Corporate Veil and Limited Liability in International Business Law

This article discusses the concept of corporate veil and limited liability in international business law. It explains the circumstances where the corporate veil should be lifted and provides case examples to support the arguments. The article also highlights the benefits of limited liability for shareholders and the risks for creditors.

International business law

A company is considered to be a separate legal entity because it is distinct from its
shareholders. When an organization comes under the corporation act then it becomes a
separate legal personality. Thus, an organization has many rights as per the law. The
company has the right to purchase immovable and movable properties, enter into contracts,
have its own nationality, domicile and name and be sued and to sue. The change in the
directors or shareholders will not affect the existence of the company. The shareholders will
not be accountable for the debts of the company which is known as “limited liability”1In the
case of partnerships, it is different as the partners would be liable for their debts if the
partnership assets are not sufficient in covering the debts. A company has a separate legal
personality which is different from its shareholders. It is found that the legal personality can
be ignored in order to make the shareholders liable for the debts of the company. The process
is known as "lifting corporate veil”.
The veil of incorporation ensures a separate legal personality of the company remains intact.
It provides inconsistent protection to the organization and its members. The case Salomon v
Salomon has established this doctrine. The principle assists to encourage investments as the
investors are stimulated to invest in financial markets, commerce and trade industries,
although being aware of the commercial risk. The corporate veil is considered to be a
situation where the shareholders are allowed to be a spate legal entity in a newly incorporated
organization. In other words, the shareholders would enjoy the limited liability. The
introduction of the Limited Liability Act in the year 1855 leads to the formation of limited
liability rule. The Joint Act Stock Companies Act 1856 replaced the Limited Liability Act in
the year 1856. A company till 1855 Act was needed to include Ltd or limited to its name.
The rule of incorporating the corporate veil has affected the “limited liability principle” is
still considered to be a controversial topic where the corporate veil is being lifted by the court
and directly looking into the shareholders. Salomon v Salomon introduced limited liability in
which members have a separate legal entity in which they are not liable for the company's
debts and also not responsible for paying the debt amount to the creditors. The corporate veil
in some circumstances is pierced. It can be examined with the help of cases in which sets of
evidence and facts is almost similar to the principle.
1 Keith Abbott, N Pendlebury and Kevin Wardman, Business Law (Cengage Learning 2013).
1

The corporate veil is being lifted in some circumstances by the courts but they are set of rules
which are not included in code or unified to provide a clearance for the occurrence of
boosting the corporate veil. The limited liability provides benefits to the shareholders of
obtaining profits from the commercial dealings of the company and they would not be liable
for the debt incurred by the company2. However, the interests of the creditors can be put at
risk were the personal guarantees are not provided by the company. The corporate veil
provides protection does not mean that the dealing of the company cannot be examined by
the public. The public is also allowed to see sales, budgets and accounts.
Mr Salomon in Salomon v Salomon case was required to include seven members on the
company's board as per the law. He allocated six shares to his six family members consisting
of his wife. The business consequently sold by him to a new corporate organization where he
has 20001 out of 20007 shares3. He was the managing director and he had full control over
the company because he owned the majority of shares. The company after sometime wound
up and the company were sued by the creditors who owed money and claim to return their
money from Mr Salomon. The arguments were considered to be valid by the court but in
contrary to the appeal, House of Lords stated that the creditors have no right to seek into who
and what is behind the organization which means Mr Salomon. The company has all the right
to carry out its affairs as per the needs and goals. The House of Lords, in this case, applied
strictly the “limited liability" principle by not taking a decision on piercing the corporate veil.
“Wood v Dummer” also depicted the court in the United States approved the limited liability
principle. The shareholders, in this case, are liable for the debts which are being incurred by
the bank to the creditors4.
It must be stated that a line may be drawn between privacy case and avoidance case. The case
low must be outlined clearly to demonstrate where the case came from. The case of Gilford
Motor Co Ltd v Horne is a famous case, in which a worker defending himself. He was
working with the company and was on a contractual agreement that he will not engage in any
competition against the employer5. But later he resigned from his post and set up his own
company and started offering the same services which he used to offer while working with
2 John Robert Allison and Robert A Prentice, Business Law (University Co-Op 2009).
3 Salomon v. Salomon, 'Salomon V. Salomon & Co Ltd [1897] AC 22 | Trans-Lex.Org' (Trans-lex.org, 1897)
<https://www.trans-lex.org/310810/_/salomon-v-salomon-co-ltd-%5B1897%5D-ac-22/> accessed 5 December
2018.
4 Wood v. Dummer, 'Wood V. Dummer, 30 F. Cas. 435 | Casetext' (Casetext.com, 1824)
<https://casetext.com/case/wood-v-dummer> accessed 5 December 2018.
5 Gilford Motor Co Ltd v Horne, '"Gilford Motor Co Ltd V Horne" On Revolvy.Com' (Revolvy.com, 1933)
<https://www.revolvy.com/page/Gilford-Motor-Co-Ltd-v-Horne> accessed 5 December 2018.
2

the previous company. It was done purposively to avoid the duties which were agreed and
signed by Horne under an agreement. The Court needs to decide whether the company was
legitimate of shame. The court had given an order to Horn and his company and the decision
was Horn would not compete as he breached the contract which was signed between Gilford
Motor Co Ltd and him.
The case of Jones v Lipman has clarified the circumstances that can be considered under the
act of "concealment" in regards to concealment case. According to this case, it was agreed by
the Lipman to sell a property even though he did not want to. Later a company was bought by
him, which was off-shelf. The property owner was being transferred to the company which he
formally intended to sell. A specific performance was ordered by the Court of Appeal6. The
decision which was taken by the Court against the company faced disagreement between the
justices. It was being argued by some people that the principles had been engaged in did not
require piercing the veil. It was also being argued Lipman should have been ordered to
transfer back the property ownership without any involvement on the company.
It the case of Adams v Cape Industry the various arguments were rejected by the court
presented by the defendants. It was against the English present company Cape Industry Plc.
and for claiming the damage or compensate. Cape Industry Plc. was an English company and
at the same times, a holding company as well to many other subsidiaries7. The person who
claimed become successful in this case and was being awarded the damages by the court of
Texas for the personal injuries. But the decision was not enforced to the English parent
company as per the Court of Appeal. The argument of the defendants was rejected by the
Court. It was present in the following manner, (i) the subsidiaries and the company itself
Cape Industry Plc. should be managed as "singe economic units, (ii) a "façade" was being
used to hide the true facts, (iii) A relationship of agency was presented between cape and its
subsidiaries. All these three arguments were fixed. On the basis of these three scenarios, the
fourth one was piercing the veil is justifiable.
The three arguments that were presented in the Court were being dealt with separately. It was
also explained by the court that way all these three arguments were rejected. In detail, the
reason of rejection of the first argument was "indisputable" as every company had their own
separate legal entity, and this is what justice requires for8. The definition of fundamental
6 Denise Collins, Business Law (Oxford University Press 2009).
7 Malcolm D Evans, International Law (Oxford University Press 2018).
8 Franklin A Gevurtz, Global Issues In Corporate Law (Thomson West 2006).
3

principal was being stated by Slade LJ, according to him, there is a separate legal entity for
every group of companies with separate legal liabilities and rights. The second argument can
be considered as a key to the topic. It is related to the principle of corporate veil Lord Keith,
who started the claimant and was being submitted to the court. It can be considered as a
device which contains corporate structure endeavour to evade:
(i) The limitation was being imposed by law on his conduct,
(ii) The right of relief against the third parties possess,
(iii) The right of relief in the future acquire as third parties.
There are three conditions which can be considered as a landmark of “Woolfson v Strathclyde
Region Council". It was being held by the court in the rejection of the third argument that
there will be a change in regards to the way being used by Cape Industry in managing their
affairs, rejecting the third argument. It was being held by the court in the third argument that
an exclusive dealing was being performed by NAAC which was separate from the parent
company Cape Industry Plc.
In regards to treating group companies a related case can be considered as the single
economic unit. The DHN Food Distributor v Tower Hamlets LBC, case shows DND operate
its business using a wholly two owned subsidiaries9. One of them was responsible for
producing the products and the other one was for distributing the products. One of the
subsidiary's premises had been purchased by the council forcefully. As a result, three
companies faced the consequences and went into liquidation. As they were not able to find
suitable premises to continue doing business. It was being found by the Court the three
companies can be considered as one single company, as because they rely on each other to
run the business and to become successful. This states that the parent company deserves to
get compensation on the basis of its wholly owned subsidiary.
In regards to Woolfson case, The House of Lord stated that when the veil is a mere
concealment in true facts in this scenario piercing of veil may occur. Here it can be noticed
that this case is a bit similar to the cases of DHN. Here subsidiary owned the compulsory
acquisition of the part of the land, not the whole land, Woolfson owned and he claimed that
he was the owner and occupied the land for the purpose of compensation 10. The argument
was being rejected by the house of the lord and mentioned that there is no sign of any special
9 DHN Food Distributors Ltd v Tower Hamlets Council, 'DHN Food Distributors Ltd V Tower Hamlets Council
[1976] 1 WLR 852 Case Summary' (Lawteacher.net, 1976) <https://www.lawteacher.net/cases/dhn-v-tower-
hamlets.php> accessed 5 December 2018.
4

condition that can justify that the corporation was a mere concealment the true facts. Mare
façade was considered and applied later in above-mentioned case of Adams and the Trustor
AB v Smallbone11. As per the case of Tutor, it was being found that £20m was missing from
the account of claimant's company. The managing director of claimant's company who owns
a different company, amount of £20m was being found into his company's account. Both the
company was owned by the defendant as the defendant was only one so he must be held
responsible, argued by the claimant. A mere façade test was applied by the claimant's
company. It was being found by the court that the company was a "device or a façade that
had been using the money of claimant. Same can be noticed in Gencor ACP Ltd v Dalby case
where fiduciary duty had been breached by the director of the company for his personal
profit. It was being transferred to a company which was incorporated on his name in order to
receive those profits12. The company had not employed any staff and the bank account was
only a oversee account and was being used only to get a receipt of the money, stated by the
court.
The circumstances were being considered by courts where the corporate veil should be lifted.
The arguments can be supported further by the case examples. The first thing is that veil
piercing is essential for achieving justice. “Re A Company” case fulfils the above-stated
condition where the court stated that the piercing the veils is considered to be necessary for
achieving the justice. “Adams v Cape Industries Plc” case depicted that Slade LJ told that the
piercing of veil can occur where the organization is a mere disguise concealing the fair and
true facts13. It was also stated by him that “it is not acceptable that the court is being entitled
of lifting the corporate veil as a matter of law against the defendant organization which is the
member of a merely corporate groups because the structure of the company has been utilized
for ensuring that the legal liability is there for specific future actions of the group will fall
under another group member rather than the defendant organization. The right of using the
corporate structure whether or not is necessary is the way it is being inherited in the corporate
law. The decision in the “Ord v Bell have Pubs Plc” case also influenced the decision taken
10 Woolfson v Strathclyde Regional Council, '"Woolfson V Strathclyde Regional Council" On Revolvy.Com'
(Revolvy.com, 1978) <https://www.revolvy.com/page/Woolfson-v-Strathclyde-Regional-Council> accessed 5
December 2018.
11 Trustor AB v Smallbone, '"Trustor AB V Smallbone (No 2)" On Revolvy.Com' (Revolvy.com, 2001)
<https://www.revolvy.com/page/Trustor-AB-v-Smallbone-(No-2)> accessed 5 December 2018.
12 Gencor ACP Ltd v Dalby, '"Gencor ACP Ltd V Dalby" On Revolvy.Com' (Revolvy.com, 2000)
<https://www.revolvy.com/page/Gencor-ACP-Ltd-v-Dalby> accessed 5 December 2018.
13 Adams v Cape Industries, 'The Principle Of Separate Corporate Personality' (Lawteacher.net, 1990)
<https://www.lawteacher.net/free-law-essays/business-law/adams-v-cape.php> accessed 5 December 2018.
5

in the case “Adams v Cape Industries Plc”. Thus, the court of appeal in the former case stated
that restructuring and reframing the group of organizations was legit which was held in the
first instance in the court14.
The “Creasy v Beachwood Motors Ltd" case shows that the incorporation of the veil was
pierced because of illegal or improper conduct. The directors of the company were the
defendant in this case who transferred the ownership of the assets to another organization15.
Thus, in this case, the decision was disputed strongly in the course of the Ord v Bellhaven
Pubs Plc case. The decision of the Supreme Court can be found recently in the “Prest v
Petrodel Resources Ltd”. The decision was made were a divorced wife claimed that the
ownership of the properties was being held of trust and fairness by the husband. It was being
stated by the Supreme Court that unless some situation exists, the piercing of veil is not
considered to be appropriate16. The situation exists where an individual is subjected to
liability or under the legal obligation and he is evading intentionally the legal restrictions by
incorporating an organization under his control. The Supreme Court outlined the
circumstances which is clear and ambiguous when piercing the veil case is likely to arise.
The corporate veil is expected to be pierced in some circumstances where the formation of
the separate legal entity is formed in such a manner that it achieves the fraudulent
commissions. The fraudulent acts, in other words, are considered to be illegal and to achieve
justice is based on the corporate veil. The “Standard Chartered Bank v Pakistan Shipping
Corporation” case depicted that the two elements need to be considered by the Supreme
Court in order to examine if the managing director organization can be liable for the
fraudulent or inappropriate misrepresentation in the tortuous liability17. It was also used to
examine if the contributory negligence can be taken into account for decrease the damages as
per the fraudulent misrepresentation. The main concern is associated with the first element in
which the managing director of Oakprime Ltd, Mr Mehra arranged a bill of lading which is as
14 Ord v Belhaven Pubs Ltd, '"Ord V Belhaven Pubs Ltd" On Revolvy.Com' (Revolvy.com, 1988)
<https://www.revolvy.com/page/Ord-v-Belhaven-Pubs-Ltd> accessed 5 December 2018.
15 Creasey v Breachwood Motors Ltd, '"Creasey V Breachwood Motors Ltd" On Revolvy.Com' (Revolvy.com,
1993) <https://www.revolvy.com/page/Creasey-v-Breachwood-Motors-Ltd> accessed 5 December 2018.
16 Prest v Petrodel Resources Ltd & Others, 'Prest V Petrodel Resources Ltd & Others [2013] UKSC 34'
(Lawteacher.net, 2013) <https://www.lawteacher.net/cases/prest-v-petrodel-resources.php> accessed 5
December 2018.
17 Standard Chartered Bank v Pakistan National Shipping Corporation, 'Standard Chartered Bank V Pakistan
National Shipping Corporation, Standard Chartered Bank V Pakistan National Shipping Corporation And Others
And Another And Others (Nos 2 And 4): HL 6 Nov 2002 - Swarb.Co.Uk' (swarb.co.uk, 2002)
<https://swarb.co.uk/standard-chartered-bank-v-pakistan-national-shipping-corporation-standard-chartered-
bank-v-pakistan-national-shipping-corporation-and-others-and-another-and-others-nos-2-and-4-hl-6-nov-
2002/> accessed 5 December 2018.
6

his knowledge was backdated. It was found that a false statement was being produced for
claiming money from the Standard Chartered Bank Under the letter of credit. The false
statement was not being known to the bank because it would not have been issued funds in
the first place. Therefore, dependence on the fraudulent misrepresentation is considered to be
sufficient enough for lifting the corporate veil and holding it behind its liability18.
The “Daimler v. Continental Tyre and Rubber Co. Ltd" case depicted that during the First
World War the Trading with the Enemy Act 1914 was formed which included dealing with
the enemy is considered to be a criminal offence. The case depicted that Continental Tyre
British Company consists of directors and shareholders of German nations were dealing with
the offence. Thus, it is the situation which depicts that the corporate veil was being pierced19.
A company ultimately is considered to be legal personality when it is incorporated under the
provisions of rules and laws. It means that the company entering into the contract is liable to
the other contracting parties. If a company, for instance, is getting a loan from a bank then the
organization itself is liable for repaying the loan amount and not the shareholders. The
corporate veil is considered to be a shield that protects the shareholders and directors of the
company from being sued by the lenders or creditors of the organization. The veil is referred
to the legal personality obtained by the company on the basis of incorporation20. There are
many expectations which can be determined to this rule. It is found that the exceptions
consists of but not limited to committing improper or illegal conducts, avoiding legal
obligations, trading with enemy, concealment and evasion of taxes and forming a subsidiary
for acting as an agent. The main reason behind the establishment of these exceptions is of
achieving justice and especially protecting the creditors. The protection of the creditors in
some of the cases is not considered to be an issue. The example of such case is trading with
the rivals or enemies where the protection of the interest of the public is the main concern.
There are many statutory provisions which affect the ignorance of the subsistence of the
separate legal of the organization by increasing the debts to its members. The decrease in the
number of members of an organization below the requirement need under Section 36
Companies Act 1963 which is seven for public company and two for private company for
18 William W Lace, The Anasazi (Lucent Books 2005).
19 Daimler Co., Ltd v. Continental Tyre and Rubber Co., 'Daimler Co., Ltd V. Continental Tyre And Rubber Co.
(Great Britain), Ltd And Another | United Kingdom House Of Lords | Judgment | Law | Casemine'
(Casemine.com, 1916) <https://www.casemine.com/judgement/uk/5a8ff8de60d03e7f57ecec0a> accessed 5
December 2018.
20 Robert R Pennington, Company Law (Oxford University Press 2006).
7

more than six month period then each and every individual would be liable for the debt
incurred by the organization21.
The Hunting Lodges Limited 1985 case shows that the High Court stated that the buyer of the
main assets and directors would be liable for the debt of the company after it becomes
apparent that the asset amount paid by the buyer is through payable of three bank drafts to
fictitious individuals that were being deposited in the building society by one director22.
Section 297 Companies Act 1963 explains that an individual who is carrying out the business
of an organization in an inappropriate or reckless manner knowingly would be personally
held liable without the limits for debts of the organization. If an organization has the
subsidiary undertaking under the section 150 Companies Act 1963 then the accounts for the
consolidated group should be prepared for depicting the assets/liabilities and profit and losses
of the group. The lifting of the corporate veil can be done for determining a
subsidiary/holding company relationship.
The court has many strategies for making decision of whether or not lifting the corporate veil.
However, it is not easy of extracting the general principle and the court does not allow the
veil of incorporation for the fraudulent purposes to be used23. “Jon v Lipan” case depicts that
a house was being sold to a new company for avoiding an order given against him for a
specific programme of selling the house to an organization established by him24. The court
explains the company as a sham and a device which holds a face of avoiding the recognition
by the law of equity. The parent-subsidiaryy relationship in the same group between the
companies is considered to be as the single entity. The veil was lifted for reflecting the
commercial and economic realities of the circumstance. The separate legal entity has
answered both to the social need and political will. It has also supported the development of
the economy and providedan opportunity to everyone for becoming the part of the economy.
The theories, laws andevidences have depicted that the company should be considered as the
21 Law Teacher, 'A Company Is A Separate Legal Entity As Distinct From Its Members' (Lawteacher.net, 2018)
<https://www.lawteacher.net/free-law-essays/business-law/separate-legal-entity-as-distinct-from-its-
members-business-law-essay.php> accessed 5 December 2018.
22 Law Teacher, 'Separate Legal Personality Of A Company' (Lawteacher.net, 2018)
<https://www.lawteacher.net/free-law-essays/business-law/separate-legal-personality-of-a-company-
business-law-essay.php> accessed 5 December 2018.
23 Günter H Roth and Peter Kindler, The Spirit Of Corporate Law (Beck 2013).
24 Jones v Lipman, 'Jones V Lipman [1962]' (Lawteacher.net, 1962) <https://www.lawteacher.net/cases/jones-
v-lipman-1962.php> accessed 5 December 2018.
8

separate legal personality. According to the law, every citizen of the country needs to follow
the legal rules and regulations25.
25 Neil Walker, Intimations Of Global Law (Cambridge University Press 2015).
9

References
Abbott K, N PendleburyK Wardman, Business Law (Cengage Learning 2013)
Adams v Cape Industries, 'The Principle Of Separate Corporate Personality' (Lawteacher.net,
1990) <https://www.lawteacher.net/free-law-essays/business-law/adams-v-cape.php>
accessed 5 December 2018
Allison JR Prentice, Business Law (University Co-Op 2009)
Collins D, Business Law (Oxford University Press 2009)
Creasey v Breachwood Motors Ltd, '"Creasey V Breachwood Motors Ltd" On Revolvy.Com'
(Revolvy.com, 1993) <https://www.revolvy.com/page/Creasey-v-Breachwood-Motors-
Ltd> accessed 5 December 2018
Daimler Co., Ltd v. Continental Tyre and Rubber Co., 'Daimler Co., Ltd V. Continental Tyre
And Rubber Co. (Great Britain), Ltd And Another | United Kingdom House Of Lords |
Judgment | Law | Casemine' (Casemine.com, 1916)
<https://www.casemine.com/judgement/uk/5a8ff8de60d03e7f57ecec0a> accessed 5
December 2018
DHN Food Distributors Ltd v Tower Hamlets Council, 'DHN Food Distributors Ltd V Tower
Hamlets Council [1976] 1 WLR 852 Case Summary' (Lawteacher.net, 1976)
<https://www.lawteacher.net/cases/dhn-v-tower-hamlets.php> accessed 5 December
2018
Evans M, International Law (Oxford University Press 2018)
Gencor ACP Ltd v Dalby, '"Gencor ACP Ltd V Dalby" On Revolvy.Com' (Revolvy.com,
2000) <https://www.revolvy.com/page/Gencor-ACP-Ltd-v-Dalby> accessed 5
December 2018
Gevurtz F, Global Issues In Corporate Law (Thomson West 2006)
Gilford Motor Co Ltd v Horne, '"Gilford Motor Co Ltd V Horne" On Revolvy.Com'
(Revolvy.com, 1933) <https://www.revolvy.com/page/Gilford-Motor-Co-Ltd-v-Horne>
accessed 5 December 2018
10

Jones v Lipman, 'Jones V Lipman [1962]' (Lawteacher.net, 1962)
<https://www.lawteacher.net/cases/jones-v-lipman-1962.php> accessed 5 December
2018
Lace W, The Anasazi (Lucent Books 2005)
Law Teacher, 'A Company Is A Separate Legal Entity As Distinct From Its Members'
(Lawteacher.net, 2018)
<https://www.lawteacher.net/free-law-essays/business-law/separate-legal-entity-as-
distinct-from-its-members-business-law-essay.php> accessed 5 December 2018
Law Teacher, 'Separate Legal Personality Of A Company' (Lawteacher.net, 2018)
<https://www.lawteacher.net/free-law-essays/business-law/separate-legal-personality-of-
a-company-business-law-essay.php> accessed 5 December 2018
Ord v Belhaven Pubs Ltd, '"Ord V Belhaven Pubs Ltd" On Revolvy.Com' (Revolvy.com,
1988) <https://www.revolvy.com/page/Ord-v-Belhaven-Pubs-Ltd> accessed 5 December
2018
Pennington R, Company Law (Oxford University Press 2006)
Prest v Petrodel Resources Ltd & Others, 'Prest V Petrodel Resources Ltd & Others [2013]
UKSC 34' (Lawteacher.net, 2013) <https://www.lawteacher.net/cases/prest-v-petrodel-
resources.php> accessed 5 December 2018
Roth GP Kindler, The Spirit Of Corporate Law (Beck 2013)
Salomon v. Salomon, 'Salomon V. Salomon & Co Ltd [1897] AC 22 | Trans-Lex.Org'
(Trans-lex.org, 1897) <https://www.trans-lex.org/310810/_/salomon-v-salomon-co-ltd-
%5B1897%5D-ac-22/> accessed 5 December 2018
Standard Chartered Bank v Pakistan National Shipping Corporation, 'Standard Chartered
Bank V Pakistan National Shipping Corporation, Standard Chartered Bank V Pakistan
National Shipping Corporation And Others And Another And Others (Nos 2 And 4): HL
6 Nov 2002 - Swarb.Co.Uk' (swarb.co.uk, 2002) <https://swarb.co.uk/standard-
chartered-bank-v-pakistan-national-shipping-corporation-standard-chartered-bank-v-
pakistan-national-shipping-corporation-and-others-and-another-and-others-nos-2-and-4-
hl-6-nov-2002/> accessed 5 December 2018
11

Trustor AB v Smallbone, '"Trustor AB V Smallbone (No 2)" On Revolvy.Com'
(Revolvy.com, 2001) <https://www.revolvy.com/page/Trustor-AB-v-Smallbone-(No-2)>
accessed 5 December 2018
Walker N, Intimations Of Global Law (Cambridge University Press 2015)
Wood v. Dummer, 'Wood V. Dummer, 30 F. Cas. 435 | Casetext' (Casetext.com, 1824)
<https://casetext.com/case/wood-v-dummer> accessed 5 December 2018
Woolfson v Strathclyde Regional Council, '"Woolfson V Strathclyde Regional Council" On
Revolvy.Com' (Revolvy.com, 1978) <https://www.revolvy.com/page/Woolfson-v-
Strathclyde-Regional-Council> accessed 5 December 2018
12