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A bankrupt was in arrears in respect of an income payments agreement with his trustee. The bankrupt entered into an individual voluntary arrangement some years after his bankruptcy. His Honour Judge Hodge QC (sitting as a High Court judge) held that the arrears should be included as a debt in the IVA for voting and dividend purposes.
"This is the ultimate statement of where the law on IVAs is to be found in our great common law...