ABSTRACT
In the recent case of Rukhadze v Recovery Partners GP Ltd, the UK Supreme Court was given the opportunity to reconsider the House of Lords’ previous formulations of the account of profits doctrine in Regal (Hastings) Ltd v Gulliver and Boardman v Phipps. It was concluded that the position in Regal and Boardman regarding the necessary link between the fiduciary position and the profits to be accounted for should be retained. However, the four judgments issued by the Supreme Court not only revealed very different bases for this holding, but also revealed several differences in interpretation of Regal and Boardman. This note summarises the four judgments, comments on the Court’s views on the character of the account of profits doctrine, and suggests ways in which future cases may further refine the doctrine.
Fong Jun Yi, On Causation and Accounts of Profits: Rukhadze v Recovery Partners GP Ltd, Modern Law Review. First published: 30 July 2026.
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