The author provides a case note and analysis of the findings of Rimer J. in the decision of Gwembe Valley Department Co. Ltd (in receivership) v Koshy & Ors, concerning a farming project in Zambia. Article by Linda Linklater (Barrister, Chancery House Chambers, Leeds). Published in Amicus Curiae - Journal of the Institute of Advanced Legal Studies and its Society for Advanced Legal Studies. The Journal is produced by the Society for Advanced Legal Studies at the Institute of Advanced Legal Studies, University of London.