Fiduciary duty

Title of the Research Paper:
Fiduciary Duty and Fiduciary Obligation
AChapter 1 – Similar case and fiduciary duty’s jurisdiction
1.1 The Lac Minerals v. International Corona Resource
1.2 A comparison with Lac v Cornona – similaries and differences
1.3 Our advise on your questions
1.4 Definition of fiduciary duty
1.5 Judgement – a Fiduciary Relationship?
1.6 No Fiduciary duty in arm’s length commercial contract
1.7 Fiduciary duty arise from the circumstances
1.8 The Joint Operating Agreement do not form a partnership
1.9 The Operator is an agent carry out of fiduciary duty in operation
Chapter 2 – Three Duties and Implied Confidential Duty
2.1 Fiduciary Obligation
2.2 Equity of Interest
2.3 Loyalty Content
Chapter 1 – Similar case and fiduciary
duty’s jurisdiction
Dear Chief Executive Officer of Afterit,
Thank you for your business given to our law firm and your absolute trust in that we will give you the
appropriate advices on this issue. We will try our best to explain you the legal issues related to your
questions.
1.1 The Lac Minerals v. International Corona Resource

After we have analysed the whole case, we found that your case is very similar to the Canadian case Lac
Minerals Ltd (Lac) v. International Corona Resources Ltd (Corona). 1The case was happened in 1981,
when Corona, a junior mining company found a prosperous gold mine area – the Williams Property in
Canada. Lac, a large mining company has arranged a meeting with Corona after heard of Corona’s
exploration. Negotiations for forming a joint venture were under progressed. Corona has disclosed to
Lac all of its exploration, including their drilling result.
Later on, without acknowledged to Corona, Lac acquired the Williams land by itself and a mine was
discovered and production is started on the Lac’s side. Total investment is Canadian dollar 200,000,000.
Corona sued for a breach of agreement and breach of duty of Lac on their agreements. Although there is
no written agreement but the informal oral agreement and some evidences on the emails. All five
members of the court concluded that Lac has breached the duty of confidence owed to Corona. The
information has past the three-part test as defined in the confidential relations. As a result, the recipient
(LAC) of the information misused the information to the detriment of the confider (Corona). 2
1.2 A comparison with the Lac v Corona Case- similarities
This case is apparently related to fiduciary duty and the confidential duty. In your case, if you apply the
adjoined area without the inform the operating committee and the non-operators by using the
information to compare with the data you had in hand, you might later being sued by them for breach
of fiduciary duty and the confidential duty for the JOA.
The similarities in this case are
a) Both regarding the issue of using of information which may consider as confidential. Lac used
the information of Corona without the consent of it. In your case, you probably had
partially used the information of the joint operating to compare with the date you had
to make the conclusion of the adjoined area.
b) Lac hold the William’s property in trust for Corona. You hold the information in trust for non-
operators because of the role of the operator.
c) Lac against the industry’s practises in the mining industry – that exchange of information is
allowed but it will keep as confidential and information won’t be used for competition
purpose. In your case, practices in the oil industry. The operator represented all the
non-operators and the operator will act in the best interests of them, therefore, the
non-operator will be protected under the fiduciary duty of the operator.
Difference :
a) The information source – Lac obtained the information from Corona in the event of negotiation
for forming a joint venture. Use of the information require the consent of Corona. In
your case, you are the operator of the joint operations, information generated from the
operation during management for the joint operation. The key issue will be do you need
to get consent of the operating committee before you can use these information. This
point will be established if you are a fiduciary capacity in the Joint Operation.
b) In Lac and Corona case, they are not in any business formats but the potential of become co-
venturers if the Joint Venture is formed. In your case, you are engaged in a joint

operation and you are acting as the operator. The court will design if you are in a
fiduciary relationship or not by the three points of scope for the exercise of power, if
you can unilaterally exercise the power and the volunerable situation of the non-
operators. In the Lac v Corona case, the breach of fiduciary is not formed because of
there is no relation in business.
c) Lac was held as being committed breach of agreement and breach of confidence duty. The
damage to Corona was award in money rather than return of the Williams Property.
Deducted the development fee paid by Lac of 50,000,000 Canadian dollars?? In your
case, the worst situation you would have will be breach of fiduciary duty and breach of
confidence duty. Remedies of breach of fiduciary duty will be based on how much profit
you would earned from the new development of the well and the possession right of
the well.
1.3 Our advices on your questions
A) Yes. You need to share your assessment of the unallocated block with the non-operators. And
B) Yes. You need to notify the non-operators of its intention to make the application; or
C) Yes/No. You may not offer the non-operators in the application even they wish to be included. It
is your decision on the question C).
The case of Meinhard v. Salmon happened in New York 1928 demonstrated the Duty of Communication
as a fiduciary duty in a joint venture relationship, the definition is the requirement of the partner need
to notify the co-partners the possible business opportunities and possible profit from the opportunities
during the course of the partnership. Fail to inform his co-partner a profitable opportunities breached
the duty of loyalty and see as self-dealing in a benefit issues. 3
1.4 Definition of Fiduciary Duty
The word “Fiduciary” comes from its roots in the Latin word “Fiducia”, means confidence and trust. A
fiduciary relationship is based on confidence and trust. The person in whom trust is given within the
relationship is called the fiduciary. If the fiduciary use his or her position to obtain the advantages at the
expense of the depending party, the latter can seek remedies from the court. 4
Fiduciary law is ruling on relationships that the person who carry the fiduciary capacity had been
imposed a high standards of conduct.5
In the book of Paul Finn’s Fiduciary Obligation (1997), he found out eight possible proscriptive duties a
fiduciary could be :
1) Not to take an unauthorized benefit from the property it holds;
2) Not to be in a situation of conflict of interest and duty;
3) Not to be in a situation of conflict of differing duties;
4) Not to inflict harm on an employer’s business

5) Not to use undue influence;
6) Not to take accretions, such as renewals of leases
7) Not to misuse confidential information; and
8) Not to take advantage of superior information derived in managing property when purchasing it.
For point 7), Fiduciary Duty when related to misuse of the confidential information is more emphasised
on who receive the information and his role / the company role in the situation. The character of the
person or the company is the essential part. Usually, they could be the manager, director, information
controller or the operator in the Joint Operating Business.
In order to protect the trusting relationship, any one or more of the above Paul Finn’s possible duties
can then be applied depending on situations. 6
The Law of Commission in the “Fiduciary Duties and Regulatory Rules : A Discussion Paper”7 has re-
defined in a more accurate way as
1) the duty not to have a conflict of interest;
2) the duty not to make an unauthorized profit;
3) the duty not to abuse confidential information; and;
4) the undivided loyalty rule (we will define in our later part the definition of undivided loyalty).
The Fiduciary Law is utilized in the promotion and preservation of desired social behaviours. Its aim is to
raise the moral standards of the commercial environment by asking the profiteers when taking profit at
the time, also considered their constructive trust that they are bearing. The Equitable doctrine is the
moral dimension to the existence of the fiduciary relation. This was shown in Chief Judge of New York
Court of Appeals in case Meinhard v. Salmon stated that :8
“A trustee is held to something stricter than the morals of the market place. Not honestly alone, but the
punctilio of an honor the most sensitive, is then the standard of behaviour….the level of conduct for fiduciaries
been kept at a level higher than that trodden by the crowd. It will not consciously be lowered by any judgement
of this court.”
1.5 Judgement - a Fiduciary Relationship or not?
The judgement of the court will include the role of the fiduciary and their influence on the society as a
whole when making their decisions. The Judge will considered whether the fiduciary relationship could
exist in such a situation9
1) The fiduciary has scope for the exercise of some discretion or power
The scope of power of operator has set as “perform duties in the Joint Operation”. The
operation duty included from the routine operation to government licensing issues. Mostly, the
management policy of the joint venture will be decided by the operating committee.10
However, the operator may have discretion on how to execute the operating committee’s
management policy. The fiduciary duty will exist during the process of their decision making

how to execute their duties, honestly or make profit to their own. 11
1) The fiduciary can unilaterally exercise that power or discretion so as to affect the beneficiary’s
legal or practical interest
The operator of a Joint Operating business, carried with all the powers in the operation in
exploration and exploitation from its definition of the role (although some of the issues need to
be approved by the Operating Committee) can definitely excerise their power unilaterally.
Besides, the limitation of the liability by the JOA granted it more fiduciary duty because of the
exempted liability of the operator.
As stated in the article 4.6 of the same agreement, operator shall not bear any damage, loss,
cost, expense or liability resulting from failing of the performance, the duties and functions of
Operator. On the exempted liability of the operator, the court could judged on the grants more
capacity to the operator and it inclined more to the fiduciary relationship with conditions
already favour to the operator.
1) The beneficiary is peculiarly vulnerable to or at the mercy of the fiduciary holding the
discretion or power.
Every joint venture or joint operating involved an agreement that lead to a common goal. The
operator is like the managing director of the company who are executing nearly all the role to
finish the common goal.
In Gerard Bean’s “Fiduciary Obligation and Joint Venture”, it stated that the role of operators
are mainly three: (1)negotiation on behalf of the co-venturers (2) advising the co-venturers (3)
implementation of decision and management of the joint venture property.
Negotiation will include the formulation of proposal. Advising will include both the evaluation of
information and making of recommendation. Implementation means carrying out the decisions
by the operating committee. 12
If the whole operation is under the duty and control of the operator, the non-operators are
actually completely rely on the performance of the operator and it can be concluded that the
non-operator (here the beneficiary) is completely vulnerable to the operator who hold most of
the power in the project.
1.6 No Fiduciary Duty in Arm’s-Length commercial contract
Fiduciary duty might not exist in the arm’s-length commercial contract and no of the parties will be in
the fiduciary relationship. In the case of Hospital Products Ltd v United States Surgical Corporation, one
company named Blackman had an exclusive distributorship arrangement for products manufactured by
United States Surgical Corporation (USSC).
Blackman’s company named Hospital Products Ltd (HPL), was soon after substituted as the distributor
and HPL using USSC products as copy model, began to manufacturing products that were exactly the
same to those produced by USSC. Is the HPL owns a fiduciary duty? The court by a bare majority held
that there was no fiduciary duty, the USSC has the right to claim for damages for breach of contract. The
majority thought that the relationship between parties is only arm’s length that the intention of the

parties are to gain profit. It stated by the Judge:
“The reason why commercial transactions falling outside the accepted traditional categories of fiduciary
relationship often do not give rise to fiduciary duties is not that they are “commercial” in nature, but that they
do not meet the criteria for characterisation as fiduciary in nature.”
1.7 Fiduciary Duty arise from the circumstances
The fiduciary relationship cannot be imposed in a contract and appeared in a Contractual Context, but it
will arise from the circumstances leading to the final agreements. In the case United Dominions
Corporation Ltd v Brian Pty Ltd, a joint venture agreement for the development of land between three
companies: United Dominions Corporation (UDC), Security Projects Ltd (SPL) and Brian Pty Ltd (Brian).
The Land was owned by SPL and it is financed by UDC on security raised from SPL. Profits was made,
however, UDC kept more by using a clause in the mortgage to SPL. Brian didn’t know about the
mortgage clause and received no profit.
The High Court found in favour of company Brian. It states that SPL and UDC owed fiduciary duty to
Brian. Dowson J said that “It is quite clear that a fiduciary relationship may arise during negotiations for
a partnership or, for that matter, a joint venture…whilst a concluded agreement may establish a
relationship of confidence…”
Fiduciary relatioships are found between partners, between agents and principals, companies and
directors, employers and employees etc. They are often referred to as the “established “ or “accepted”
catgeories of fiduciary relationship.13
1.8 This Joint Venture is not a Partnership
The relationship your company formed with Goforit and Meto does not constitute partnership when we
looked into the provisions provided in the Partnership Act of England. Two of the main criteria of a
partnership are: 1) the partnership relation must be a business and 2) the business must be carried on
with a view of making profit. The Joint Operating Agreement is only a strategic alliance when resources
are pooling together to a project.
We can say that JOA is a single venture, which means the co-venturers are not carrying on a business. 14
The business operated under a JOA is the exploring for petroleum which may also involve selling and
marketing of the petroleum explored, but none of them is a carry on business. 15 Regarding to the
profit, JOA is defined as a cost-sharing exercise , there is no joint profit, only a sharing of ultimate
product.
1.1 the Operator is an agent carry out a fiduciary duty
In a joint venture business, the role of the operator is similar as an agent or managing director. Their
main duty in business is to maximizing capital return for their partners by the performance of profit-
making during the period.

In Bowstead on Agency (1967), fiduciary duty is applicable on the agent because the agent’s acts are
thought to be those of the principal : qui facit per alium facit per se. The meaning is that where X’s acts
are treated as Y’s acts, X should act as if it were Y and therefore, there is fiduciary duty with purpose to
prevent X acting in himself or someone else’s interest.
Although in a Joint Operating Agreement the management policy will mostly being determined by the
operating committee, the operator may have discretion (the power) as to how to implement the
operating committee’s management policy. Such discretion in Operation involved to the managerial
fiduciary duty. As a result, there is an implied fiduciary duty therefore existed.
The implied duty of the operator should be, honesty toward other non-operator, not making profit from
the Joint Ventures and is subjected to a duty act bona fide in the interest of the company.
Chapter 2: Three Duties and Implied
Confidential Duty
The Fiduciary Duty mainly involved three duties : the obligation of the fiduciary duty (avoid the conflicts
of operator’s company interest with the joint venture business), the Equity and fiduciary, the Undivided
Loyalty. We will talk one by one here and related to your case.
2.1 Fiduciary Obligation
A fiduciary has the obligation not to profit from his fiduciary position without knowledge and consent, a
duty not to conflict with other parties in the relations. The rule of profit and rule of conflicts thus applied
here.
Paul Finn said that two very important rules that is generally accepted is that the fiduciary
a) Cannot misuse his position, or knowledge or opportunity resulting from it, to his own or to a
third party’s possible advantages or
a) Cannot in any manner falling with the scope of his service, have has related to the rule of
conflict.
The rule of profit and the rule of conflict has been also reflected in the Australian case Chan v. Zacharia
(1984) and Keech v Sandford (1726) .

Dr. Chan and Dr Zacharia are partnership and runned a medical practice centre. The centre was engaged
in a three year lease inside a premise with an option that it can be renewed for a further two years.
When the business reached the third year, the partners determined to wind up the company. The
appellant, Dr Chan, within the option period, renew the lease for himself for two years and the lessor
gave him a two years renewal upon the payment for a premium.
It was held by the court that a fiduciary relationship did exist and Dr. Chan was bound to count in the
winding up of the partnership and he is therefore a constructive trustee for any benefit he received from
the new lease. The court stated that the fiduciary relationship can countinue despite the fact that the
partnership is dissolved. Dr. Chan abused his position as a fiduciary in a trustee and former partner
relationship and in looking to obtain an advantage for himself. He subjected the performance of his
personal interest rather than interest of the partnership.
In Keech v Sandford, 16Lord Hershell said for this case “ It(the fiduciary duty) is an inflexible rule of the
court of Equity that a person in a fiduciary duty position, is not…unless otherwise expressly provided,
entitled to make a profit; he is not allowed…human nature being what it is, there is danger, in such
circumstances…being swayed by interest rather than by duty, and thus prejudicing those whom he was
bound to protect.”
Operator shall not involve in a position of conflict of interest to his other partners (non-Operators in
your case). The data ( is received from the well that is completed under the drilling ) used to be coupled
with data from the prospective value of the unallocated block is in a purpose of making profit for your
own rather than the Joint Operation. As an operator, you need to share the assessment of the
unallocated block with the non-operators, AND notify the non-operators of your intention the make the
application. And you need to be approved by the Operating Committee and pay for the cost of the data.
17
2.2 Equity of Interest
Equity is a ruler standard on fiduciaries because it is used to discourage disloyalty and to encourage
fiduciaries to promote the beneficiaries’ interest. A fiduciary can be held liable even if he has acted in
good faith and made profit for the beneficiaries as well as making a personal benefit, see case Boardman
v Phipps (1967).
Equity and fiduciary
The fiduciary obligation arise because of the actor or the party in the Joint Operation should always bear
an obligation in consider whether his actions will affect other party.
The rationale for equity’s intervention on the case between the conflicted party was illustrated by the
case from High Court of Australia in Maguire v Makaronis (1997), when the court said that
“Equity intervenes…not so much to recoup a loss suffered by the plaintiff as to hold the fiduciary to, and
vindicate, the high duty owned to the plaintiff…Those in a fiduciary position who enter into transactions
with those to whom they owe fiduciary duties labour under a heavy duty to show the righteousness of
the transactions.”
1) Protection of the Non-Operators

In the Joint Operating Agreement, the operator promise to act in the best interests of other non-
operators. Thus, they have been granted a valuable trust which is the primary goal of their JOA
relationships. Non-operators, under the fiduciary relationship, will be protected from abuse by the co-
venturers and their interests being protected. Equity is the major concern and the enforce the trust
which is at the heart of the relationship.
1) Requirements of disclosure of information
Therefore, the operator is required to disclose all the information that acquired during the joint venture
business to other non-operator and the Operating Committee in the sense that the operator will not
take the advantage of the confidential information by himself, and obtain the personal interest or secret
interest by himself.
2.3 Loyalty content
In Boardman v Phipps, Mr Boardman was the solicitor of a family trust.18 The trust also held a minor
shares in a textile company with factories in Australia. Boardman and another beneficiary Tom Phipps,
after attended a general meeting of the company and knew there was profit earned, acquired more
shares of the company by bought in a majority stake. However, they did not obtain the fully informed
consent of all the beneficiaries. Through capitalising some of the assets, the family trust make a profit,
the trust benefited from the deal of £47,000, while Boardman and Phipps earned £75,000. But then,
John Phipps, another beneficiary, sued for their profit is alleging a conflict of interest.
The court decision is ruled out that Boardman and Phipps had breached his duty of loyalty. They are
putting themselves in the conflict of interest. Even this were was a profit, they were therefore liable for
the fiduciary duty and liable for the profit. It also stated that the requirement of the trustee is strict that
no party, without the consent from all the beneficiaries, shall not involve in conflict of interest and earn
profit from their duty.
As a result, your company under the loyalty content of the fiduciary duty, when without the consent of
the operating committee and Goforit Energy and Meto Energy, cannot use the informations obtained
from the Joint Operating Business for your own interest because the datas you have hold is under the
constructive trust by the non-operators. 19The only defence given to the fiduciary (in this case, your
company) is that he did so with the informed consent of the principal (as listed in the case Parker v
McKenna).
Breach of confidence and breach of fiduciary duty may be committed by the same person or same
company at the same time. The Confidentiality doctrine will protect more because parties may be
liable for breach of confidence when they make use of information even it is innocently received. (for
example, you picked up a envelop write “ confidential” and you open it to use the information.)
Duration of Obligations
The duration of obligation for the confidential duty and the fiduciary duty is different. Fiduciary duty
is shorter compared with the confidential duty unless otherwise mentioned in the agreement.
However, the implied duration of the fiduciary duty (i.e. information used of the period carry the

former fiduciary period) could be extended even after the finish of the fiduciary capacity.
First, under the confidential duty situation, the liability for breach of confidence will come at the
moment when the information is received by the party. This period can be as long as the signed the
information as ‘confidential’ either there is the existence of the relationship between the party or
not. The wrongful use of information and disclosure charges will be as long as the required period of
confidential duty. In conclusion, validity of the claim is not rely on the continuance of the party’s
relationship. However, the claim of the confidential duty will stop automatically when it becomes
public knowledge.
Second, under the fiduciary duty circumstance, the duration of obligation will be finished when the
party has finished its fiduciary capacity in the work. The most obvious example will come from the
employees of a company, who after change of their job, are with have no obligation to its former
employer and therefore they can assist the competitor.
The only defence given to the fiduciary is that he did so with the informed consent of the principal (as
listed in the case Parker v McKenna). A full and frank disclosure of all the material information known to
the fiduciary is usually asked for in an Informed consent.
Information used should get approval
Under the strict rule, the operator of a joint venture shall base on the trust of other non-operators,
avoid all the situation of the unfair used the informations generated from the joint venture. They shall
report all the datas, statistics, figures and other informations generated from the joint operation to first
the operating committee, second to the non-operators. Any use of the datas should get approval from
operating committee and non-operators to avoid the gaining of self-interest and against a rule of fair
competiton.
However, there is an exceptional case of the continuance of the fiduciary duty when involved the
principal of trust. This is happened when the trustee involved in a conflict interest or a secret profit
made with information he got from its former client. The termination of the trustee’s fiduciary duty is
therefore declined if his conduct lead to his personal profit from the relationship. A breach of fiduciary
duty will be committed after the questioning of using the prior information.
In which, in your case, the information you are using to compare with the land you are going to acquired
need to prove is not sourcing from the duration that you are acting as the operator for the joint venture
business. In addition, your duty will mostly involved as a full time commercial fiduciary. 20This idea is
developed in US that the operator or employee cannot divert business opportunities from their
principals if those chance fall within the principal’s present line of business. The director or the manager
cannot divert or exploit the opportunities for their own benefit at which, those oppoturnities belong to
the corporation.
The Corporate Opportunity doctrine will define the opportunity as a property owned by a corporation
and assumed cannot be used without its approval. According to the amended and restated Joint
Operating Agreement made on 31st Jan 2020, article 15.2 there is a two years duration for the
confidential information and it bind that parties agreed they should kept confidential for this
information and not be disclosed to any person or entity. The acquisition of the information shall require

the approval of the Operating Committee (article 15 Venture Information-Confidentiality-Intellectual
Property).
PART I ) Only Confidential Duty
There are two cases I am going to illustrate the court’s decisions in :
1) There is no breach of confidential duty in Case One.
2) There is a breach of Confidential duty but not breach the Fiduciary Duty in case two.
The differences between Case one (without breaching any duties) to Case two (breach of confidential
duty) :
First, the scheme itself didn’t treat as confidential data. Second, there is no sufficient evidents that the
defendant has used the confidential information in its decision in the purchase agreement.
Case one : Not breach duty of confidence
In the Arklow Investments Ltd v Maclean. Arklow sought the helps from a banker, FAR to assist it in
finding investors in a project to buy an island for residential and resort purpose. Arklow’s attention is
clear and there was no secret. From the business plan and other related informations, it was known by
FAR that the whole project can function well. FAR had arranged some unsuccessful meeting for Arklow
with some brokers. However, FAR after a month, withdrew from the broker arrangement and reached
an agreement to purchase the island. Arklow sued FAR for breach of confidence and breach of fiduciary
duty, however, it was not successful.
The Court of Appeal held that FAR did receive confidential information but this was limited to six pieces
of information from the Arklow’s provided information. First, the scheme didn’t treat itself as
confidential data. There was no sufficient evidents that Far HAS USED THOSE INFORMTION DURING ITS
PURCHASE OF THE ISLAND. The fiduciary claim was also rejected because they viewed as FAR had not
taken any obligation to act in Arklow’s interest. There is no formal arrangement to this.
In this case, if your company can prove that the data you have used in the application of the adjoined
area (as shown in the graphic 1.1 , process in consider about if you are not in the fiduciary duty) which
you are going to apply is completely unrelated to the data from the joint venture business. Then, under
the case of Arklow v Maclean, you have the right not to inform the non-operator and the operating
committee.
Case that Breach of Confidential Duty but not Fiduciary Duty
The following case illustrated the breach of Confidentialy Duty but not the Fiduciary Duty.
Verco v Rutland Fund Management Ltd. Verco and Pratt, spent a lot of time to find the target company
H&T for a management buy-in and required a venture capital from investment company. Verco and
Pratt has done the detail research and also its business industrial analysis. They took their plan to RFM
who is a venture capital company. They signed a confidentiality agreement and then the plan and
related information were disclosed. However, later, RFM first expel out of Pratt then Verco by offering
completely unacceptable condition for his own buy-in in the target company. RFM developed a big
business and earn large profit after acquired H&T.

Verco and Pratt won in the case sue for RFM breach of the confidentiality agreement and they was
aswarded the damages calculated on the sales price of the project.
They also sue for fiduciary duty but failed as the there was no obliagation seems from RFM toward the
Verco as parties do not choose to enter into a partnership or pursue a jont venture, but they decided to
regulate their relationship on the basis of contract. In the contract, there is no acceptance of the
fiduciary obligations are assumed.
Bibliography
Charles Mitchell “Causation, Remoteness, And Fiduciary Gains”, HeinOnline – 17K.C.L.J. 325 2006
Kenneth M.Rosen “Meador Lecture Series 2005-2006 Fiduciaries ”, HeinOnline – 58 Ala. L. Rev. 1041
2006-2007
William A. Gregory “The Fiduciary Duty of Care : A Perversion of Words”, HeinOnline- 38 Akron L. Rev.
181 2005
Matthew Conaglen “Remedial ramifications of conflicts between a fiduciary’s duties”, Law Quarterly
Review 2010
M. Sharwood “Case Note – International Corona Resources Limited v. Lac Minerals Ltd” (Supreme Court
of Ontario, Canada Judgement of Mr. Justice R.E. Holland released 7 March 1986)
Patrick McLoughlin , Catherine Rendell “Law of Trusts”, published by Macmillan
Thomas Allen “Bribes and Constructive Trusts: A-G of Hong Kong v Reid”
Professor Cameron Steward “Fiduciary Relationship”
Dennis R. Klinck “The Rise of the “Remedial” Fiduciary Relationship: A comment on International Corona
Resources Ltd v. Lac Mineral Ltd”
John Glover “Is breach of confidence a fiduciary wrong? Preserving the reach of judge-made law”

Fiduciary duty

More Related Content

What's hot

Viewers also liked

Similar to Fiduciary duty

Recently uploaded

Fiduciary duty