Joe is responsible for buying supplies for the business where he works and regularly brings his boss purchase orders to sign. Being short of cash one day, he writes up a company cheque payable to himself and slips it in between two purchase orders so that only the signature line of the cheque is visible. He presents the papers to his boss who signs all three without question. The company subsequently refused to honour the cheque, and Joe sued. Ignoring the obvious criminal aspect, with reference to the factors necessary to make out an action in breach of contract and any defences, please assess the likelihood of success of Joe's lawsuit.