Allegations of dishonesty in English civil litigation – whether against individuals or corporate bodies – are not to be made lightly, and care must be taken over how they are pleaded. This is reflected in paragraph 8.2 of Practice Direction 16, which provides that a claimant must "specifically set out…any allegation of fraud" in the Particulars of Claim. The Court of Appeal has, in the recent case of Sofer v SwissIndependent Trustees SA  EWCA Civ 699, provided useful guidance on the relevant standard when pleading dishonesty against a corporate defendant.
In summary, the Court of Appeal found for the Claimant in holding that it is not necessary specifically to identify in the Particulars of Claim the individuals within the defendant corporate body whom it is alleged had the relevant knowledge of the dishonesty (which knowledge is to be attributed to the corporate defendant). A Claimant is instead to provide the best particulars possible pending disclosure.