Recipients of funds fraudulently transferred by a government employee may be liable as knowing recipients or knowing accessories under Barnes v Addy principles, and the funds are recoverable as void ultra vires payments of public money. The Commonwealth does not owe a duty of care to recipients of fraudulently transferred funds to prevent the fraud, particularly where the recipients were not vulnerable and were authors of their own misfortune. Damages flowing solely from interlocutory injunctions obtained in recovery proceedings are not recoverable as damages for negligence or misleading and deceptive conduct.
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