ABSTRACT

5.1 One of the most abrupt reversals of the common law occurred when the House of Lords held in 1976 in Miliangos v George Frank (Textiles) Ltd 1 that claims for debts incurred in a foreign currency could be made in a foreign currency rather than in sterling. Previously, it had always been accepted as inevitable that foreign currency debts had to be converted into sterling because sterling was the currency of the forum. Miliangos was decided less than 15 years after the House had decided In re United Railways of Havana and Regla Warehouses Ltd, 2 which appeared to have set up a rampart protecting sterling judgments.