In Lipschitz and Another NNO v Wolpert and Abrahams an important case in South African law, the auditors of a company in liquidation were sued under section 184 of the Companies Act to contribute an amount in excess of R3 million to the company's assets as compensation. An exception was successfully filed to the particulars of claim on the basis that an auditor, appointed under section 98 (1) of the 1926 Companies Act, was not an "officer of the company" within the meaning of the phrase in section 184 (1). Holmes JA quoted section 184(1) to the following effect:
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