August 28, 2025
Lever Bros Ltd v Bell [1932] AC 161, [1931] UKHL 2
Facts Lever Brothers Ltd (Appellants) held a controlling interest in the Niger Company. Mr Bell and Mr Snelling (Respondents) were appointed as chairman and vice-chairman, respectively, of the Niger Company under five-year service contracts. As part of a corporate restructuring, Lever Brothers decided to terminate these appointments prematurely. They entered into compensation agreements with Bell and Snelling, paying them £30,000 and £20,000 respectively, in consideration for the early termination of their service contracts. Subsequent to these payments, Lever Brothers discovered that both Bell and Snelling had, during their employment, committed serious breaches of their duties as directors. They had secretly