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Briggs J had held that the terms of a guarantee in favour of the Society, making the guarantor's liability concurrent with that of the principal debtor, provided for a liability ‘for a liquidated sum' within the meaning of s 267(2)(b) of the Insolvency Act 1986 rather than a liability to pay unliquidated damages, and thus could found a bankruptcy order (see  EWHC 2989 (Ch),  BPIR 213).
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