Upon a finding of oppression in a quasi-partnership company, the court's discretion to fix a fair price for compulsory purchase of shares is not confined to the company's past remuneration or distribution practices. Where authorised representatives were paid above-industry rates, the court may adjust remuneration to the industry standard for the purpose of calculating future maintainable earnings, as failing to do so would reward the oppressors and deprive the oppressed shareholder of the value of their partnership share. Section 232(e) permits the court to take into account benefits derived by an individual through directorship when valuing shares held by that individual's family trust.
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