Under the Insolvency Act 1986 section 212,[171] a liquidator or administrator can bring a claim for summary

Director duty cases
See also: UK company law, Directors' duties in the United Kingdom, Directors' duties, Misfeasance, and CDDA 1986

Under the Insolvency Act 1986 section 212,[171] a liquidator or administrator can bring a claim for summary judgment in the company's name to vindicate any breach of duty by a director owed to the company. This means the directors' duties found in the Companies Act 2006 sections 171 to 177, and in particular a director's duty to act within her powers, her duty of care and duty to avoid any possibility of a conflict of interest. "Director" in this sense is given a broad scope and includes de jure directors, who are formally appointed, de facto directors who assume the role of a director without formal appointment, and shadow directors, under whose directors the official directors are accustomed to act.[172] The candidates for de facto or shadow directors are usually banks who become involved in company management to protect their lending, parent companies, or people who attempt to rescue a company (other than insolvency practitioners). In Re Paycheck Services 3 Ltd a majority of the Supreme Court held that acting as a director of a corporate director cannot make someone a de facto director unless they voluntarily assume responsibility for a subsidiary company.[173] Similarly to be shadow director, according to Millett J in Re Hydrodam (Corby) Ltd[174] it is not enough to simply be on the board of a parent company.