1Administrators of a company in voluntary administration owe duties to the company and its creditors collectively, not to an individual director, shareholder, or single creditor; a director's personal losses flowing from the administration are properly claims of the company requiring leave for a derivative action.
2Where a solicitor is consulted by a sole director about the company's solvency concerns, the retainer is ordinarily with the law firm and the client is the company, not the director personally, absent evidence of a personal retainer.
3The tort of conspiracy by unlawful means is not established merely because professionals who referred work to each other stood to earn fees from a voluntary administration; knowledge of a prospect of remuneration does not prove an agreement to act unlawfully with intent to injure.
