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United Kingdom Leading Case conflict of interest s175minority protection

Howard Smith Ltd v Ampol Petroleum Ltd

[1974] AC 821
JurisdictionUnited Kingdom
CourtPrivy Council
Year1974
StatusBinding authority

Summary

Directors must exercise their powers for proper purposes; an allotment of shares designed primarily to frustrate a takeover bid constitutes an improper exercise of power.

Key Principle

directors must exercise powers for proper purposes; allotment to frustrate takeover improper

Area of Law

Company and Partnership

Related Cases

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Directors' exercise of power to issue restriction notices is vitiated if the predominant purpose is improper, applying the proper purpose doctrine to board powers.

Bilta (UK) Ltd v Nazir (No 2) [2015] UKSC 23

A director's fraud cannot be attributed to the company so as to enable the wrongdoer to invoke the illegality defence against the company's own claims.

Prest v Petrodel Resources Ltd [2013] UKSC 34

The corporate veil may only be pierced where a person under an existing legal obligation deliberately interposes a company to evade it; the concealment principle is distinct and does not pierce the veil.

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