Industrial Developments v Cooley [1972]

Strict
approach maintained.
Defendant
was MD of plaintiff company.
Became
aware of information that would have been valuable to company.
Instead
of passing it on to company he kept it to himself.
Obtained
release from company by dishonest representation –
Intended
to obtain lucrative contract for himself.
Other
party objected to plaintiff company’s set up, so would not have been possible for
plaintiff company to obtain contract.
Roskill
J held that despite this, and despite fact defendant made it clear to other
party he was dealing with him on personal basis, defendant must account to plaintiff
company for profits made from contract.