To establish that a defendant is a shadow director of a company, it is necessary to allege and prove:

who are the directors of the company, whether de facto or de jure;

that the defendant directed those directors [on] how to act in relation to the company or that he was one of the persons who did so;

that those directors acted in accordance with such directions; and

that they were accustomed so to act. What is needed is:first, a board of directors claiming and purporting to act as such; and secondly, a pattern of behaviour in which the board did not exercise any discretion or judgment of its own, but acted in accordance with the directions of others.

Per Re Hydrodan (Corby) Ltd. [1994] 2 BCLC 180

Highlights on Introduction to Directors of Companies in Ghana