On an application to terminate a winding up under s 482 of the Corporations Act 2001 (Cth), the concept of 'commercial morality' is primarily directed at protecting future creditors from being imperilled, not at punishing directors for past failures to meet statutory obligations. Where the company is the alter ego of a director who is free to establish a new company, refusing to terminate the winding up on grounds of past misconduct will not ameliorate the risk to future creditors and is therefore unlikely to be justified where the company is now solvent and debts have been paid.
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