidental Worldwide Investment Corp v Skibs A/S Avanti, Skibs A/S Glarona, Skibs A/S Navalis (The 'Siboen' and the 'Sibotre') . Roger Sibeons distinctive new book forms part of a movement towards what many others have referred to as the `return to sociological theory and method. It was indeed the case, of course, that the mutual agreement of both TT and PIAC were in evidence at the time of signing the New Agreement., Richards LJ inserted a corollary to the dissention of Lord Wilberforce[8] that a successful claim under duress can be raised where there is a threat by party A to exceed their contractual responsibilities; saying that the courts may make a value assessment based on the facts, such that a threat or pressure to advance such a threat may not be illegitimate for party B. The Defendant claimed they were entitled to the rescission due to the innocent misrepresentation and duress and underpayment of the hire. the wife raised undue influence and misrepresentation in her defence to have the Obiter remarks by Leggatt LJ suggested that lawful act duress could be widened with reference to blackmail in circumstances where a defendant had no reasonable grounds[10] for making a lawful demand. Most Popular Parking/Curbside Management Programs, Latest From ParkDC, Videos, Events Calendar. Case Summary - The Sibeon and the Sibotre [1976] - Arnold v. Britton [2015] - Rainy Sky SA v. Kookmin Bank [2011] - Parker v. South Eastern Railway [1877] - Unfair Contract Terms Act 1977 - Consumer Rights Act 2015 - Davis Contractors v. Fareham Urban District Council [1956] - Taylor v. Caldwell [1863] Worldwide Investments v Skibs (The Sibeon & The Sibotre)) Economic duress DSND Subsea Ltd v Petroleum Geo Services ASA - Dyson J Pressure: o (a) whose practical effect is compulsion or a lack of practical choice for the victim, o (b) which is illegitimate, and o (c) which is a significant cause inducing the claimant to enter into the . Armstrong and others and sought to have the contract set aside as a result of Kerr J if(typeof ez_ad_units != 'undefined'){ez_ad_units.push([[320,100],'swarb_co_uk-medrectangle-3','ezslot_5',114,'0','0'])};__ez_fad_position('div-gpt-ad-swarb_co_uk-medrectangle-3-0'); [1976] 1 Lloyds Rep 293if(typeof ez_ad_units != 'undefined'){ez_ad_units.push([[250,250],'swarb_co_uk-medrectangle-4','ezslot_4',113,'0','0'])};__ez_fad_position('div-gpt-ad-swarb_co_uk-medrectangle-4-0'); Cited MCI Worldcom International Inc v Primus Telecommunications Inc ComC 25-Sep-2003 The claimant sought judgment, and the defendant leave to amend its defence. Issue: Inequality of Bargaining Power within the commercial realms of hard-bargain trading world of business. limited to 60,000 and that it was only to last for a few weeks. But, the Court of Appeal said that Aboodys claim failed because it was not to her manifest disadvantage (note: there is no longer a need to prove a manifest disadvantage in actual undue influence cases). The chapter seeks to explore the doctrine of economic duress in the UK, Malaysia, Singapore and Australia. ); North Ocean Shipping Co v Hyundai Construction Co (The Atlantic Baron) [1979] Q.B. mortgaged by the borrowers applied illegitimate pressure to them during lengthy This was completely untrue. [1] occidental worldwide investment corporation v skibs (the sibeon & the sibotre) [1976] 1 lloyds rep 293 [2] times travel (uk) ltd v pakistan international airlines corporation (rev 2) [2019] ewca civ 828 [3] times travel (uk) ltd v pakistan international airlines corporation [2017] ewhc 1367 [4] dimskal shipping co sa v international transport Fortnite Valorant Apex Legends Destiny 2 Call of Duty Rainbow Six Halo Infinite League of Legends Battlefield Rocket League PUBG Splitgate CS:GO Brawlhalla For Honor Hyper Scape Rocket Arena The Division 2 Fall Guys Realm Royale Overwatch . Such a degree of coercion that the other party was deprived of his free consent and agreement (Sibeon v Sibotre) 4 elements to proving economic duress (1) pressure (2) illegitimate (3) significant (4) lack of choice. Rozhodne by to bolo pozitvnejie.,,Ok, nabudce ti nechm tvoje zakrvaven veci," Velox dal ruky do zmierlivho gesta a asi by bol odiiel, ibae v tej sekunde sa baby vrtili do izby. Occidental Worldwide Investment v Skibs (The Sibeon & The Sibotre) [1976] 1 Lloyds Rep 293 The defendants chartered two vessels from the claimant. [4]Dimskal Shipping Co SA v International Transport Workers Federation [1992] 2 AC 152 He told his wife that the charge was The Defendant agreed to reduce the hire rate. The defendants told the claimants that they would go bankrupt if they did not lower the cost of charter. 705; [1978] All E.R. claimants that they would go bankrupt if they did not lower the cost of charter. Occidental Worldwide Investment Corporation v Skibs A/S Avanti, The Sibeon and The Sibotre [1976] 1 Lloyd's Rep 293 Economic duress is a threat to a person's financial or business interests. The doctrine of economic duress was first recognized in the case of The Sibeon and The Sibotre. In this case the court first recognise the element of duress under a contractual agreement. The proceeds of this eBook helps us to run the site and keep the service FREE! 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By way of defence, PIAC relied on the waiver in the New Agreement, but TT successfully challenged the validity of the New Agreement under economic duress. 1170, 719 (Mocatta J). significant detriment that is needed to support an estoppel. that they w ould go bankrupt if they did not lower the cos t of charter. Today she would probably be successful as someone who is bullied to sign a contract can have it set aside even if they could receive a benefit from signing the contract. M.F.M. Given the rather vague concept of morally and socially unacceptable conduct formulated in CTN5, it is unsurprising that the court was directed towards blackmail in order to rationalise the concept of lawful duress. ground of economic duress. The cigarettes were then stolen. What is internal control and what are some of its objectives? for them to rely on the guarantee, Duress, Undue Influence & Unconscionable Conduct Case Summary, Copyright 2023 StudeerSnel B.V., Keizersgracht 424, 1016 GC Amsterdam, KVK: 56829787, BTW: NL852321363B01, he entered into the contract as a result of. What is the only available remedy for economic duress. Steyn LJs obiter comments in CTN[6] had an overarching significance for the ultimate conclusion reached in the appeal, which will become apparent later. Economic duress is a fairly new area of law. Richards LJ also cited the finding in Occidental;[7] due to the lawfulness of the act itself the question was whether the nature of the demand constituted illegitimacy? The husbands business was in trouble. In the UK the doctrine was first recognised in England by Ker J in the Siboen and The Sibotre [1976] 1 Lloyds Rep 293 and its existence has been affirmed in cases such as R v A-G . ; Jager R. de; Koops Th. The Defendant owned two tankers that were charted to the Plaintiff for three years. Victor Green (the organisers) was in a bad position and the timing meant they could not get anyone else in to erect the stands and if they didnt get the stands up there would be many claims from those exhibitors who wished to exhibit there. A.Internal control can be defined as the, The service contract act was enacted to protect economies in the geographical areas where the contract is performed. The organisers reluctantly agreed to pay the extra money to erect the stands, Held: Court said this amounted to duress and Victor Green had NO practical choice here, Kerr LJ = "a threat to break a contract unless money is paid will not always be duress unless by refusing to pay would lead to serious and immediate consequences". misappropriated by the son. Home renovation services - Window and Door replacement, Siding, Soffit, Fascia, Roofing, Custom. This prospect would seem even more improbable when one considers the cordial relations which characterised both parties business relationship, until the advent of this dispute. Day and Davies have noted their understanding that this judgement will be referred to the Supreme Court, providing leave of appeal is granted. This was completely untrue. The claimant appealed refusal of an award an account of profits for what was akin to a breach of statutory duty. Sibeon - 20kapitola - Lenisov tok. Held: So, the Court of Appeal said that although the wifes will and intention was not overborne there was undue influence. balance of power between the parties was such as to merit the interference of the Anthony Giddens merupakan tokoh yang mengembangkan teori strukturasi Teori ini dibahas secara mendalam pada bukunya yaitu, The Constitution of Society: Outline of the Theory of Structuration (Polity Press, Cambridge), pertama terbit tahun 1984. had constructive notice of the misrepresentation and failed to take reasonable steps Mutual Finance v John Wetton and Sons [1937] 2 KB 389. There must be present some factor which could in law be regarded as a coercion of his will so as to vitiate his consent.. Looking for a flexible role? In the UK the doctrine was first recognised in England by Ker J in the Siboen and The Sibotre [1976] 1 Lloyds Rep 293 and its existence has been affirmed in cases such as R v A-G for England and Wales [2003] UKPC 22. promise had been given in advance of the act it would be legally enforceable. retained shares falling below a set level. In 2010 agents of PIAC determined to commence proceedings, against PIAC, pertaining. 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The Sibeon and The Sibotre (1976) - (Facts) The defendants, had chartered two vessels from the plaintiff. The defendants told the claimants that they would go bankrupt if they did not lower the cost of charter. ), Auditing (Robyn Moroney; Fiona Campbell; Jane Hamilton; Valerie Warren), Company Accounting (Ken Leo; John Hoggett; John Sweeting; Jennie Radford), Culture and Psychology (Matsumoto; David Matsumoto; Linda Juang), Lawyers' Professional Responsibility (Gino Dal Pont), Il potere dei conflitti. v Beale. However, they have expressed their disappointment that Richards LJ did not jettison13 the concept entirely. Therefore the threat was legitimate and consequently, economic duress could not be established. (Decision) The court held and Kerr J concluded, If I should be, compelled to sign a lease or some other contract for a nominal but legally sufficient consideration, under an imminent threat of having my house burnt down or a valuable picture slashed.I do not, think that the law would uphold the agreement., Universal Tankships of Monrovia v International Transport Workers Federation (1983), (Facts) The ITWF blacked a ship, The Universe Sentinel, to prevent it from leaving port. I help people navigate their law degrees. PIAC are after all a commercial entity and pressure is a recognised feature of such environments. Most Popular Parking/Curbside Management Programs, Latest From ParkDC, Videos, Events Calendar. Vitally important as it is for the law to facilitate the healthy functioning of competitive markets, there is arguably, somewhat of a dismissive abdication, on the part of the courts to adequately provide a degree of protection for the vulnerability of small, family businesses, such as TT. Module: Contract Law (LAW1108) Barton v Arms trong (1976) AC 104. McAleer noted, There is a large difference between a gun to the head and being subject to a pushy salesman.[11] PIACs conduct in these negotiations may be categorised as being akin to the latter. Course Hero is not sponsored or endorsed by any college or university. They were not well informed about the, details of the mortgage, and clearly had no idea what's going on. Richards LJ inserted a corollary to the dissention of Lord Wilberforce, Given the rather vague concept of morally and socially unacceptable conduct formulated in. [7]Occidental Worldwide Investment Corp v Skibbs A/S Avanti [1976] 1.Lloyd's Rep 293 Cited Pao On and Others v Lau Yiu Long and Others PC 9-Apr-1979 (Hong Kong) The board was asked whether a contract of guarantee had been obtained by duress. The House of. Barton alleged that he entered into the contract as a result of death threats made, against him by Armstrong and others and sought to have the contract set aside as a, On appeal, the Privy Council held in favour of Barton and set aside the, onus is on the person who made the threat, A father (Sear) was told that criminal proceedings would be taken against his, son if he did not sign promissory notes for a sum of money alleged to have been, The threat of criminal proceedings against the son amounted to duress, and, the father was consequently not liable on the promissory notes, The threat can be made to the contracting party, unlawful taking, detention, damage or destruction, that pressures a person who has an interest in the. This case centred around an appeal, from the High Court to the Court of Appeal in 2018. When the, Appellant attempted to seize the house, the Respondents attempted to challenge A threat made by a party to a contract may be illegitimate when This case centred around an appeal, from the High Court to the Court of Appeal in 2018. Following PIACs decision to reduce the number of fortnightly tickets from 300 to 60 on 17th September 2012, TT proceeded to sign the New Agreement on account of their business future survival, on September 23rd. Stilk v Myrick). Contract 2 Coursework - Free download as Open Office file (.odt), PDF File (.pdf), Text File (.txt) or read online for free. The preponderance of jurisprudence highlighted that there was scant support for an extension of lawful act duress. Richards LJ was keen to emphasise, from the outset, that the present case did not constitute unlawful act duress whatsoever. Occidental Worldwide Investment v Skibs (The Sibeon & The Sibotre) [1976] 1 Lloyds Rep 293 Defendants chartered two vessels from the claimant. Law is an intellectually demanding and thought-provoking subject. This was completely untrue. Occidental Worldwide Investment v Skibs (The Sibeon & The Sibotre) [1976] 1 Lloyds Rep 293 The defendants chartered two vessels from the claimant. [14]Jodi Gardiner, Does.Lawful.Act.Duress.Still.Exist? [2019] CLJ (inducement). [17]Consumer Rights Act 2015, 2022 QUB The Verdict. celebrities who live in fairfield county ct; unethical behavior is always; estudio dela atalaya de esta semana However, the faith requirement, arguably runs counter to Lord Ackners seminal assessment that a duty to conduct negotiations in good faith is inherently repugnant[12] English law values. Occidental Worldwide Investment Corporation v Skibs [1976] 1 Lloyds Rep 293 However, the doctrine of economic duress is still developing through case laws as this doctrine has been established for over two decades only. Long) in consideration for certain shares. Long agreed, but only to ensure public confidence in the, The sale proceeded and Pao On sought to enforce the indemnity. To investigate the proposition, 'there is no clear agreement about what amounts to a constitutional convention', firstly, will require a look at the different definitions of what amounts to a constitutional convention, and to discuss their function or purpose, within the U.K's constitution. Our academic writing and marking services can help you! In particular, the defendant had requested that Pao On retain 60% of shares. Mr O'Brien was a chartered accountant and he also had a shareholding in a In 2010 agents of PIAC determined to commence proceedings, against PIAC, pertaining to unpaid commission which they were contractually owed. Lecture 13 duress - cases 1. C agreed to renegotiate the contract . Pronunciation of sibotre with 1 audio pronunciation and more for sibotre. 1170, 719 (Mocatta J). They were later divorced and the wife sought to have that refinancing contract set aside on the basis of undue influence, There was a problem with her argument to set aside the contract on the basis of undue influence: it relates to Birks and Chins theory of undue influence that excessive influence is needed as there was no evidence that there was excessive influence in this case. The court noted that Commonwealth jurisdictions, including Australia, restricted recognition of duress to threatened or actual unlawful conduct. Pronunciation of sibotre with 1 audio pronunciation and more for sibotre. Richards LJ was keen to emphasise, from the outset, that the present case did not constitute unlawful act duress whatsoever. contract and it was very unfair and pressures were brought to bear by the bank. The avoidance of a contract based upon the application of a form of lawful economic duress advanced by pressure which was legitimate within the cut and thrust of contractual negotiations was deemed as being an extension of the common law which the courts could not credibly countenance. Corporation v Skibs A/S Avanti, The Siboen and the Sibotre [1976] 1 Lloyd's Rep 293. Furthermore, the judge identified that illegitimate pressure could constitute conduct which is not itself unlawful, albeit with the caveat that this would be unlikely to occur in a commercial context.[9]. Hartley v Ponsonby (1857) . Held: Lord Scarman said: Duress, whatever form it takes, is a coercion of the will so as to vitiate consent. Proudly created with Wix.com, Contract LAW2040 Case Note First-Class Answer (Awarded an 80). After the conversation the wife agree to enter into the refinancing contract. No products in the cart. Undue influence is about influence/pressure in a relationship context and about regulating this relationship pressure, So there was no excessive pressure but the influence the husband did have was used improperly: It is evident that Mrs Hewett's decision to accede to her husband's request was based upon an assumption on her part that he was as committed as she was to the marriage, but this was not the case as he had already embarked upon an affair. The difficulty in defining these boundaries was most recently demonstrated in Times Travel Ltd v Pakistan International Airlines Corporation[2]; the subject of this present appeal. [3]Times Travel (UK) Ltd v Pakistan International Airlines Corporation [2017] EWHC 1367 HELD: Threat by a supplier who had a monopoly was not sufficient to constitute The threat must be directed to the person's financial standing but not to the person himself or his property. exercise independence of thought on financial matters and was used to dealing for economic duress, it was not established in this case. Occidental Worldwide Investment Corporation v Skibs A/S Avanti, The Sibeon and The Sibotre [1976] 1 Lloyd's Rep 293 Economic duress is a threat to a person's financial or business interests. coupled with a demand for payment even where the threat is one an action which The claimants needed the credit facilities and so paid the invoice and then sought to reclaim the money on the grounds of economic duress. Study with Quizlet and memorize flashcards containing terms like The Sibeon v The Sibotre, Pao On v Lau Yiu Long, The Universal Sentinel and more. Why then place small, commercial entities in isolation, in the absence of protective legislation? To export a reference to this article please select a referencing stye below: UK law covers the laws and legislation of England, Wales, Northern Ireland and Scotland. They were awarded damages with conditions attached. Home renovation services - Window and Door replacement, Siding, Soffit, Fascia, Roofing, Custom. Legislation pursuant to the protection of the rights of individual consumers[17] is in place. The Sibeon and The Sibotre [1976] (above) The charterers of two ships renegotiated the rates of hire after a threat by them that they would go bankrupt and cease to trade if payments under the contract of hire were not lowered. To amount to economic duress there had to be a coercion of the will so as to vitiate consent. celebrities who live in fairfield county ct; unethical behavior is always; estudio dela atalaya de esta semana 705; [1978] All E.R. Australia and New Zealand Banking Group Ltd v Karam [2005] NSWCA 344, CTN Cash and Carry Ltd v Gallaher Ltd [1993] EWCA Civ 19, Dimskal Shipping Co SA v International Transport Workers Federation [1992] 2 AC 152, Occidental Worldwide Investment Corp v Skibbs A/S Avanti [1976] 1 Lloyd's Rep 293, Progress Bulk Carriers Ltd v Tube City IMS LLC, The Cenk Kaptanoglu [2012] EWHC 273, Times Travel (UK) Ltd v Pakistan International Airlines Corporation [2017] EWHC 1367, Times Travel (UK) Ltd v Pakistan International Airlines Corporation (Rev 2) [2019] EWCA Civ 828, Jack Beatson, The Use and Abuse of Unjust Enrichment (first published 1991, OUP), 129, Andrew Burrows, Anson's Law of Contract (first published 2016, OUP), 67, Paul Davies & William Day, Lawful act duress (again) [2019] LQR 2020, Jodi Gardiner, Does Lawful Act Duress Still Exist? [2019] CLJ, Law Commission Report No 292, 2005, Part5, [1]Occidental Worldwide Investment Corporation v Skibs (The Sibeon & The Sibotre) [1976] 1 Lloyds Rep 293 claimants) hired a couple of ships from the defendants, who then made a threat saying they would go bankrupt if the defendants did not renegotiate. would otherwise be lawful.The line between permissible forms of persuasion and Smith v William Charlick Ltd [1924] 34 CLR 38. mixture of goods and services. Held: The misrepresentation alleged was made by the claimants in-house . take place. swarb.co.uk is published by David Swarbrick of 10 Halifax Road, Brighouse, West Yorkshire, HD6 2AG. In fact the charge was not limited in the amount or [11]Andrew Burrows, Anson's Law of Contract (first published 2016, OUP) 67 Commercial customers and they were also were owed substantial amounts of money by the, defendant which they feared they would lose if the defendants did. the validity of the of the mortgage, HELD: By majority (Justices Mason, Wilson and Deane JJ) held the Amadio's Vitally important as it is for the law to facilitate the healthy functioning of competitive markets, there is arguably, somewhat of a dismissive abdication, on the part of the courts to adequately provide a degree of protection for the vulnerability of small, family businesses, such as TT. The Court of Appeal referred to Lord Nicholls in Royal Bank of Scotland v Etridge where he said that "undue influence means that power has been misused" and "when a husband is forecasting the future of his . It is company, would lose his home. Following PIACs decision to reduce the number of fortnightly tickets from 300 to 60 on 17th September 2012, TT proceeded to sign the New Agreement on account of their business future survival, on September 23rd. Lists of cited by and citing cases may be incomplete. time. the father was consequently not liable on the promissory notes, The Sibeon and The Sibotre [1976] 1 Lloyds Rep 293. Vslovnost sibotre s 1 vslovnost audio, a vce sibotre. View playboy sibotre's TFT overview statistics and how they perform. I think that there are indications in Skeate v Beale itself and in other cases that the true question is ultimately whether or not the agreement in question is to be regarded as having been concluded voluntarily . Duress. The Sibeon and The Sibotre [1976] 1 Lloyd's Rep 293. Before its appearance cases in this category would have been dealt with as contracts lacking consideration (e.g. the sale of controlling interests (shares) in various companies.Barton alleged that [9]Progress Bulk Carriers Ltd v Tube City IMS LLC, The Cenk Kaptanoglu [2012] EWHC 273 case one may imply (as I do here) a term in the contract that no prosecution should Duress emerged from the courts as a protection against parties threatening recourse to unlawful action, including physical intimidation. Read more. Learn faster with spaced repetition. Which case confirms the law needs to be substantial or significant? (contributing factor), The onus is on the person who made the threat to show that it had no effect ); North Ocean Shipping Co v Hyundai Construction Co (The Atlantic Baron) [1979] Q.B. for the sale of controlling interests (shares) in various companies. Barton was in financial difficulty and entered into a contract with Armstrong for Susan entered into a contract with Andrew, a dealer who specializes in diamond jewelry. Agnes is very good at her job andMorges fears threatened by her.Over a period of several months he routinely criticizes, Susan wanted to give a diamond pendant to Lucy, her daughter. . contract. The Sibeon and The Sibotre) [1976], Pao On Lau Yiu Long [1980] (JCPC) etc.Perhaps the most complete statement of the law is to be found in Universe Tankship of Monrovia v ITWF [1983]. The Sibeon & The Saboture Attorney General v R Barton v Armstrong Emphasis on legitimacy of pressure - 2 step authority Focused on ability of victim to make the choice freely - dures Threat of any unlawful act is illegitimate Physical duress authority The Universe Sentinel Emphasis on legitimacy of pressure - 2 step authority Teamfight Tactics.