Section 14 states that terms are implicitly about quality and title and are only relevant where the seller is acting "in the course of a business". There is no requirement as to the status of the buyer. The phrase "in the course of a business" has received much judicial consideration. Some judges have applied definitions found in other acts, but the case of "Stevenson v Rogers" gives a wide definition to this requirement. It will encompass activity which is ancillary or loosely related to the business of a company. To use Richards' example, a bank that sells a company car will be acting "in the course of a business".