Williams v Natural Life Health Foods Ltd [1998] 1 WLR 830

House of Lords

Basic Facts: W, who started a franchise based on misleading information from a company, sued the company’s Managing Director (D) personally after the company failed.

Issue: Can an individual be personally liable for negligent advice provided by a company?

Held: denied Plaintiff’s claim against Defendant personally in tort. D was always acting as a corporate agent and therefore liability was restricted to the company and not him personally.

  • Lord Steyn:

    • Personal liability requires showing that the individual assumed personal responsibility for the advice or services provided.

    • Mere association with the company is insufficient; no personal liability established in this case.

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Wilsher v Essex Area Health Authority [1988] AC 1074

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White v Jones [1995] 2 AC 207