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The issue in Stewart v Atco Controls Pty Ltd (in Liquidation) [2014] HCA 15 (7 May 2014) was whether a liquidator was entitled to an equitable lien over a fund constituted by a settlement sum with respect to the costs and expenses incurred in certain litigation. In considering this matter, the High Court of Australia reviewed and explained the dicta by Dixon J in In re Universal Distributing Co Ltd (In liq) (1933) 48 CLR 171. In doing so, the Court also reflected upon the general duties of liquidators.

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