Penang Foundry Co., Ltd (In Liquidation) and Others v. Gardiner [1913] ScotLR 3 (31 January 1913)

Penang Foundry Co., Ltd (In Liquidation) and Others v. Gardiner [1913] ScotLR 3 (31 January 1913)

Where a company issues share certificates stating shares are fully paid, and the allottee accepts them in good faith believing this representation, the company is estopped from claiming otherwise and cannot recover unpaid amounts from the allottee.

Citation
[1913] ScotLR 3
Parties
Pursuer: Penang Foundry Company, Limited (In Liquidation) and Others; Defender: A. H. Gardiner
Jurisdiction
Scotland
Judgment Date
31 January 1913
Procedural Posture
Company Law Action / Judgment After Proof
Outcome
Defender entitled to absolvitor; claim dismissed.
Legal Topics
Shareholder Liability, Estoppel, Liquidation, Allotment of Shares, Representation on Share Certificates

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Parties

Penang Foundry Company, Limited (In Liquidation) and Others

Pursuer

A. H. Gardiner

Defender

Procedural Posture

Company Law Action / Judgment After Proof

  1. 1 Whether an allottee of shares, who receives share certificates stating shares are fully paid and believes this in good faith, can be held liable for unpaid amounts when the company goes into liquidation.

Ratio Decidendi

Where a company issues share certificates stating shares are fully paid, and the allottee accepts them in good faith believing this representation, the company is estopped from claiming otherwise and cannot recover unpaid amounts from the allottee.

Court Disposition

Defender entitled to absolvitor; claim dismissed.

Orders

  • Absolvitor granted in favour of the defender.
  • Pursuers' claim for payment of £560 dismissed.