Schofield v Schofield & Ors

Schofield v Schofield & Ors

There was no objective, unqualified agreement by Lee Neil Schofield to treat the meeting as valid and effective; his participation was conditional and maintained objections, so the Duomatic principle did not apply and the meeting was invalid.

Parties
Appellant: Neil David Schofield; Respondent: Lee Neil Schofield; Respondent: Avenue Road Development Limited; Respondent: Nikolas Garth Rimes (Administrator for Avenue Road Development Ltd)
Jurisdiction
England and Wales
Judgment Date
25 February 2011
Procedural Posture
Civil Appeal / Judgment on Appeal
Outcome
appeal dismissed
Legal Topics
Director Removal, Shareholder Consent, Duomatic Principle, Meeting Notice Requirements

Case Brief

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Parties

Neil David Schofield

Appellant

Lee Neil Schofield

Respondent

Avenue Road Development Limited

Respondent

Nikolas Garth Rimes (Administrator for Avenue Road Development Ltd)

Respondent

Procedural Posture

Civil Appeal / Judgment on Appeal

  1. 1 Whether Lee Neil Schofield acquiesced to short notice for the EGM under the Duomatic principle
  2. 2 Whether the meeting on 2 October 2009 was validly convened for the removal and appointment of directors

Ratio Decidendi

There was no objective, unqualified agreement by Lee Neil Schofield to treat the meeting as valid and effective; his participation was conditional and maintained objections, so the Duomatic principle did not apply and the meeting was invalid.

Court Disposition

appeal dismissed

Orders

  • No declaration granted.
  • No injunction granted.