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Wider policy considerations also support the respondents' case that bribes and secret commissions received by an agent should be treated as the property of

"Wider policy considerations also support the respondents' case that bribes and secret commissions received by an agent should be treated as the property of his principal, rather than merely giving rise to a claim for equitable compensation.... one would expect the law to be particularly stringent in relation to a claim against an agent who has received a bribe or secret commission". - Lord Neuberger, FHR European Ventures LLP v. Cedar Capital Partners LLC [2014] UKSC 45 at [42]. Critically analyse the law on bribes and secret commissions in light of the above statement, supporting your answer by reference to relevant legal and academic authority. In your opinion, should Irish courts follow the approach of the UK Supreme Court in Cedar Capital? Give reasons for your answer.

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