Equitable assignment of debt through endorsement on a promissory note is valid when intention to transfer is clear.

A written endorsement on a promissory note, signed by the transferor and made on the instrument itself, can operate as a valid equitable assignment even without express words of assignment if it clearly identifies the debt and directs payment to the transferee. The intention to transfer the debt may be inferred where the endorsed instrument is delivered with that direction. The absence of a stamp objection did not invalidate the assignment, as the necessary duty and penalty had already been levied. The endorsement was therefore treated as a valid equitable assignment in favour of the plaintiff.

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Issues: Whether the endorsement on the promissory note amounted to a valid equitable assignment in favour of the plaintiff.

Analysis: The endorsement was a written direction signed by the transferor and endorsed on the instrument itself. Though it did not use express words of assignment, it clearly identified the debt due under the promissory note and directed payment to the plaintiff. When such a direction is written on the instrument and handed over with it, the intention to transfer the debt can be inferred. The absence of stamp objection also did not affect validity, as the necessary duty and penalty had already been levied.

Conclusion: The endorsement constituted a valid equitable assignment in favour of the plaintiff.

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