Where a party claiming misleading or deceptive conduct fundamentally misunderstands the scope of financial documents — such as treating figures for two businesses as relating to one — and then engages in their own projections and analysis based on that misunderstanding, the causal chain between the misleading conduct and the decision to enter the transaction is broken. This is distinguishable from mere naïve or unreasonable reliance, which does not of itself sever the causal link. Additionally, where actual performance meets the level depicted in allegedly misleading documents and the ultimate loss is caused by wholly unrelated supervening events, causation of loss is unlikely to be established.
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