the true facts or when a subsidiary company was acting as an authorised agent of its parent, and apparently not so just because "justice requires" or to treat a group of companies as a single economic unit. In the case of tort victims, the House of Lords suggested a remedy would, in fact, be available. In Lubbe v Cape plc Lord Bingham held that the question of proving a duty of care being owed between a parent company and the tort victims of a subsidiary would be answered merely according to standard principles of negligence law: generally whether harm was reasonably foreseeable. In Chandler v Cape plc, it was held that the corporate veil was not relevant in tort cases, thus effectively circumventing Adams. In VTB Capital plc v Nutritek International Corp, Lord Neuberger remarked, "In addition, there are other cases, notably Adams v Cape Industries plc [1990] Ch 433, where the principle [of piercing the corporate veil] was held to exist (albeit that they include obiter observations and are anyway not binding in this court)." See also UK company law and US corporate law Lubbe v Cape Plc [2000] 1 WLR 1545 Berkey v. Third Avenue Railway 244 N.Y. 602, 155 N.E. 914 (1927) a well known corporate veil case in US corporate law, concerning tort victims Notes References E McGaughey, 'Donoghue v Salomon in the High Court' (2011) 4 Journal of Personal Injury Law 249, on SSRN English conflict of laws case law United Kingdom company case law Court of Appeal (England and Wales) cases 1990 in case law 1990 in British law United Kingdom corporate personality case law