31 McPherson JA at par [11] noted that applications and orders to resurrect the dissolved company have often been made. He noted that some have been refused where, for example, the application was made by a contributory or director seeking to avoid personal liability for insolvent trading, or by a creditor aiming to enforce liability both against the company and a former officer. He noted, however, that applications are commonly granted where the applicant is a would-be plaintiff attempting to recover damages, or compensation, in respect of which the company was insured for personal injuries sustained before dissolution. However, as McPherson JA noted at par [12], an order reviving a company by restoring its corporate status would be of little use to such a plaintiff if, in the meantime, the statute of limitations had run against him. Thus, in England, it became the practice to include in the order a direction that the time between dissolution and revival should not count for the purpose of the Limitation Act. In par [13] McPherson JA discussed the extent to which that practice had been followed in Australia and referred to the decision in Ellul v Active Home Improvements Pty Ltd (1993) 112 FLR 4 where, in exercising the discretion to declare a corporate dissolution void, Higgins J treated s 36 of the Limitation Act 1985 (ACT) as exemplifying a legal policy that, in such circumstances, time should be extended.