In a Barnes v Addy knowing assistance claim against corporate entities, where the claim could proceed on either objective or subjective grounds, a pleading that merely sets out what the banks 'knew' without expressly alleging that the conduct was dishonest or wrongful is equivocal and does not satisfy the requirement to plead dishonesty with clarity and precision. Further, where conscious wrongdoing is alleged against a corporate entity, the individual officers whose knowledge and dishonesty is to be attributed to the corporation must be identified in the pleading. The question whether Barnes v Addy knowing assistance in Australia requires subjective dishonesty of the third party was left open.
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