Companies and Corporations

6 cases · November 2017 to July 2025

Case Volume by Year

1
17
5
25
2017–2025

Key Issues & Sub-Topics

Winding up — Post-winding-up application — Power of court to terminate winding-up proceedings under s 493 Companies Act 2016 — Whether winding-up order may be terminated notwithstanding procedural regularity — Concealment of material information in winding-up petition — Draft audited financial statement showing unresolved liabilities — Whether petitioner denied existence of debt — Majority shareholders holding 56.6% equity supporting revival of family company — Need for shareholder investigation — Liquidator to cease further action — Costs of liquidation borne by applicants — Interests of justice. 1 Shares — Transmission and transfer of shares — Whether shares devolving from deceased shareholder to beneficiaries under will constitute transmission or transfer — Executor obtained probate and caused partial transfer of shares to one beneficiary with stamp duty paid — Executor later requested remaining shares to be registered in names of other beneficiaries without Form 32A or stamp duty — Company refused registration — Whether executor’s assent perfects transmission or separate transfer required — Whether Articles of Association restrict registration of beneficiaries except through proper instrument of transfer — Whether directors may exercise discretion in registration — Whether court may override mandatory requirements of Companies Act 2016 and company Articles — Companies Act 2016 ss 33, 50, 103, 105(1), (4), 109; Probate and Administration Act 1959 s 12. 1 Winding up — Inability to pay debts — Statutory demand duly served — Presumption of insolvency under ss. 465(1)(e) and 466(1)(a) Companies Act 2016 — Judgment debt arising from court orders — No bona fide or substantial dispute — Filing of appeal not amounting to stay — Winding-up petition allowed with costs — Civil procedure — Interlocutory application rendered academic by subsequent winding-up order 1 Minority Oppression — Allegation of oppressive conduct by Defendants — Whether Plaintiff established a claim for minority oppression under Section 346 of the Companies Act 2016 — Plaintiff removed from management and denied physical access to company premises — Whether such actions constituted oppression — Breakdown of mutual trust and confidence among shareholders — Whether the Plaintiff’s rights as shareholder and director were disregarded — Whether Defendants acted for an improper purpose or breached fiduciary duties — Sufficiency of evidence to support claim of oppressive conduct — Applicability and scope of Section 346 of the Companies Act 2016. 1 Winding up — Liquidator — Whether leave of the winding-up court is required to commence proceedings against a court-appointed liquidator — Whether the applicant established a prima facie case or demonstrated pecuniary loss to the company in various allegations — Whether allegations warrants the court intervention in the liquidation process. 1 Appeal — Oppression — Purchase of shares of minority shareholder — Whether petitioner’s gross delay in filing ‘oppression petition’ inexcusable and fatal — Whether in the circumstances of this case, the Applicant’s only remedy lay in a derivative action in the name of the 1st Respondent Company to the exclusion of any remedy for minority oppression — Whether in the circumstances of this case, the reflective loss principle had any application — Companies Act 1965 [Act 125], section 181 1

Winding up — Post-winding-up application — Power of court to terminate winding-up proceedings under s 493 Companies Act 2016 — Whether winding-up order may be terminated notwithstanding procedural regularity — Concealment of material information in winding-up petition — Draft audited financial statement showing unresolved liabilities — Whether petitioner denied existence of debt — Majority shareholders holding 56.6% equity supporting revival of family company — Need for shareholder investigation — Liquidator to cease further action — Costs of liquidation borne by applicants — Interests of justice. 1 case

Shares — Transmission and transfer of shares — Whether shares devolving from deceased shareholder to beneficiaries under will constitute transmission or transfer — Executor obtained probate and caused partial transfer of shares to one beneficiary with stamp duty paid — Executor later requested remaining shares to be registered in names of other beneficiaries without Form 32A or stamp duty — Company refused registration — Whether executor’s assent perfects transmission or separate transfer required — Whether Articles of Association restrict registration of beneficiaries except through proper instrument of transfer — Whether directors may exercise discretion in registration — Whether court may override mandatory requirements of Companies Act 2016 and company Articles — Companies Act 2016 ss 33, 50, 103, 105(1), (4), 109; Probate and Administration Act 1959 s 12. 1 case

Winding up — Inability to pay debts — Statutory demand duly served — Presumption of insolvency under ss. 465(1)(e) and 466(1)(a) Companies Act 2016 — Judgment debt arising from court orders — No bona fide or substantial dispute — Filing of appeal not amounting to stay — Winding-up petition allowed with costs — Civil procedure — Interlocutory application rendered academic by subsequent winding-up order 1 case

Minority Oppression — Allegation of oppressive conduct by Defendants — Whether Plaintiff established a claim for minority oppression under Section 346 of the Companies Act 2016 — Plaintiff removed from management and denied physical access to company premises — Whether such actions constituted oppression — Breakdown of mutual trust and confidence among shareholders — Whether the Plaintiff’s rights as shareholder and director were disregarded — Whether Defendants acted for an improper purpose or breached fiduciary duties — Sufficiency of evidence to support claim of oppressive conduct — Applicability and scope of Section 346 of the Companies Act 2016. 1 case

Winding up — Liquidator — Whether leave of the winding-up court is required to commence proceedings against a court-appointed liquidator — Whether the applicant established a prima facie case or demonstrated pecuniary loss to the company in various allegations — Whether allegations warrants the court intervention in the liquidation process. 1 case

Appeal — Oppression — Purchase of shares of minority shareholder — Whether petitioner’s gross delay in filing ‘oppression petition’ inexcusable and fatal — Whether in the circumstances of this case, the Applicant’s only remedy lay in a derivative action in the name of the 1st Respondent Company to the exclusion of any remedy for minority oppression — Whether in the circumstances of this case, the reflective loss principle had any application — Companies Act 1965 [Act 125], section 181 1 case

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