In Re Windsor Steam Coal Co  1 Ch 151 it was held that a liquidator may be liable to the company for negligence if he does anything that causes some loss to the company or its creditors.
Misfeasance of Liquidator—No Wilful Default—Payment in Settlement of Invalid Claim—Liquidator’s Liability to makegood—Trustee or Agent—Claim to Indemnity—” Loss “—Negligence —Trustee Act, 1925 (15 Geo. 5, c. 19), s. 30, sub-s. 1; «. 61.
Russell LJ said:
“…the liquidator, Mr. March, paid away a sum of 15,000 to persons who had no claim to it, knowing that the persons who otherwise would be entitled to those moneys objected to the payment being made”
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