Re Charnley Davies Ltd (No 2) [1990] BCLC 760 is a UK insolvency law case concerning the administration procedure when a company is unable to repay its debts.

It held that an administrator would only breach a duty of care (here in selling off property, arguably for too little) if an ordinary, skilled practitioner would have acted differently.

Creditors of Charnley Davies alleged that the administrator, Mr AJ Richmond, acted with undue haste in selling the business.

The administrator owed a duty to a company to obtain a proper price for assets, the same as for anybody with a power to sell property that does not belong to him (such as a mortgagee, as in Cuckmere Brick Co Ltd v Mutual Finance Ltd [1971] Ch 949).

In order to succeed the claimant must establish that the administrator has made an error which a reasonably skilled and careful insolvency practitioner would not have made.’ Millett J also said the following.