Where companies had borne losses sustained as a result of fraudsters usurping the identity of genuine shareholders, and where the companies, the providers of registration services, the stockbrokers, and the true shareholders had all been innocent of wrongdoing, those companies were unable to recover contribution from the stockbrokers on the basis of implied indemnity as there was an estoppel by representation that their share certificates naming the fraudsters as the genuine shareholders conferred prima facie title at the relevant time, and they could not prove that the persons they had reinstated to share ownership were the true shareholders.

[2006] EWHC 1184 (Ch)