The 'fraud exception' formulation from Beach Petroleum v Johnson does not permit attribution of a director's knowledge to the company for limitation purposes when the director faces claims for breach of duty, regardless of whether the company received any benefit from the director's conduct.
The full text is available to signed-in members, including the 9 later cases that cite this judgment.
3 of the 9 citing cases carry a classified treatment. How each court treated it is available to signed-in members.