Friday, 30 May 2014

Fraudulent Misrepresentation by a Company - UK Landmark (Derry v. Peek)


(1889) LR 14 App Cas 337
1. The prospectus of a train company (defendant Company) stated that on the basis of a new law they could use steam powered trams instead of horse powered ones.
2. On the basis of this information, the plaintiff bought shares in the company.
3. However, the information was not completely accurate since the use of steam power was subject to approval of the Board of Trade. The right to use had never been refused before and the defendant company honestly believed that they would get the approval.
4. The Board of Trade refused and the company wound up. The plaintiff sued the Chairman and 4 directors of the defendant company.
5. It was held by the House of Lords that the statement was made in honest belief and hence did not amount to fraud. A statement would be fraudulent only if made (a) knowing it to be false; (b) without believing it to be true; (b) recklessly without taking care if it was true or not.


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