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''Gilford Motor Co Ltd v Horne'' 933Ch 935 is a
UK company law The United Kingdom company law regulates corporations formed under the Companies Act 2006. Also governed by the Insolvency Act 1986, the UK Corporate Governance Code, European Union Directives and court cases, the company is the primary legal ...
case concerning
lifting the corporate veil Piercing the corporate veil or lifting the corporate veil is a legal decision to treat the rights or duties of a corporation as the rights or liabilities of its shareholders. Usually a corporation is treated as a Corporate personhood, separate leg ...
. It gives an example of when courts will treat shareholders and a company as one, in a situation where a company is used as an instrument of fraud.


Facts

Mr EB Horne was formerly a managing director of the Gilford Motor Co Ltd. His employment contract stipulated (clause 9) not to solicit customers of the company if he were to leave employment of Gilford Motor Co. Mr. Horne was fired, thereafter he set up his own business and undercut Gilford Motor Co's prices. He received legal advice saying that he was probably acting in breach of contract. So he set up a company, JM Horne & Co Ltd, in which his wife and a friend called Mr Howard were the sole shareholders and directors. They took over Horne’s business and continued it. Mr. Horne sent out fliers saying, The company had no such agreement with Gilford Motor about not competing, however Gilford Motor brought an action alleging that the company was used as an instrument of fraud to conceal Mr Horne's illegitimate actions.


Judgment


High Court

Farwell J held that the covenant Mr Horne would not compete was broken. ‘I cannot help feeling quite convinced that at any rate one of the reasons for the creation of that company was the fear of Mr Horne that he might commit breaches of the covenant in carrying on the business…’ But because the covenant was too wide and against public policy (restraint of trade?) he refused to enforce it. Gilford Motor appealed.


Court of Appeal

Lord Hanworth MR granted an injunction, so that Horne was forced to stop competing through the company. Lawrence LJ and Romer LJ concurred.


See also

{{Clist personality *''
Jones v Lipman ''Jones v Lipman''
962 Year 962 ( CMLXII) was a common year starting on Wednesday (link will display the full calendar) of the Julian calendar. Events By place Byzantine Empire * December – Arab–Byzantine wars – Sack of Aleppo: A Byzantine e ...
1 WLR 832 is a UK company law case concerning piercing the corporate veil. It exemplifies the principal case in which the veil will be lifted, that is, when a company is used as a "mere facade" concealing the "true facts ...
''


References

* United Kingdom company case law United Kingdom corporate personality case law Court of Appeal (England and Wales) cases 1933 in case law 1933 in British law