In Bunge Corp. v. Manufacturers Hanover Trust Co., 31 NY2d 223 [1972] the dishonest employee of the remitter of an official bank check delivered the check to the named payee but then (with the assistance of a confederate in the payee's employ) stole it back and returned it to the bank, which cancelled it and gave the remitter a credit. The Court of Appeals determined that while an action could presumably be maintained by the payee against the remitter, equitable estoppel would bar the payee from pursuing a claim against the bank. The Court held that upon the check's return by the remitter the bank had no obligation to the named payee to make any inquiry of the named payee before cancelling the check. In a dissent, Judge Breitel objected that freeing the bank of the obligation to make some inquiry of the specific person to whose order the check was made would obliterate the "distinction between order paper and bearer paper." (31 NY2d, at 236.)