Len's new secretary came in and asked him to sign four letters that he 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 his bank, and when his 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.Even if he was careless, Len will not have to honour the cheque.

b.Len would be obligated to honour the cheque no matter how careful he was.

c.Len may be able to avoid his obligation on the cheque on the basis of unconscionability.

d.Len may be able to avoid his obligation on the cheque on the basis of duress.

e.Len may be able to avoid his obligation on the cheque on the basis ofnon est factum.