DBLP Sea Cow Ltd v Steffensen [2026] EWHC 281 (Ch) (12 February 2026)

DBLP Sea Cow Ltd v Steffensen [2026] EWHC 281 (Ch) (12 February 2026)

The SPA and its variations governed the transfer of shares, imposing an express bare trust in favour of DBLP. The '22 May Document' was a sham created to mislead a broker and was not binding on DBLP. Mr Steffensen breached the trust by selling the shares without satisfying the payment condition. As he was debarred from defending and there was no real prospect of a defence, summary judgment was granted for DBLP.

Citation
[2026] EWHC 281 (Ch)
Parties
Claimant: DBLP SEA COW LIMITED; Defendant: Lars Steffensen
Jurisdiction
England and Wales
Judgment Date
12 February 2026
Procedural Posture
Commercial Chancery Claim / Summary Judgment Following Debarring Order
Outcome
Summary judgment for the claimant; continuation of injunction; order for account of proceeds or equitable compensation.
Legal Topics
Breach of Trust, Sham Documents, Summary Judgment, Debarring Order, Share Purchase Agreements, Equitable Relief
Equity Commercial Law Trusts Contract Law Breach of Trust Sham Documents Summary Judgment Debarring Order +2 more

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 3 Authorities cited 11 Party arguments 2 Amounts and remedies 3
Sign in to unlock

Parties

DBLP SEA COW LIMITED

Claimant

Lars Steffensen

Defendant

Procedural Posture

Commercial Chancery Claim / Summary Judgment Following Debarring Order

Legal Issues

  1. 1 Whether the defendant held shares on bare trust for the claimant under the SPA and variations
  2. 2 Whether the '22 May Document' superseded the SPA or was a sham
  3. 3 Whether summary judgment should be granted following a debarring order

Ratio Decidendi

The SPA and its variations governed the transfer of shares, imposing an express bare trust in favour of DBLP. The '22 May Document' was a sham created to mislead a broker and was not binding on DBLP. Mr Steffensen breached the trust by selling the shares without satisfying the payment condition. As he was debarred from defending and there was no real prospect of a defence, summary judgment was granted for DBLP.

Court Disposition

Summary judgment for the claimant; continuation of injunction; order for account of proceeds or equitable compensation.

Orders

  • Summary judgment granted in favour of DBLP SEA COW LIMITED against Lars Steffensen.
  • Continuation of the proprietary injunction restraining dealing with the shares or proceeds.