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DHN Food Distributors Ltd v Tower Hamlets LBC

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4 March 1976

End date
March 4, 1976

[1976] 1 WLR 852

DHN Food Distributors Ltd v Tower Hamlets LBC httpsuploadwikimediaorgwikipediacommonsthu

Judge(s) sitting
Lord Denning MR, Goff LJ and Shaw LJ

Court of Appeal of England and Wales

Woolfson v Strathclyde Regional, Adams v Cape Industries, Jones v Lipman, Ord v Belhaven Pubs Ltd, Lee v Lee's Air Farming Ltd

DHN Food Distributors Ltd v Tower Hamlets London Borough Council [1976] 1 WLR 852 is a UK company law case where, on the basis that a company should be compensated for loss of its business under a compulsory acquisition order, a group was recognised as a single economic entity. It stands as a liberal example of when UK courts may lift the veil of incorporation of a company.


The decision was, however, doubted in Woolfson v Strathclyde Regional Council and qualified in Adams v Cape Industries plc.


DHN imported groceries and provision and had a cash-and-carry grocery business. Its premises were owned by its subsidiary which was called Bronze. It had a warehouse in Malmesbury Road, in Bow, the East End of London. Bronze’s directors were DHN’s. Bronze had no business and the only asset were the premises, of which DHN was the licensee. Another wholly owned subsidiary, called DHN Food Transport Ltd, owned the vehicles. In 1970 Tower Hamlets London Borough Council compulsorily acquired the premises to build houses. As a result, DHN had to close down. Compensation was already paid to Bronze, one and a half times the land value. DHN could only get compensation too if it had more than a license interest. The Lands Tribunal held no further compensation was payable.


The Court of Appeal held that DHN and Bronze were part of a single economic entity. Therefore, as if DHN had owned the land itself, it was entitled to compensation for the loss of business.

Lord Denning MR's judgment went as follows.

Goff LJ concurred and read his judgment.

Shaw LJ concurred with both judgments, and concluded with the following.


DHN Food Distributors Ltd v Tower Hamlets LBC Wikipedia

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