neither may recover loss caused to the other by breach of the duty owed to that other. Applying these tests, the House of Lords held that one of Mr Johnson's claimed heads of loss should be struck-out (diminution in the value of his shareholding in WWH, and amounts which WWH would otherwise have paid into his pension), and the remaining claims were allowed to proceed (these included the cost of personal borrowing by Mr Johnson to fund his outgoings and those of his business, the value of shares lost when the bank foreclosed upon security which he provided, and additional tax liability). The court held that the claims for cost of borrowing would need to be scrutinised carefully at trial to ensure that they were not merely claims for lost dividends (which were not allowable) in disguise. The court also allowed a claim for losses on other investments which Mr Johnson made based upon advice from Gore Wood. The court also struck out claims for mental distress and aggravated damages on other grounds. The rule against reflective loss is justified by the need both to prevent double recovery and to provide protection for the company's creditors, who might be prejudiced if the shareholder's claim were to succeed. Commentary The case has generally been accepted as correctly decided and stands as an authoritative proposition of the law. See also Abuse of process Notes United Kingdom company case law House of Lords cases 2000 in case law 2000 in British law