Company law is part of an ideology. It is part of an ideology about the way in which our society should function. Ever since the decision in Salomon v A Salomon & Co Ltd (1897), it has become a part of our national culture that investment and economic growth were more important than an old morality about an individual being responsible for their own actions and their own debts. The House of Lords gave legitimacy to the idea that businesspeople could protect themselves from loss (and thus impose the risk of loss on everyone they dealt with) by using a company. Companies proliferated wildly as a result. The effect was twofold. First, companies became the most signi cant economic actors in our economies and acquired a personality in the minds of ordinary people as well as in our company law. Second, a sense of unreality took hold in that we all accepted that these abstract entities controlled so much of our lives. We accepted that these intangible legal persons should be treated as though they were people because of the status that company law gave them.