ABSTRACT
The scope of the misfeasance application was extended in 1986 so that it now includes negligence actions; company directors17 are under an obligation to carry out their duties with reasonable care and skill. Historically, a low standard of care has been imposed on directors. In Re City Equitable Fire and Insurance Co Ltd,18 it was held that the standard was a subjective one and that a director need not exhibit in performance of his or her duties a greater degree of skill than might reasonably be expected from a person of his or her knowledge and experience. It was also held that a director is not bound to give continuous attention to the affairs of the company. Where duties may properly be left to some other official, a director is justified in trusting the official in the absence of grounds for suspicion.19
