Company – Voluntary winding up. The Court of Appeal, Civil Division dismissed the defendant former liquidator's appeal against an order that she contribute £548,074.56 to the assets of a company in creditors' voluntary liquidation by way of compensation for her breaches of duty. The illegality defence could not apply, as there had been no inextricable link between the claim and the fraudulent conduct, and the policy of requiring liquidators properly to collect and distribute the assets of the company that had to prevail.