The combination of alleging tortious conduct and a conspiracy to commit tortious conduct is also problematic. As Lord Denning observed in Ward v. Lewis [1955] 1 All E.R. 55 (Eng.C.A.): It is important to remember that when a tort has been committed by two or more persons, an allegation of a prior conspiracy to commit the tort means nothing. The prior agreement merges in the tort. Unlawful Interference with Economic or Contractual Relations
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