The Said v Butt principle protecting directors from liability for inducing their own company's breach of contract does not apply where the director directs the company to induce a third party to breach its contract with the plaintiff. A director who directs and commands the company's tortious conduct with the requisite intention is personally liable under the Performing Right Society principle. Exemplary damages are available for the tort of inducing breach of contract where the defendant's conduct demonstrates contumelious disregard for the plaintiff's contractual rights, though the quantum should be tempered where substantial compensatory damages are also awarded.
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