Len's new secretary asked him to sign four letters that she said concerned general office matters. One of the "letters" was, in fact, a cheque for $500, payable to the secretary. The secretary cashed the cheque at her bank, and when her bank presented the cheque for payment, Len refused to pay it. He said he had been tricked and it was all a mistake. On these facts, which of the following is true?

a	Len would be obligated to honour the cheque no matter how careful he had been.
b	Even if Len had been careless, he will not have to honour the cheque.
c	Len may be able to avoid his obligation on the cheque on the basis of duress.
d	Len may be able to avoid his obligation on the cheque on the basis of unconscionability.
e	Len may be able to avoid his obligation on the cheque on the basis of non est factum.