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Under the 'old' law of deception offences, a causal link between the deception and the obtaining could be implied where D wrote a guaranteed cheque, even where the victim had admitted that they had not considered whether the bank would honour the cheque. The 'new' ;aw of fraud does not require obtaining, so this principle is no longer necessary. However the case can still be used as authority for the implied representations which a person makes when using a cheque guarantee card.

R v PREDDY, SLADE AND DHILLON [1996] 3 All ER 735 (HL)

Mortgage fraud did not amount to obtaining property by deception under the 'old' law before the Fraud Act 2006. Also note the HOL comments on fraud reform.

DPP v RAY [1974] AC 370 (HL)

A customer in a restaurant makes an implied representation on ordering food, that he will pay for it.

R v ALLEN [1985] AC 1029 (HL)

In order to be convicted of making off without payment contrary to s.3 of the Theft Act 1978, D must have intended never to pay.

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