Manifest error

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manifest error” was in IIG Capital llc v Van der Merwe[1] as one which is “obvious or easily demonstrable without extensive investigation” even if not readily apparent at the time that the certificate was provided.

In North Shore Ventures Ltd v Anstead Holdings Inc the court said:

“it is quite possible for one person to certify the existence of some fact at a particular moment in time which the other person, the recipient of the certificate, cannot verify save after the occurrence of a subsequent event”.

See also

  1. [2007] EWHC 435 para 52