Lonrho Ltd v Shell Petroleum Co Ltd [1980] 1 WLR 627

Court: House of Lords

Facts: Lonrho Ltd sought disclosure of documents from Shell Petroleum, the parent company, which were held by its subsidiary. The issue was whether the parent company could be compelled to disclose these documents.

Issue: Can a parent company be required to disclose documents held by its subsidiary, given the principle of separate corporate personality?

Held: The House of Lords ruled that disclosure could not be granted against the parent company because the documents were owned by the subsidiary, which was a distinct legal entity.

Key Judicial Statement: Lord Diplock stated, "It is fundamental to our law that the rights and obligations of a company are distinct from those of its shareholders."

💡Leveluplaw: Each company in a corporate group is a separate legal entity, and a parent company cannot be compelled to disclose documents owned by its subsidiary.