“…58 the criminal offence could be committed even if the company was not being wound up; thus departing from what the House of Lords had held in DPP v Schildkamp [1971] AC 1 (this amendment had in fact been made by the Companies Act 1981). In that respect, therefore, criminal liability was more extensive than civil liability.…”
“…be noted that, although the sidenote to a statutory provision can be an aid to its construction, it is no more than that. As Lord Reid put it in R v Schildkamp [1971] AC 1, 10:…”