Application for a declaration that the director has been engaged in wrongful trading

AuthorMark Watson-Gandy
Pages363-376
Chapter 25


Application for a Declaration that the Director has been Engaged in Wrongful Trading

OBJECTIVE

The court has the power on the application of the liquidator or the administrator1

to make a declaration that a person who is, or was, a director of the company in liquidation has been carrying on the business of the company as a director at a time when he knew, or ought to have concluded, that there was no reasonable prospect that the company would avoid going into insolvent liquidation or administration.2If the court makes such a declaration, the court can also order that the director is liable to make a contribution in a sum the court fixes to the company assets.3

The application can be made against any person who is, or was, a director of the company in liquidation or administration.4‘Director’ includes a shadow director.5

Any compensation ordered goes to the general funds in the hands of the liquidator or administrator rather than to compensate an individual creditor. This is the case even though the nature of the contribution is compensatory rather than punitive.6

The liability of the directors is several rather than joint and several.7

The director has a defence if he can show that he took every step with a view to minimising the potential loss to the company’s creditors he ought to have taken with the knowledge that there was no reasonable prospect that the company would avoid going into insolvent liquidation or administration.8

The knowledge of the director and the conclusions he ought to have reached are, for the purposes of the section, judged against that which might be expected of a reasonably diligent person having both the general knowledge, skill and experience that may reasonably be expected of a person carrying out the same

1Section 246ZB of the Insolvency Act 1986.

2Sections 214(1), (2) and 246ZB(1), (2) of the Insolvency Act 1986.

3Sections 214(1) and 246ZB(1) of the Insolvency Act 1986.

4Sections 214(1) and 246ZB(1) of the Insolvency Act 1986.

5Sections 214(7) and 246ZB(7) of the Insolvency Act 1986.

6Morphitis v Bernasconi [2003] EWCA Civ 289, [2003] BCC 540.

7Re Continental Assurance Co of London plc [2001] BPIR 733.

8Sections 214(3) and 246ZB(3) of the Insolvency Act 1986.

364 Corporate Insolvency Practice

functions by that director in relation to the company and the general knowledge, skill and experience that the director has.9

APPLICATION

Proceedings are commenced by application notice (on Form IAA).

The application must recite the nature of the declaration sought and the grounds for bringing the application.10

The application should be returnable to the registrar in the Companies Court or to the district judge in a Chancery District Registry or county court with insolvency jurisdiction.

The respondent should be the person against whom relief is sought.11

COURT FEES

Where fresh proceedings need to be brought, a court fee of £280 is payable.12If

the application can be made as part of exisiting proceedings and the application is on notice to other parties, a court fee of £155 is payable.13Where the application is made by consent or without notice in existing proceedings, a court fee of £50 is payable.14

SERVICE

The application will need to be filed at court and served on the respondent as soon as practicable after it is filed and in any event, unless it is necessary to apply without notice or on short notice, at least 14 days before the date fixed for the hearing.15

The usual rule is that, subject to any other express provision, the application must be served at least 14 days before the date fixed for the hearing.16However, the

9Sections 214(4) and 246ZB(4) of the Insolvency Act 1986. Thus Knox J held he was entitled to assume that the directors knew the company’s financial results in the absence of proper accounting records: Re Produce Marketing Consortium Ltd (1989) 5 BCC 569.

10Rule 1.35(2) of the Insolvency (England and Wales) Rules 2016.

11Banque Arabe Internationale d’Investissement SA v Morris [2002] BCC 407.

12Paragraph 3.5 of Schedule 1 to the Civil Proceedings Fees Order 2008.

13Paragraph 3.12 of Schedule 1 to the Civil Proceedings Fees Order 2008.

14Paragraph 3.11 of Schedule 1 to the Civil Proceedings Fees Order 2008.

15Rule 12.9(3) of the Insolvency (England and Wales) Rules 2016.

16Rule 12.9(3) of the Insolvency (England and Wales) Rules 2016.

court does have power, in cases of urgency, to hear an application immediately with or without notice to the other parties.17

Service may be effected personally18or by post in accordance with the rules on postal service under Part 6 of the CPR.19Service on a person may be effected by service on that person’s solicitor, if they are authorised to accept service on that person’s behalf.20

THE FIRST HEARING

At the first hearing, the registrar or district judge will give directions as to whether points of claim are needed and for the filing of evidence. He may also require the application to be served on other people. He may give directions as to whether witnesses are to attend for cross examination. The first hearing is likely to be heard in chambers and the advocates are not expected to robe.

EVIDENCE

No evidence needs to be filed before the first hearing. The application will, however, need, in due course, to be supported by a witness statement by the liquidator. This will need to address:

ƒ the order he seeks;
ƒ the date the company was incorporated;
ƒ the registered office of the company;
ƒ the nominal share capital of the company;
ƒ the issued share capital of the company;
ƒ the objects of the company;
ƒ the date upon which the petition to wind up the company was presented;
ƒ the date upon which the company went into liquidation;
ƒ that he was appointed as liquidator of the company;
ƒ the date upon which he was appointed as liquidator;
ƒ the date the company became insolvent;
ƒ that the respondent is, or was, a director of the company at the time;
ƒ the respondent’s role in allowing the company to continue to trade;
ƒ particulars of the matters that the respondent can be said to have known about, or ought to have known about;
ƒ the conclusions which might be expected of a reasonably diligent person having both the general knowledge, skill and experience that may reasonably expected of a person carrying out the same functions by that

17Rule 12.10(1) of the Insolvency (England and Wales) Rules 2016.

18Rule 1.44 of the Insolvency (England and Wales) Rules 2016.

19Paragraph 1(2) of Schedule 4 to the Insolvency (England and Wales) Rules 2016.

20Rule 1.40 of the Insolvency (England and Wales) Rules 2016.

366 Corporate Insolvency Practice

director in relation to the company and the...

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