In Welch v. Scott, [1920] 2 W.W.R. 510 (B.C.C.A.), it was held that no such lien existed. The very idea was considered absurd. Galliher J.A. stated: If a dozen or a hundred persons can come together and create a lien by some secret arrangement among themselves which the public know nothing about, then there would be no need for legislation along such lines.
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