POWERS OF ATTORNEY 
283 
transaction already binding on the principal and not involving 
the passing of any interest vested in the trustee in bankruptcy 
[Markwick v. Hardingham (1880), 15 Ch. D. 339]; and this 
rule is also without prejudice to the rights conferred on third 
parties by ss. 40 to 47 of the Bankruptcy Act, 1914, in respect 
of transactions entered into bona fide and without notice 
of an act of bankruptcy. By s. 22 of the last-mentioned 
statute a bankrupt is bound to execute such powers of attorney 
as may be reasonably required by the Official Receiver or the 
trustee in bankruptcy, or as may be prescribed by the Bank- 
ruptcy Rules or directed by the Court, in order to effect the 
due administration of his estate; and by s. 55 (4) a trustee 
in bankruptcy may execute any power of attorney for the 
purpose of carrying into effect the provisions of the Act. 
Where a company has given a power of attorney, liquida- Liquidation 
tion has apparently at common law the same effect as the of Donor 
bankruptcy of an individual donor, i.e. it revokes the power Bompazy. 
[re Oriental Bank (1885), 28 C.D. 634; and as to dissolution of 
a company, see Salton v. New Beeston Cycle Co. (1900), 1 Ch. 
43]. There is, however, the same statutory protection as in 
the case of bankruptcy; for bys. 205 of the Law of Property 
Act, 1925, the expression ‘bankruptcy’ in ss. 124, 126, and 
127 includes liquidation. 
A liquidator has power to appoint an agent to do any 
business which he is unable to do himself [Companies Act, 
1929, s. 191 (2)]. 
[t is probably still an open question whether bankruptcy 
of the attorney automatically revokes the power. There are 
dicta to this effect, as in the old case of Hudson v. Granger 
(1821), 5 B. & A. 27 relating to a factor. On the other hand, 
it was held in McCall v. Australian Meat Co. (1870), 19 W.R. 
188, in relation to an agency contract, that it was a question 
of fact in each case whether the circumstances of the bank- 
ruptcy, having regard to the nature of the agent’s duties and 
the terms of his employment, were such as to render the agent 
unfit to carry out his agency. 
Possibly the only safe course for the principal to take on 
hearing of his attorney’s bankruptcy is to execute an express 
revocation of the power, without prejudice to any prior revoca 
tion which may have arisen by operation of law. 
Ratification of an unauthorized act may be given expressly Ratification. 
in writing or verbally, or may be implied either by some 
adoptive act or by silent acquiescence after knowledge of the 
irregularity. The effect of ratification is thrown back to the 
date of the act done, and the agent is put in the same position 
as if he had had authority to do the act at the time the act