Indeed, there does not seem to be any basis on which these would
be limited to just payment obligations and so performance obligations would be included by these words
McBain has said and cited Goode for the proposition that although common law liens ‘can cover obligations other than debts it appear[s] that the majority (and, perhaps, all) common law liens have only covered debts, in practice’. McBain (n 11)[n 19];
Roy Goode, Hire-Purchase Law and Practice (2nd edn
Butterworths 1970).