Traditionally, the remedy available to a charge holder, including a floating charge holder, has been to appoint a receiver over the property that forms the subject matter of the charge.1 Receivership as a remedy developed historically in the context of real property. The remedy developed because secured creditors were reluctant to take possession of mortgaged property on account of the potential risks in incurring a liability to the mortgagor.2 A secured creditor who went into possession was liable on the basis of 'wilful default'. In consequence, the practice developed of the mortgagee instead appointing a receiver and manager who would take possession of the mortgaged business and proceed to run its operations with a view to using the proceeds so as to reduce the secured debt.3 Also, contracts of loan began to specify that any receiver appointed would be deemed to be the agent of the mortgagor rather than the mortgagee. This state of affairs has