A shareholder cannot recover damages for diminution in the value of shareholdings where that loss reflects loss suffered by the company, even where the defendant owed a separate and independent duty of care to the shareholder personally. Framing the claim as a lost chance or opportunity to prevent mismanagement of corporate assets does not alter the reflective nature of the loss. The New Zealand approach in Christensen v Scott, which permitted such recovery based on the existence of an independent duty, is not followed in Queensland.
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