Reviewed case brief

Whaley Bridge Calico Printing Co v Green

(1880) 5 QBD 109

The court held that a promoter who sells property to the company he promotes at a profit is in a fiduciary position and must account for any undisclosed gain. Bowen J provided an influential description of who qualifies as a promoter.

promoterfiduciary-positionsecret-profitaccountability
Court
Queen's Bench Division
Year
1880
Subjects
Company Law
Reviewed
2026-06-30

Rule established

A promoter occupies a fiduciary position towards the company and is accountable for any secret profit made

Facts

    Issues

      Held

        Ratio decidendi

        How to use it in an exam

        Editorial source

        Queen's Bench Division Reports

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