David Blayney KC and Sophie Holcombe, instructed by Pinsent Masons, successfully obtained reverse summary judgment in relation to various claims dating back to 2005 brought by the liquidators of three venture capital trust companies against the investment manager and individual members of the investment manager. The Court held that the claimants were unable to show that they had real prospects of establishing that the limitation period was extended by section 32(1)(b) of the Limitation Act 1980 (deliberate concealment) in circumstances where the claimants had failed to articulate an arguable case on the elements that needed to be established by a claimant relying on section 32 (paragraph 96 of the Judgment), either in their evidence or in their response to a Part 18 request before the hearing.  These necessary elements included the identification of allegedly concealed facts, and the claimants' own lack of knowledge of, and/or inability to discover, such facts, before they were placed in voluntary liquidation. The claimants alleged that the principle of "wrongdoer control" made it arguable that no knowledge could be attributed to them at the relevant time, but the court dismissed this argument because the claimants had directors at the time who were not said to have been wrongdoers, through whom knowledge and discoverability could be attributed (paragraphs 115-118 of the Judgment). The Judgment includes a useful review of the authorities relating to the operation of section 32(1)(b) in circumstances where it is alleged that wrongdoers were in control of a claimant company.  It also demonstrates the valuable role that can be played by a Part 18 request in advance of a summary judgment hearing.