The claim against the liquidator was abandoned due to the fact that he was an insolvency practitioner and had no personal responsibility for the present state of the site and there was nothing to suggest that the “liquidator did anything wrong”.  What is involved in the concept of doing nothing wrong is not explained.  Interpreting the risk to liquidators in light of this case and the leading Irish Ispat case (in which a liquidator also escaped clean up costs), liquidators need to carefully consider what actions to take, or not to take, if it transpires that issues arise about unlawful waste – bearing in mind that ‘waste’ can include anything that is to be discarded.