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UK Law Reference
Toate cazurile
Company Law
Court of Appeal
1976

DHN Food Distributors Ltd v Tower Hamlets London Borough Council

[1976] 1 WLR 852

Ratio Decidendi

The corporate veil may be lifted to treat a group of companies as a single economic entity where the subsidiaries are wholly owned and controlled by the parent, and justice requires it.

Fapte

DHN traded from premises owned by its wholly-owned subsidiary, Bronze. The council compulsorily acquired the premises and offered compensation to Bronze (as owner) but refused business disturbance compensation to DHN (as it had no legal interest in the land).

Rezumatul hotărârii

The Court of Appeal lifted the corporate veil, treating DHN and its subsidiaries as a single economic entity. DHN was entitled to compensation for business disturbance as it effectively owned the premises through its subsidiary.

Citate cheie

"These three companies should, for present purposes, be treated as one."

— Lord Denning MR

Tratament ulterior

Doubted

Disapproved in Woolfson v Strathclyde [1978] and Adams v Cape Industries [1990]. The single economic unit theory is no longer generally accepted as grounds for piercing the veil.