The Supreme Court decided on 16 December 2008 in the Worldport Ireland Limited case that bodies corporate or companies cannot be restricted under Section 150 of the Companies Act 1990.

The Supreme Court overruled the 2005 decision of the High Court which had concluded that the Companies Acts did not prohibit a corporate entity from being a shadow director both generally, and for the purposes of restriction under section 150.

However, companies may still fall within the definition of "shadow directors" as defined by Section 27 of the Companies Act 1990. Shadow directors are persons in accordance with whose directions or instructions the directors of a company are accustomed to act.