I-Admin (Singapore) Pte Ltd v Hong Ying Ting [2020] SGCA 32 of its materials. Likewise, equitable compensation would be inappropriate. The restitutionary objective of equitable compensation requires that a plaintiff be restored to the same position they would have been in if the breach had not been effected. However, as noted by Prof Brennan, this may prove to be a highly speculative exercise, particularly where there has been no actionable use of the confidential information. 73 This leaves a possible award of equitable damages, a statutory remedy under s 2 of the Chancery Amendment Act 1858 (c 27) (UK) (“Chancery Amendment Act”) where a court “is not limited to any specific basis for assessing damages” (Lunn Poly Ltd and another v Liverpool & Lancashire Properties Ltd and another [2006] 2 EGLR 2 at [22]). Prior to the enactment of the Chancery Amendment Act, one of the Acts which led to the combined administration of law and equity, the English Courts of Chancery sporadically used their power to award monetary compensation but ordinarily considered it undesirable to do so (Breach of Confidence at [19.10]; see also, I.C.F. Spry, The Principles of Equitable Remedies: Specific Performance, Injunctions, Rectification and Equitable Damages (Lawbook Co, 8th Ed, 2010) at p 623)). Section 2 of the Chancery Amendment Act, better known as Lord Cairns’ Act, provided that: [where] the Court of Chancery has jurisdiction to entertain an application for an injunction … against the commission or continuance of any wrongful act … it shall be lawful for the same Court … to award damages … either in addition to or in substitution for such injunction or specific performance, and such damages may be assessed in such manner as the Court shall direct. 74 Notwithstanding initial debate as to the intended scope of s 2 and whether the phrase “wrongful act” was envisaged to include causes of action that fell within the exclusive jurisdiction of equity (Breach of Confidence at 35

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