| Commentary

(c) Secret profits

| Commentary

(c)     Secret profits

The employee must not make any secret profits (Boston Deep Sea Fishing and Ice Co v Ansell (1888) 39 Ch D 339), and must account to the employer for any he does make: Reading v A-G [1951] AC 507, [1957] 1 All ER 617. One interesting variant of this occurred in Padden v Arbuthnot Pensions and Investments Ltd [2004] EWCA Civ 582, [2004] All ER (D) 165 (May) where the Court of Appeal upheld a High Court ruling that an employee who had defrauded a client was

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