NOTE 82.  ADD: See also Foster Bryant Surveying Ltd v Bryant [2007] EWCA Civ 200.

ADD AT END OF PARAGRAPH: After October 2008 (when the Companies Act 2006 comes into force), company directors cannot avoid liability by resigning in respect of (a) his duty under s.175 of the Act to avoid conflicts of interest as regards the exploitation of any property, information or opportunity of which he became aware while he was a director; and (b) his duty under s.176 not to accept benefits from third parties as regards things done or omitted by him while a director: see s.170(2), Companies Act 2006.