Decisions are coming fast and furious as the Privy Council clears it decks before Michaelmas term hearings start on 2 October. Four judgments came down last week. We wrote about Krys v Farnum Place LLC in last week’s update, and on 25 September 2025 we got judgments in:
- Cable & Wireless Jamaica Ltd v Abrahams [2025] UKPC 44, a Jamaican scheme of arrangement case that will be of interest to restructuring practitioners in most jurisdictions using English-style schemes. The Board agreed with the courts below that the scheme was rightly refused sanction. The minority shareholders who were to have their shares cancelled should have constituted a separate class for voting purposes, and the statutory procedure for reducing the company’s share capital had not been followed.
- Chief Fire Officer & Ors v Ramsaran [2025] UKPC 46, a Trinidad & Tobago case where the Board found that the appellant had been denied a fair opportunity to be considered for appointment as the Deputy Chief Fire Officer, and is entitled to have an assessment of damages in the High Court.
- Trotman v Ramsaroop [2025] UKPC 45, a Trinidad & Tobago case on costs in habeas corpus proceedings. The Board dismissed the appeal, and took the opportunity to discuss several costs assessment points that may be of interest to practitioners in that area.
Two judgments are scheduled for release on 30 September:
- Ankong & Anor v Green Elite Ltd (in Liquidation), a BVI case about the application of the Duomatic principle of informal approvals of company actions by shareholders.
- Maso Capital Investments Ltd & Anor v Trina Solar Ltd, a merger appraisal case from the Cayman Islands concerning the trial judge’s valuation methodology. At trial, the Grand Court determined fair value by weighing the market price, merger price, and a discounted cash flow valuation in a ratio of 30:45:25. The Court of Appeal removed the merger price and said fair value should be determined in the ratio 30:70 market price and DCF valuation.
And finally, back in the courtroom! On 2 October, a panel of Lord Hodge, Lord Lloyd-Jones, Lord Sales, Lord Hamblen, and Lord Stephens is scheduled to hear Maharaj v National Gas Company of Trinidad and Tobago, a freedom of information case about the proper approach to balancing the public interest when the public authority considers an exemption to disclosure applies.