Questions 1 What interest does an action in debt protect? Is this an interest that is always protected by an action in damages? What must the plaintiff show in order to succeed in protecting this interest via damages? 2 What was the cause of the plaintiffs’ loss? 3 Is Damon still good authority after Ruxley Electronics v Forsyth (below, p 301)? (c) Non-contractual debt
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Brandon J:… I do not think that a claim for salvage is a proceeding for the recovery of damages, and the question is accordingly reduced to this: whether it is a proceeding for the recovery of a debt. As to this it is to be observed that the words used are ‘any debt’, indicating that the net is being spread as widely as possible. Those words are, as it seems to me, apt to cover sums, whether liquidated or unliquidated, which a person is obliged to pay either under a contract, express or implied, or under a statute. They would, therefore, cover a common law claim on a ‘quantum meruit’, or a statutory claim for a sum recoverable as a debt, for instance a claim for damages done to harbour works under s 74 of the Harbour, Docks, and Piers Clauses Act 1847.