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DISCLOSURE TO SELF IS NO DISCLOSURE

Dictum

“Disclosure” is not the most appropriate word to use when a person who plays many parts announces to himself in one character what he has done and is doing in another. To talk of disclosure to the thing called the company, when as yet there were no shareholders, is a mere farce. To the intended shareholders there was no disclosure at all.

— Lord Macnaghten. Gluckstein v. Barnes [1900] A.C. 240

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NATURE OF FIDUCIARY RELATIONSHIP AND AGENCY

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