Company – Subsidiary company. The claimants were nowhere near being able to show that they had a good arguable claim against the first defendant parent company on the basis of advice said to have been to the second defendant subsidiary as to the management of risk of political unrest and violence in Kenya. Accordingly, the Court of Appeal, Civil Division, dismissed the claimants' appeal on grounds different from the judge, with the result that there was no anchor defendant for proceedings in England.