IN the Court of Appeal in Patel v Mirza  EWCA Civ 1047;  Ch. 271, Gloster L.J., in sympathy with the “hapless law student”, said of the illegality concept “it is almost impossible to ascertain … principled rules from the authorities relating to the recovery of money or other assets paid or transferred under illegal contracts” (at ). The Supreme Court ( UKSC 42;  3 W.L.R. 399) has clarified the law in many respects. In other respects, it may have created some new uncertainties and no diminution in work for inventive lawyers and some of their more dubious clients.