Armitage v Established Investments Limited (in liq) involved an appeal by an undischarged bankrupt (A), against a High Court decision imposing conditions that A was not to engage in business for three years following discharge at the end of his bankruptcy. The High Court had also ordered that the period of bankruptcy was to be extended for three years beyond the statutory three year period, although A did not challenge this aspect of the High Court decision.

In upholding the High Court decision to impose conditions on A's business activities after discharge, the Court of Appeal noted that A had been adjudicated bankrupt three times, had continued with conduct causing loss to creditors both before and into his third bankruptcy and had been convicted for dishonesty offences. In all the circumstances, the serious lapses of commercial morality shown by A required the protection of the community and the orders made by the High Court restricting A's ability to engage in business activities after discharge were appropriate. The appeal was dismissed.

See Court decision here.