CaseSnappy Blog

Decoding Judgements: The Fine Line of Fiduciary Duty – Lehtimäki v Cooper

4 October 2024 | CaseSnappy Team

A person cupping their hands to hold loose change and a handwritten note reading "MAKE A CHANGE."

Introduction

Greetings CaseSnappy enthusiasts! Today’s Decoding Judgements series blog post features the intriguing case of Lehtimäki and others (Respondents) v Cooper (Appellant) [2020] UKSC 33, revolving around the complex web of charitable trusts, fiduciary duties and the wide-ranging power of courts.

A Charity’s Dilemma: The Case Facts

Highlighting the dispute is CIFF, a charitable company, intending on making a $360 million grant to a new charity, BWP, founded by Ms. Cooper, a former member and trustee. Approval of this grant necessitated consent from the company's members and the Charity Commission. The spotlight fell on Dr. Lehtimäki, the sole non-conflicted member, who was ambiguous about his voting choice.

To Vote or Not to Vote: The Issues

Ms. Cooper sought an order requiring Dr. Lehtimäki to vote in favour of the resolution. However, Dr. Lehtimäki and another party contended three key points: the member isn't a fiduciary, thus an order can’t be made; the court doesn't typically interfere with a fiduciary’s discretion unless he's imprudent or unreasonable; and that Companies Act, s 217 denies the court from directing Dr. Lehtimäki's vote.

Figuring Out Fiduciary: The Decision

The UK Supreme Court confirmed that Dr. Lehtimäki was a fiduciary when acting as a member of CIFF. The court held it could direct Dr. Lehtimäki to vote in favour of the resolution, ruling Companies Act 2006, s 217 didn't bar it from directing a member's vote. This led to the appeal being allowed and an order directing Dr. Lehtimäki to vote in favour of the resolution.

In his judgement, Lord Briggs determined that "Where the court has finally decided what is in the charity’s best interests there can be no reasonable basis for a fiduciary acting contrary to that decision and, here, actually vetoing the transaction which the court has decided best furthers the purposes of the charity."

CaseSnappy: Unravelling Judgements

In the case of Lehtimäki and others (Respondents) v Cooper (Appellant) [2020] UKSC 33, we witness the intriguing interplay between charitable trusts and the intricate concept of fiduciary duty. This judgement emphasises the wide scope of a court's power in ensuring the fulfilment of fiduciary obligations, even amidst contentious debate surrounding the exact role of a member.

Don’t forget to join us for our upcoming Decoding Judgements blog series, offering you insights on more fascinating cases. Want to delve deeper into legal knowledge? Join our CaseSnappy community today for free!

Get started
By using CaseSnappy, you agree to the storing of cookies on your device to enhance site navigation, analyse site usage and assist in our marketing efforts. View our Privacy Policy for more information.