Julius Grower, ‘The tort of bribery bares its teeth’

“The Court of Appeal’s decision in Wood v Commercial First Business Ltd; Business Mortgage Finance 4 Plc v Pengelly [2021] EWCA Civ 471; [2021] 3 WLR 395 (Wood v Pengelly) is likely to reinvigorate the amalgam of common law (as opposed to equitable) rules covering bribery. However, in attempting to short circuit the settled principles governing the rescission of contracts procured by such corruption, David Richards LJ, with whom Males LJ and Elisabeth Laing LJ agreed, raised an unnecessary and challenging question as to whether all true agents really are fiduciaries …”

Julius AW Grower, ‘The tort of bribery bares its teeth’ (2022) 138 Law Quarterly Review (Jan) 15-21.

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