7.2.1 McMillan v Guest

In this 1942 case, it was held that a director of a private company holds a public office. McMillan was resident in the United States and since 1938 had been a U.S. citizen – he looked after the American and Canadian interests of a company called A. Wander Ltd. He had attended only one board meeting in the UK, in 1931. Lord Atkin said that there was no doubt on Rowlatt Jʼs definition, which was the law at the time (see 7.7.1), that he was an officer.

The general tenor of Lord Wrightʼs judgment is the same. He quoted the New English Dictionary definition of:

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