 The rule applies even if the later assignee made no enquiries of the trustees and even if the first assignee was not negligent in failing to give notice, for instance because he was not aware of it or because there was no one to whom notice could be given.In "Ward v Duncombe" [1893] AC 369, the House of Lords decided that the rule that notice determines priority of dealings applied regardless of the conduct of the competing assignees.In spite of the criticisms of the way in which the rule in "Dearle v Hall" has developed, there is much to be said for the concept that the priority of assignments or charges over debts should, as a general rule, depend on the date notice is given to the person who owes the debt.