Schemes of fraud:

Auditors must not be made liable for not tracking out ingenious and carefully laid schemes of fraud whenever there is nothing to arouse their suspicion, and whenever those frauds are perpetrated through  tried servants of the company and are undetected for years regards to the directors.  Therefore to hold would make the position of an auditor intolerable.....

KAY, LJ.: ".... The words of the section are "any misfeasance or breach of trust in relation to the company.... misfeasance means something other than a breach of trust...... it does not mean mere non-feasance:  RE WEDGWOOD COAL AND IRON CO...... I think the only safe interpretation to adopt is that it includes all cases other than breaches of trust in which an officer of the company has been guilty of a breach of his duty as such officer which has caused pecuniary loss to the company by misapplication of its assets, and for that in a action he might have been made liable......"