Reviewed case brief

Regal (Hastings) Ltd v Gulliver

[1967] 2 AC 134

The House of Lords held that directors who acquire profit by reason of their fiduciary position must account for it to the company. The rule applies strictly — it is immaterial that the directors acted honestly, that the company suffered no loss, or that the company could not itself have obtained th

directorsfiduciary-dutyno-profit-ruleaccountabilitycorporate-opportunity
Court
House of Lords
Year
1967
Subjects
Company Law
Reviewed
2026-06-30

Rule established

Directors must account for any profit made by virtue of their position; the no-profit rule is strict and applies irrespective of whether the company could have obtained the profit itself or suffered any loss.

Facts

    Issues

      Held

        Ratio decidendi

        How to use it in an exam

        Editorial source

        [1967] 2 AC 134

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