Medforth v Blake

Medforth conducted pig farming on a large scale, with a £2 million annual turnover and a herd of 3000 sows, 120 boars and 11000 weaners.

Scott VC, drawing upon jurisprudence established in such prior cases as Cuckmere Brick Co v Mutual Finance and Downsview Nominees Ltd v First City Corporation Ltd, summarised the law as follows.

[...] In my judgment, in principle and on the authorities, the following propositions can be stated:- (1) A receiver managing mortgaged property owes duties to the mortgagor and anyone else with an interest in the equity of redemption.

(3) The extent and scope of any duty additional to that of good faith will depend on the facts and circumstances of the particular case.

Medforth revised the position previously taken by the Privy Council in Downsview Nominees, where a receiver's duty of care to the company was limited to a requirement that he take reasonable steps to obtain a proper price on the exercise of his power of sale.