Insolvency – Bankrupt's estate. In a situation where the appellant had been made bankrupt twice, future payments under an income payments order (an IPO) were provable debts in a later bankruptcy commencing after the bankrupt had been discharged from the earlier bankruptcy. The Court of Appeal, Civil Division held, in allowing the appellant's appeal, that future IPO payments were not enforceable by the trustee in the earlier bankruptcy against the bankrupt and that recovery of future IPO payments was restricted to proof in the later bankruptcy.