The attribution of the tortious actions of a director to the company will operate to render the company liable. Does that attribution also operate to exclude the normal presumption that the director is liable for his own acts? Commonwealth courts have accorded primacy to the rules of company law and answered this question in the affirmative (Trevor Ivory Ltd. v. Anderson [1992] 2 N.Z.L.R. 517; Sealand of the Pacific v. Robert C. McHaffie Ltd. (1974) 51 D.L.R. (3d) 702). In England, the decision of the House of Lords in Williams v. Natural Life Health Foods Ltd. [1998] 1 W.L.R. 830 seemed to suggest that the answer would be no. In Standard Chartered Bank v. Pakistan National Shipping Corpn. (Nos. 2 and 4) [2002] UKHL 43, [2002] 3 W.L.R.1547 their Lordships have made this explicit: directors remain liable for their own wrongs.