Nielsen v Baldorino

Liability in deceit requires a false representation made knowingly, without belief in its truth, or recklessly (not caring whether it is true or false), intended to be and in fact acted upon by the claimant to its detriment; where directors deliberately make false representations as to a company's financial position to procure a management buy-out at an undervalue, they are liable in deceit and (with the requisite combination and intent to injure) for unlawful means conspiracy.