In Rabson v Croad [2013] NZSC 3, the Court of Appeal dismissed Mr Rabson's appeal of a High Court order pursuant to section 301 of the Companies Act 1993 (Act) that he reimburse $58,084.31 to a company in liquidation of which he had been a director.  Mr Rabson sought leave to appeal to the Supreme Court to challenge the Court of Appeal's substantive determination on the basis that (among other things) the High Court failed to comply with section 301 of the Act which confers on the Court the power, in the course of a liquidation, to inquire into the conduct of certain persons and if appropriate order that they repay money to the liquidated company.

The Supreme Court confirmed the Court of Appeal's finding that inquiry through the formal proof proffered by the liquidators in the High Court when Mr Rabson failed to appear, despite notice, fulfilled the requirement of section 301.

See court decision here.