The defendant’s knowledge is irrelevant, as liability is not dependent on fault. However, it is necessary to show that the defendant was unjustly enriched: per Lord Templeman in Lipkin Gorman v Karpnale Ltd. … in a claim for money had and received by a thief, the plantiff victim must show that money belonging to him was paid by the thief to the defendant and that the defendant was unjustly enriched and remained unjustly enriched … an innocent recipient of stolen money will be enriched if the recipient has not given full consideration.