A sole shareholder can in principle be a victim of oppressive conduct under s 232, because the norms of conduct prescribed by that section have a wholly objective content independent of the identity and will of the shareholders. However, consolidated group profits do not demonstrate the dividend-paying capacity of individual subsidiaries, and an applicant for derivative action leave must show evidence of individual company profitability. The 'best interests' test in s 237(2)(c) is assessed by reference to the particular putative plaintiff company, not the group as a whole. Derivative actions pursued as a pressure tactic to achieve a collateral purpose (such as forcing a share buy-out) will fail the good faith requirement.
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