In their judgment in Alfred McAlpine Construction Ltd. v. Panatown Ltd. (The Times, 11 February 1998), the Court of Appeal has added yet another to the list of explanations for the rule in Dunlop v. Lambert (1839) 6 Cl. & F. 600; 7 E.R. 824. There, the House of Lords held that, where goods had been lost at sea, a consignor could recover substantial damages even though the goods, by the time of the loss, had become the property of the consignee. Since then, it has generally been accepted that the same result follows even though the consignee has neither title, risk, nor an immediate right to possession of the goods. It has also generally been assumed that the consignor holds the damages for the benefit of the true owner.