Saturday, 24 May 2014

Doctrine of Indoor Management in Company Law

Royal British Bank v. Turquand

Citation: (1856) 6 E & B 327

This case is a landmark judgment in UK company law and lays down the important Doctrine of Indoor Management which protects outsiders and third parties who have no way of knowing if the internal rules of the company are being complied with. The doctrine is now followed in most common law jurisdictions.  
The directors of the defendant company issued a bond to the plaintiff.
The articles of association of the defendant company provided that the directors of the company could borrow only on the basis of a general resolution passed.
When the plaintiff sued on the bond the defendant company pleaded that the required resolution had not been passed.

It was held that a person dealing with a company could assume that all the internal processes of the company are in order and have been complied with.   

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