In a judgment useful to insolvency practitioners, a court has recently confirmed that liquidators are not personally liable for payment of dividends. In Lomax Leisure v Miller and Bramston  EWHC 2508 (Ch) Miller and Bramston faced personal claims on dividend cheques they had cancelled, after receiving a pending application from a creditor whose claim they had rejected. Miller and Bramstom were later replaced by a new liquidator who brought claims in the name of the company and various creditors. The court found that the duty to pay a dividend does not override a liquidator’s general duty to properly consider all claims arising. Furthermore, the court found that a liquidator is not personally liable to pay a dividend and there is no relationship of debtor and creditor between the liquidator and any creditor. The remedy available to creditors in these circumstances would be an application for payment of the dividend under IR4 182(3) or if this fails, because of a dissipation of assets, a claim for misfeasance in office.