Adams v Cape Industries plc
UK company law case
Adams v Cape Industries plc [1990] Ch 433 is a UK company law case on separate legal personality and limited liability of shareholders. The case also addressed long-standing issues under the English conflict of laws as to when a company would be resident in a foreign jurisdiction such that the English courts would recognise the foreign court's jurisdiction over the company. It has in effect been superseded by Lungowe v Vedanta Resources plc, which held that a parent company could be liable for the actions of a subsidiary on ordinary principles of tort law.
The decision's significance was also limited by the House of Lords decision in Lubbe v Cape plc and the groundbreaking decision in Chandler v Cape plc, holding that a direct duty may be owed in tort by a parent company to a person injured by a subsidiary.
Facts
Cape Industries plc was a UK company, head of a group. Its subsidiaries mined asbestos in South Africa and shipped it to Texas in the US, where a marketing subsidiary, NAAC, supplied the asbestos to another company in Texas. Employees of the Texas subsidiary became ill, with asbestosis. They sued Cape and its subsidiaries in a Texas court. Cape was joined and argued there was no jurisdiction to hear the case. Judgment was still entered against Cape for breach of a duty of care in negligence to the employees.
“Adams v Cape Industries plc” enters the record as uK company law case. Crown Archives preserves that source wording while asking what Adams, Cape and Industries can confirm, complicate or overturn.
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Chronology, provenance and viewpoint should be read together before a broad social or political interpretation is accepted. The source revision retrieved here is dated Jun 2, 2024. The linked authority identifier is Q4680487. The first chronological checks are 1990.
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This entry incorporates text from “Adams v Cape Industries plc” on English Wikipedia. Contributors are listed in the page history. Text is available under the Creative Commons Attribution-ShareAlike 4.0 License. Selected authority identifiers and statements are retrieved from Wikidata under CC0; their references and qualifiers remain part of the verification path.