Practitioners acting for liquidators in phoenix company and carousel payment schemes should note the Court's detailed treatment of the release rule in equity, finding that liability of knowing assistants under Barnes v Addy is several rather than joint, such that settlement with one wrongdoer does not release others. The judgment also confirms that a liquidator's failure to challenge tax assessments under Part IVC does not necessarily break the chain of causation for equitable compensation claims against directors and accessories.
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