Madoff Securities International Limited (in Liquidation) v Steven Raven & Ors
Author: Chris Millar
Another set-back for Madoff recoveries. Claims against the directors for breach of fiduciary duties were dismissed, inter alia, by reference to the “Duomatic” principle i.e. where it was or would have been the case that all the company’s shareholders assented to a matter which could have been carried into effect by a resolution in general meeting, thereby authorising the directors to carry out the transaction in question.