Lonrho v Shell Petroleum [1982]

Lord Diplock:
Where only manner of enforcing performance for which
Act provides is prosecution for criminal offence of failure to perform
statutory obligation, two classes of exception to general rule:
1.  Where Act
imposed for benefit or protection of particular class of individuals.
2.  Where Act
creates public right and particular member of public suffers ‘particular,
direct and substantial’ damage different to that which was common to all rest
of public.