There was only one issue before the Court of Appeal in the recent case of Equitable Life Assurance Society v. Hyman 1 and it was not in itself a particularly complicated one. But with Lord Woolf, M.R., seeing the question largely as a matter of public law, Morritt, L.J., as one of company law and Waller, L.J., as one of contract, the picture which emerges is anything but straightforward. The issue was whether it was open to the directors of the claimant Society to declare bonuses at differential rates to holders of its policies who fell into two different categories.

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