Reviewed case brief

Erlanger v New Sombrero Phosphate Co

(1878) 3 App Cas 1218

(1878) 3 App Cas 1218 · House of Lords

promoterfiduciary-dutysecret-profitdisclosureindependent-board
Court
House of Lords
Year
1878
Subjects
Company Law
Reviewed
2026-08-02

Rule established

A promoter stands in fiduciary relation to the company and must disclose all material facts including personal profit to an independent board

Facts

    Issues

      Held

        Ratio decidendi

        How to use it in an exam

        Editorial source

        (1878) 3 App Cas 1218

        Educational summary only. Read the reported judgment or an authorised law report before relying on the case professionally.