On a compulsory purchase order for oppression, shares should be valued at current value without minority discount where the minority position resulted from oppressive conduct, and the valuation must exclude the depreciating effect of the oppressive conduct. Winding up of a solvent company should be ordered only as a last resort where a compulsory purchase order is available. Where a director breaches fiduciary duty by acting for an improper purpose, the Brickenden principle precludes the director from arguing that profits would have been derived irrespective of the improper purpose, but equitable compensation is not available where the loss would have occurred irrespective of the breach. A third party company that receives benefits with full knowledge that they derive from a fiduciary's breach of duty is liable to account for those profits.
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