structural:summarization
Fraud

Employers have been responsible for the fraudulent misrepresentations of their employees since the mid-nineteenth century, under the decision of Barwick v English Joint Stock Bank. This liability was extended in the early 20th century, to cover fraudulent actions which were not of benefit to the employer, a previous requirement. Thereupon, the test for vicarious liability of fraud was whether it was within an employee's authority – either actual, or outwardly appearing – to carry out the fraudulent actions that he did. It was not enough that an employee merely asserted that he had supposed authority, however; the defrauded individual or company must have been assured or led to believe by the employer – or have inferred through standard dealings – that the employee in question had it.