I-Admin (Singapore) Pte Ltd v Hong Ying Ting [2020] SGCA 32 [19.12]), English courts have applied Lord Cairns’ Act in relation to purely equitable rights including breaches of confidence. Besides ordering the delivery up of confidential drawings in the defendant’s possession, the Court of Appeal in Saltman called for an inquiry on “what damages have been and may be suffered … by reason of the [d]efendant’s breaches of confidence” (per Cohen J at 219). 75 The decision in Seager produced a similar outcome, although the award of damages was not expressly made under Lord Cairns’ Act. The plaintiff in that case invented a carpet grip and obtained a patent for it. He then commenced negotiations with the defendant company to market the grip. During negotiations, the plaintiff described, in confidence, the features of his design as well as a potential alternative design. When the parties’ discussions concluded unsuccessfully, the defendant went on to produce its own carpet grip, embodying the alternative design disclosed by the plaintiff. Lord Denning MR opined that the defendant had to pay for the advantage it had gained by using information received in confidence. He then stated that “[i]t may not be a case for injunction or even for an account, but only for damages, depending on the worth of the confidential information to [the defendant] in saving him time and trouble” (Seager at 932). The court went on to order an inquiry by a Chancery master (the “Master”) for damages to be assessed. 76 In proceedings before the Master, the plaintiff advanced two alternative bases for the computation of damages: capitalised royalties or the loss suffered by his carpet grip business. The defendant proposed that reasonable remuneration should be the cost of hiring a consultant who would have provided information of the character of the plaintiff’s confidential information. The Master decided that the Court of Appeal should determine which of the three bases was correct. In Seager v Copydex Ltd (No 2) [1969] 1 WLR 809 (“Seager 36