While it is possible to be in possession of goods without knowledge of their presence, their nature, their location or even their existence1, possession without knowledge of what is possessed does not generally render the possessor a bailee. However, although a possessor who is unaware that he is in possession of goods belonging to another is not a bailee, he may owe to the owner a duty to take reasonable care to identify the owner's interest before destroying or otherwise dealing in the goods2. Three situations have been identified where 'undisclosed or surreptitious bailment' may
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