CL-2018-000297, CL-2018-000404, CL-2018-000590, - [2025] EWHC 2364 (Comm)

OMV Petrom v Glencore [2015] EWHC 666 (Comm), in which Flaux J (as he was then) attributed responsibility for misrepresentations made to the claimant buyer of oil, through documents issued by the defendant to another in which the defendant knowingly misdescribed the oil sold, since the defendant intended the misdescription to be given to and relied on by buyers like the claimant;

European Real Estate Debt Fund v Treon [2021] EWHC 2866 (Ch), to the extent it considered the possible liability of a defendant who was said to have procured company directors to cause a parent company to make false representations, the parent company being unaware of the falsity;

the recent decision of Foxton J in 4VVV Ltd et al v Spence et al [2024] EWHC 2434 (Comm) that certain individuals were liable for deceit who had acted to ensure that materials used by Emerging Properties Ltd (‘EPL’) to attract property investors would make false representations, so that investors would be tricked into investing, without any finding as to whether EPL acted fraudulently (so the liability found was a primary liability, not liability as accessories to a deceit committed by EPL).