InRedland Bricks Ltd. v. Morris Lord Upjohn, in a speech with which all the other Law Lords agreed, asserted that the Court of Appeal had been wrong to consider the applicability of Lord Cairns' Act. Much of the judgments, he observed, had been taken up with a consideration of the principles laid down in Shelfer v. City of London Electric Lighting Co., a case concerned exclusively with the proper principles upon which in practice Lord Cairns' Act should be applied. Neither Lord Cairns' Act nor Shelfer's case, he said in terms, had anything whatever to do with the principles of law appli-cable to the case then before the court. It is accordingly crystal clear that Lord Upjohn regarded Lord Cairns' Act as totally irrelevant: what is less clear is the reason for his opinion.