COMPANY LAW – SUMMATIVE ASSESSMENT

DOCTRINE OF CORPORATE VEIL PIERCING: ON ITS WAY TO

BREXIT?

EXAM NUMBER: B236260

COURSE CODE: 11016

QUESTION NUMBER: Q1

WORD COUNT: 3703

 TABLE OF CONTENTS
I. INTRODUCTION .................................................................................................................................... 1

II. UNDERSTANDING THE CONCEPT OF “LIFTING THE CORPORATE VEIL” ................................................... 2

A. ORIGIN OF SEPARATE LEGAL PERSONALITY AND LIMITED LIABILITY ..........................................................................2

B. NECESSITY FOR PIERCING THE CORPORATE VEIL ...................................................................................................3

III. ROAD MAP OF CASE LAWS – FROM SALOMON TO PREST ..................................................................... 4

A. SALOMON V SALOMON ...................................................................................................................................4

B. TREATMENT OF GROUP COMPANIES AND PARENT COMPANIES AND ITS SUBSIDIARIES .................................................5

IV. PREST: A BREAKTHROUGH FOR INTERPRETATION? ............................................................................... 6

A. SUMMARY OF FACTS ......................................................................................................................................6

B. LORD SUMPTION’S RULING AND IMPORTANT TAKEAWAYS: ....................................................................................7
I. UPHOLDING THE PRINCIPLE OF CORPORATE PERSONALITY. .....................................................................................7
II. EVASION V/S CONCEALMENT ...........................................................................................................................7
III. STRICT INTERPRETATION OF THE JUDGMENT IN SALOMON .....................................................................................8
IV. TEST OF EVASION ..........................................................................................................................................8

V. THIN LINE BETWEEN CORPORATE VEIL PIERCING AND LIFTING ............................................................. 8

VI. PERSISTING PROBLEMS POST PREST: “EVASION” V/S “CONCEALMENT” ............................................... 9

VII. COMPLEXITY OF THE DOCTRINE ..................................................................................................... 10

VIII. CONCLUSION ................................................................................................................................. 11

IX. BIBLIOGRAPHY ................................................................................................................................... 13

A. BOOKS ......................................................................................................................................................13
B. JOURNAL ARTICLES ......................................................................................................................................13
C. INTERNET SOURCES ......................................................................................................................................13
D. STATUTORY INSTRUMENTS ............................................................................................................................14
E. CASES .......................................................................................................................................................14
 Page 1 of 16

DOCTRINE OF CORPORATE VEIL PIERCING: ON ITS WAY TO

BREXIT?1

I. Introduction

One of the foundational cannons of corporate law is that every corporation has a
separate legal personality.2 This proposition elucidates the fact that every company in
itself is a legal person with rights and duties, separate from that of its shareholders,
directors, and other constituents.3 This separation between the corporation and its
constituents is what is famously referred to as the “corporate veil”.4 One of the most
pertinent implications of the famous Salomon v Salomon5 case is that it upheld the
sanctity of corporate personality and conferred limited liability on the members of a
company.6 Conferring limited liability on the members can trigger negative implications
such as insider trading, fraudulent dealings, defrauding others in the company for
personal benefits of an individual or a group of individuals, etc.7 Therefore, to avoid
such occurrences, courts have on certain occasions decided to pierce the corporate
veil and treat the corporation and its members as one entity.8

In this paper, the author attempts to assess the current approach of the common law
courts, more specifically in the United Kingdom, towards lifting of the corporate veil by

1
Alexander Schall, “The New Law of Piercing the Corporate Veil in the UK” (SSRN, 2016)
https://ssrn.com/abstract=3538410 accessed 4th January 2024.
2
Paul Davis, Sarah Worthington, and Chris Hare, “The Limits of Separate Legal Personality And Limited
Liability”, Gower: Principles of Modern Company Law” (11th edn, Sweet & Maxwell 2021) Ch 7 333.
3
Ibid.
4
Harsh Ram, “Case Analysis: Salomon v/s Salomon & Co Ltd [1896] UKHL1” (Legal Service India, E
– Journal) https://www.legalserviceindia.com/legal/article-13655-case-analysis-salomon-v-s-salomon-
co-ltd-1896-ukhl1.html accessed 3 January 2024.
5
Salmon v Salmon & Co Ltd [1897] A.C. 22 (1896)
6
Sylvester C. Udemezue and Nwamaka Adaora Iguh, “Does Salomon V. Salomon Still Reign? A
Disquisition on Recent Case Law on Corporate Legal Personality and Lifting the Veil” (2020) 16 ULJ 43
7
Liton Chandra Biswas, “Approach of the UK Court in Piercing Corporate Veil” (SSRN, 2011)
http://dx.doi.org/10.2139/ssrn.2438217 accessed on 5 January 2024.
8
Los Watkins and Hamiisi Junior Nsubuga, “The Road to Prest v Petrodel: An analysis of the UK
Judicial Approach to the Corporate Veil – Part I” (2020) ICCLR 547.
 Page 2 of 16

analysing cases starting from the Salomon era to Lord Sumption’s ruling in Prest,9 to
establish its current status in law. Further, it becomes a relevant question whether with
all the confusion in interpretation surrounding the doctrine of piercing the corporate
veil, should it continue being evaluated or abolished altogether? The aim of this paper
is to not give a definitive answer to this question, however, it aims to analyse relevant
factors that impact such a dilemma.

II. Understanding the Concept of “Lifting the Corporate Veil”

A. Origin of Separate Legal Personality and Limited Liability

Businessmen are aware that running a business comes with the inherent risk of failure.
If not for the concept of separate legal personality and limited liability, multiple great
business ideas with extensive potential for success, would not have become a reality.
With the fear of having to risk personal property for a business failure, many would be
disincentivised to venture into new businesses.10 It was to mitigate this fear and to
promote legitimate business ideas that the concept of limited liability came into being.11
Despite the corporate personality, a company cannot run itself, as rightly stated – “a
corporation is an abstraction. It has no mind of its own any more than it has a body of
its own”.12 The shareholders appoint board of directors, who are responsible for taking
business decisions on behalf of the company and managing it on a day-to-day basis,
subject to regulatory and shareholder approvals. While the shareholders and directors
are the ones running a company, there is a very clear distinction and a separation
made between them and the company itself in law (discussed below), for the purposes
of being held liable and sued. This separation is very famously referred to as the
“corporate veil”.13

In accordance with section 16 of the Companies Act, 200614, “a body corporate is

capable of exercising all the functions of an incorporated company”15 and further

9
Petrodel Resources Ltd v Prest [2013] 2 A.C. 415.
10
Biswas (n 7).
11
Ibid.
12
Lennard’s Carrying Co Ltd v Asiatic Petroleum Co Ltd [1915] AC 705 713.
13
Watkins and Nsubuga (n 8).
14
Companies Act 2006 (CA, 2006).
15
CA, 2006 s 16 (3).
 Page 3 of 16

section 3 limits the liability on the shareholders only to the extent of unpaid shares held
by them.16 Therefore, upon successful incorporation under the Companies Act, 2006,
a corporation has its own corporate personality, and is qualified as a “person” as per
the Interpretation Act, 1978.17 Directors act as agents of a company, and therefore,
are not usually responsible for any liability claims that arise in the ordinary course of
business against the company18. This does not however protect the directors from
being held liable for a breach of their own obligations.19 Shareholders on the other
hand derive their rights and obligations from the charter documents (memorandum of
association and articles of association) of a company.20 As members holding equity in
the company, they pay for the shares allotted to them, and in case these shares are
only paid in part, the liability of shareholders in a company limited by shares, is only to
the extent of those unpaid shares.21

B. Necessity for Piercing the Corporate Veil

While the intention behind introducing the concept of separate legal personality and
limited liability was to promote business ideas and shareholder investments, it also
paved path for directors and shareholders to misuse this privilege by indulging in
fraudulent and dishonest activities for personal gains.22 To avoid such occurrences,
courts in certain cases had to pierce the corporate veil and look past the doctrine of
limited liability to treat the company and its constituents as one entity and extend the
liability to members and directors as well.23 Principle of piercing the corporate veil is
not codified in the UK law and is therefore open to interpretation by the courts on a
case to case basis. However, the doctrine of separate legal personality is of extreme
importance and cannot be disregarded for every minor dispute raised. As rightfully
held in United States v Milwaukee, “Separate legal entity of a corporation is a general
rule, but when the notion of legal entity is used to defeat public convenience, justify

16
CA, 2006 s 3 (2).
17
Simon Johnson, “Corporate Personality and Limited Liability” (Practical Law UK)
https://uk.practicallaw.thomsonreuters.com/2-613-0725 accessed on 3 January 2024.
18
Ibid.
19
Ibid.
20
Ibid.
21
CA, 2006 s 3 (2).
22
Biswas (n 7).
23
Ibid.
 Page 4 of 16

wrong, protect fraud or defend crime, the law will regard the corporation as an
association of persons.”24 The courts tend to pierce the corporate veil only in
exceptional cases that warrant such intervention.25

III. Road Map of Case Laws – From Salomon to Prest

A. Salomon v Salomon26

Salomon is the landmark judgment that clarified and upheld the principle of a corporate
entity having a separate legal personality.27 In the given case, Mr. Salomon set up a
new company and transferred the business from his existing company to it. The
creditors sued Mr. Salomon on the grounds that he set up the new company to avoid
financial liabilities.28 Based on lack of sufficient evidence to show any fraudulent
dealings and respecting the principles of a corporate entity being a separate legal
entity, the court held that the new company was in fact set up by Mr. Salomon “to
extend his business and provide for his family”29 and not for any other devious
reasons. In furtherance to not lifting the corporate veil in the given case, the court
stated that “a limited company was to be viewed like any other independent person
with its rights and liabilities appropriated to itself. Further, Lord Halsbury stated that
“either the limited company was a legal entity, or it was not. If it was, the business
belonged to it and not to Mr. Salomon. If it was not, there was no person and no thing
to be an agent at all; and it is impossible to say at the same time that there is a
company and there is not.”30

Implications: Following Salomon, multiple courts have referred to it and continue citing
the case for upholding the sanctity of the doctrine of separate legal personality. In a
recent 2022 judgment, where the personal liability of senior manager was questioned,
as an accessory to a tort committed by the company, the Court of Appeal following the
rationale in Salomon case held that “It was necessary to strike a balance between two

24
United States v Milwaukee Refrigerator Transit Co 142 F. 247.
25
Emil Stark v John B Coker 20 Cal 2d 839.
26
Salomon (n 5).
27
Johnson (n 17).
28
Salomon (n 5); Watkins and Nsubuga (n 8).
29
Salomon (n 5).
30
Ibid 31.
 Page 5 of 16

competing principles: the first that individuals were entitled to limit their liability by
incorporating a limited company to carry on their business, and the second, that
tortfeasors should not escape liability for their tortious acts merely because they were
company directors or officers”.31

However, the limited jurisprudence on the interpretation of the doctrine in the Salomon
case became increasingly challenging, more specifically in cases that involved
subsidiaries and group companies.32 Perhaps, the fundamental question that the
doctrine raises for group companies would be whether individual companies in a group
would be treated as a single entity or separate legal entities for all legal purposes.
Judges took opposing views in various cases. For instance, in one case, Lordship
Denning treated group companies as a single economic entity and justified it based
on the controlling interest being same in group companies.33 On the other hand, this
opinion was highly criticised, and it was held that each entity even in group companies
is separate from one another, with each company having its respective rights and
obligations.34

B. Treatment of Group Companies and Parent Companies and its Subsidiaries

Extreme opinions led to lack of clarity on when the separate legal personality could be
disregarded and whether the corporate veil could be lifted in cases of group
companies. An attempt was made by the Court of Appeal to bring some clarity to this
issue in the Adams v Cape Industries35 and held that “the court is not free to disregard
the principle of Salomon v A Salomon & Co Ltd [1897] AC 22 merely because it
considers that justice so requires. Our law, for better or worse, recognises the creation
of subsidiary companies, which though in one sense the creatures of their parent
companies, will nevertheless under the general law fall to be treated as separate legal
entities with all the rights and liabilities which would normally attach to separate legal
entities.”36 Authorities justified piercing the corporate veil in three of the following

31
Barclay-Watt v Alpha Panaretti Public Ltd [2022] EWCA Civ 1169.
32
Watkins and Nsubuga (n 8).
33
DHN Food Distributors Ltd v Tower Hamlets London Borough Council [1976] 1 WLR 852.
34
The Albazero [1977] AC 774.
35
Adams v Cape Industries plc [1990] Ch 433.
36
Ibid.
 Page 6 of 16

situations: “(i) where the company was a “facade or sham”; (ii) where the company
was involved in some form of impropriety; and (iii) where it was necessary to do so in
the interests of justice.”37 However, while agreeing with submissions under points (i)
and (ii), Sir Mariott, upholding the decision in Adams case, rejected the submission of
piercing the corporate veil on grounds for interests of justice. He argued that the first
two submissions were relevant because of their link “to the use of the company
structure to avoid or conceal liability for that impropriety.”38 To conclude, the court held
that it was “entitled to ‘pierce the corporate veil’ and recognise the receipt of the
company as that of the individual(s) in control of it if the company was used as a device
or facade to conceal the true facts, thereby avoiding, or concealing any liability of those
individual(s).”39

However, there was an inherent confusion in the interpretation of the terms “façade”
and “sham”. Therefore, there was a need for a better way to interpret the doctrine.
Years later, Prest v Petrodel seems to have somewhat established clarity on this.

IV. Prest: A Breakthrough for Interpretation?

A. Summary of Facts

Lord Sumption’s ruling in Prest has brought in a paradigm shift in the interpretation of
when the corporate personality is to be disregarded. The most significant takeaway
from this ruling is that the corporate veil is to be pierced only “where a person was
under an existing legal obligation or liability or subject to an existing legal restriction
which he deliberately evaded or whose enforcement he deliberately frustrated by
interposing a company under his control.”40 This case is an intersection of family law
and company law, involving a divorce petition filed by Mrs. Prest. In trying to determine
the ancillary relief, amongst other things, the high court ordered transferring seven UK
properties from two companies under Mr. Prest’s control, to Mrs. Prest. While doing
so the judge denied piercing the corporate veil but ordered the transfer of assets based

37
Petrodel Resources (n 9).
38
Ibid.
39
Ibid.
40
Ibid.
 Page 7 of 16

on section 24 of the Matrimonial Causes Act 1973,41 and stated that section 24 granted
an extended power to treat the assets of a company substantially owned by one party
in a marriage as available for distribution, as long as the remaining assets were
sufficient to pay off the creditors, an opinion that is highly dissented.42 The court of
appeal criticised the family divisions extension of section 24 and stated that it was
beyond the jurisdiction of courts to exercise such power “unless (i) the corporate
personality of the company was being abused for an improper purpose, or (ii) on the
particular facts of the case, it could be shown that an asset legally owned by the
company was held in trust for the husband.”43 This decision was again appealed by
Mrs. Prest before the Supreme Court.

B. Lord Sumption’s Ruling and Important Takeaways:

i. Upholding the principle of corporate personality.

Upholding the judgement in Salomon case, Lord Sumption explained that to pierce the
corporate veil of a company would mean disregarding its separate legal personality.
He rightfully argued that many cases in law attributes the acts of an entity to people
controlling it, without disregard its separate legal personality, for instance, the concept
of agency in law of contracts.

ii. Evasion v/s Concealment

He introduced characterisation of cases into principles of “evasion” and “concealment”

to establish clarity on when the corporate veil needs to be pierced. Distinguishing
evasion from concealment helps establish the level of interference the courts must
invoke. For instance, Lord Sumption identifies concealment cases to be those wherein
a company is used to hide the identity of the real actors.44 Such cases don’t require
piercing of corporate veil, instead, courts should limit their interference to simply
looking behind the veil or lifting it to see what the company is being used to conceal.

41
Matrimonial Causes Act (1973).
42
Petrodel Resources (n 9).
43
Ibid.
44
Ibid.
 Page 8 of 16

To the contrary, evasion is more serious in nature and is invoked in cases wherein a
person in control of a company is using it to frustrate a legal right or an obligation that
existed independently on the individual without the company’s involvement.

iii. Strict Interpretation of the judgment in Salomon

He adopted a very strict interpretation of the doctrine, relying on Salomon, and stated
that “it is not an abuse to cause the company to incur a legal liability in the first place,
or to identify that the liability belongs to the company, not the controller.”

iv. Test of Evasion

The test is then to evaluate whether an individual is under an existing legal obligation
or liability, or subject to an existing legal restriction, that they deliberately evade or
whose enforcement they deliberately try to frustrate, by interposing a company under
their control.

If the above test is satisfied, the corporate veil may be pierced. However, piercing of
corporate veil should be an exception and should be undertaken only when absolutely
necessary and when other possible alternatives are not available.” 45

Implications: Prest was one of the first few cases that has attempted to objectively
interpret the corporate personality doctrine by characterising cases as “evasion” and
“concealment” (refer to Part V of this paper for a detailed analysis on this). It also
brought in more clarity to the interpretation by discarding the subjective analysis of the
earlier courts of piercing the corporate veil in case of a “fraud” or a “sham”. However,
there are still interpretational challenges as to what happens when characterisation of
cases is not possible under either of these two principles? Therefore, while Prest may
have brought in a sense of clarity, there still remains many questions unanswered.

V. Thin Line Between Corporate Veil Piercing and Lifting

45
Ibid.
 Page 9 of 16

Lord Sumption in his ruling suggested a distinction between piercing the corporate veil
as against merely lifting it.46 It is pertinent to understand how these operate practically.
For instance, court asking the defendants to produce accounts in accordance with CA,
200647 would qualify as merely peeping behind the veil to establish the case.48 In
Gross v Rackind49 civil court allowed the shareholders to petition claims of unfair
prejudice under section 994 of CA, 2006.50 Based on the understanding in these
examples, it can be possibly be argued that lifting the veil / peeping behind the veil,
are preconditions that the court allows to establish a case on whether or not the
corporate veil needs to be pierced.

VI. Persisting Problems Post Prest: “Evasion” v/s “Concealment”

Perhaps the most important implication of the holding in Prest is the differentiation it
creates between actually lifting the corporate veil as against invocation of common law
principles, such as agency and tort law, which were interchangeably seen as
lifting/piercing the corporate veil.51 While distinguishing between evasion and
concealment does provide significantly more clarity to the doctrine, than was available
earlier, it was still dissented on multiple grounds.

There is no doubt that the ruling in Prest was a breakthrough in bringing more
objectivity to the doctrine of corporate veil piercing. More so, because the ruling helped
overcome the confusion posed by the “façade” and “sham” test in earlier cases.52
However, there are multiple factors that are yet to be addressed. One may argue that
the ruling in Prest was a strong attempt at saving the remains of the doctrine of
corporate veil piercing, by trying to bring in some practical objectivity on when it should
be pierced.

46
Ibid.
47
CA, 2006 s 399.
48
Simon (n 17).
49
Gross v Rackind [2004] EWCA Civ 815.
50
CA, 2006 s 994.
51
Petrodel (n 9).
52
Schall (n 1).
 Page 10 of 16

Lord Sumption’s ruling identifies evasion as a form of corporate abuse and holds it as
the ultimate threshold for piercing the corporate veil.53 However, as pointed out by
Lady Hale, not all cases fall within the ambits of “evasion” or “concealment”. Holding
evasion to be the ultimate factor seems to be discarding multitudes of other forms of
corporate abuses that may surface in other cases. For instance, the Re Darby54 case
was an obvious case of concealment by two promoters who were trying to conceal
their identities by naming the company as the promoter in the prospectus. There was
no established case for evasion, however they were fraudulently making profits in the
name of the company hiding behind the corporate veil. It can hardly be contested that
this wasn’t a case of corporate abuse and warranted the lifting of the corporate veil.
But of course, if one was to base their decision on the outcome of Prest, the only form
of accepted corporate abuse seems to be that of evasion, making the principle of
piercing the corporate veil so limited that the court seems to have forgotten the
rationale behind the doctrine to begin with.

Further, Lord Sumption’s ruling seems to have established the doctrine of corporate
veil piercing as the “last resort” remedy. He uses Gencor55 case to explain this
proposition and states that the lifting of corporate veil was not warranted as the laws
of agency, albeit more conventional remedies were available for the court to look into.
However, by this logic, piercing of corporate veil doctrine has been reduced to simply
looking into cases of evasion or perhaps, if there are cases that come up and do not
have alternative remedies under law. While Lord Sumption tried to make the doctrine
of piercing corporate veil an exception, he invariably ended up proving it to be
redundant, while perhaps creating a new rule very specific to evasion cases.
Therefore, while the judgement in Prest can be used as a guiding principle, it is not
the absolute solution in every case and the ambiguity of interpreting when the
corporate personality can be disregarded, still remains.

VII. Complexity of the Doctrine

53
Petrodel (n 9).
54
Re Darby, ex parte Brougham [1911] 1 KB 95.
55
Gencor ACP Ltd v Dalby [2000] EWHC 1560 Ch.
 Page 11 of 16

Professor David Million, rightfully states that “veil-piercing is the most heavily litigated
issue in corporate law, yet legal doctrine in this area is notoriously incoherent.”56 Many
renowned scholars have taken a similar view, this can be attributed to the vagueness
surrounding the doctrine and lack of clear guidance on its application and the extent
thereof. While multiple case laws have interpreted the doctrine of corporate personality
and when it should be disregarded, it is clear from the constantly changing opinions
with regards to its interpretation, that a great deal of discretion on what it means and
how it is to be interpreted, has been deferred to the judgement of courts. Extensive
discretion and lack of clarity on application and limits of this doctrine, seem to only be
triggering more theoretical debates on paper, rather than achieving a practical
outcome. Some scholars, such as Professor Brainbridge have even suggested
abolition of the principle as a whole.57

VIII. Conclusion

Importance of the doctrine of corporate personality and limited liability of shareholders

remains uncontested. However, every rule comes with an exception. The exception to
this doctrine is the situations in which the courts disregard the separate legal
personality of the company and pierce this veil of separation to treat the shareholders
and the company as one entity and extend the liability. Based on the decided cases,
there seems to be consensus on the fact that the general rule is to respect the
corporate personality of an entity and that the piercing of corporate veil should be
invoked only in exceptional circumstances. This doctrine has subjected the courts to
interpretational challenges for decades. Since the judgment in Salomon to the post
Prest era, there is of course significant improvements made in relation to how the
doctrine is to be interpreted. However, each time there seemed to be some sense of
clarity, new questions of interpretational issues have surfaced. Even the much-
appreciated ruling in Prest by Lord Sumption was dissented by his fellow judges on
certain grounds.

56
David K. Millon, “Piercing the Corporate Veil, Financial Responsibility, and the limits of Limited
Liability” (2007) 56 ELJ 1307
57
Stephen M. Bainbridge, “Abolishing Veil Lifting” (2001) 26(3) JCL, 470, 481
 Page 12 of 16

One can suggest retaining the existing model, wherein courts are given the right to
interpret the doctrine on a case-to-case basis. However, if principle of evasion was the
ultimate guiding principle, the doctrine would disregard almost every other form of
corporate abuse and expect the courts to bank on alternative remedies available in
law, such as agency, torts, contract law, etc. In such a scenario, abolition of the
principle makes more sense to avoid further confusion. Ruling in Prest could be simply
seen as disregarding separate personality of a company in cases of evasion.

Another alternative would be to extend the doctrine of piercing the corporate veil to all
forms of corporate abuses and not just evasion, but this would be as good as going
back to square one, as the concept of “corporate abuse” is extremely wide and would
face multiple interpretational challenges.

Pursuant the ruling in Prest, the current law in the UK seems to be somewhere in the
middle. The doctrine of piercing the corporate veil persists as an exceptional rule that
is ideally to be invoked in cases of evasion, and as a last resort. While the concept of
evasion is not exhaustive and other forms of corporate abuses may be included in the
ambit of the doctrine, it would be a special exception that may be interpreted into the
doctrine, only when no alternative form of remedy is available under law. The ruling in
Prest can therefore either act as a massive reform of the doctrine or lead to its
abolition, it is perhaps too soon to comment on which way it would go.
 Page 13 of 16

IX. Bibliography

A. Books

1. Davis P, Worthington S, and Hare C, “The Limits of Separate Legal

Personality and Limited Liability”, Gower: Principles of Modern Company
Law (11th edn, Sweet & Maxwell 2021) Ch 7 333.

B. Journal Articles

1. Watkins L and Nsubuga HJ, “The Road to Prest v Petrodel: An analysis

of the UK Judicial Approach to the Corporate Veil – Part I” (2020) ICCLR
547
2. Udemezue SC, and Iguh NA, “Does Salomon V. Salomon Still Reign? A
Disquisition on Recent Case Law on Corporate Legal Personality and
Lifting the Veil” (2020) 16 ULJ 43.
3. Ramsay IM and Noakes DB, “Piercing the Corporate Veil in Australia”
(2001) 19 CSLJ 250 – 271.
4. Millon DK, “Piercing the Corporate Veil, Financial Responsibility, and the
limits of Limited Liability” (2007) 56 ELJ 1307.
5. Bainbridge SM, “Abolishing Veil Lifting” (2001) 26(3) JCL, 470, 481.

C. Internet Sources

1. Ram H, “Case Analysis: Salomon v/s Salomon & Co Ltd [1896] UKHL1”
(Legal Service India, E – Journal)
https://www.legalserviceindia.com/legal/article-13655-case-analysis-
salomon-v-s-salomon-co-ltd-1896-ukhl1.html accessed 3 January 2024.
2. Biswas LC, “Approach of the UK Court in Piercing Corporate Veil”
(SSRN, 2011) http://dx.doi.org/10.2139/ssrn.2438217 accessed on 5
January 2024.
 Page 14 of 16

3. Johnson S, “Corporate Personality and Limited Liability” (Practical Law

UK) https://uk.practicallaw.thomsonreuters.com/2-613-0725 accessed
on 3 January 2024.
4. Schall A, “The New Law of Piercing the Corporate Veil in the UK” (SSRN,
2016) https://ssrn.com/abstract=3538410 accessed 4th January 2024.

D. Statutory Instruments

1. Companies Act 2006 (CA, 2006).

2. Matrimonial Causes Act (1973).

E. Cases

1. Salmon v Salmon & Co Ltd [1897] A.C. 22 (1896).

2. Petrodel Resources Ltd v Prest [2013] 2 A.C. 415.
3. Lennard’s Carrying Co Ltd v Asiatic Petroleum Co Ltd [1915] AC 705
713.
4. United States v Milwaukee Refrigerator Transit Co 142 F. 247.
5. Emil Stark v John B Coker 20 Cal 2d 839.
6. Barclay-Watt v Alpha Panaretti Public Ltd [2022] EWCA Civ 1169.
7. DHN Food Distributors Ltd v Tower Hamlets London Borough Council
[1976] 1 WLR 852.
8. The Albazero [1977] AC 774.
9. Adams v Cape Industries plc [1990] Ch 433.
10. Re Darby, ex parte Brougham [1911] 1 KB 95.
11. Gross v Rackind [2004] EWCA Civ 815.
12. Gencor ACP Ltd v Dalby [2000] EWHC 1560 Ch.