The case confirms that advancing unsecured interest-free loans to a controlling shareholder without notice to a minority director-shareholder, where the loan is unrelated to the company's business and devoid of commercial benefit, constitutes oppressive conduct under s 232 of the Corporations Act. It also confirms that using company funds to pay the majority's legal costs in defending oppression proceedings is oppressive, and that subsequent reimbursement does not negate the oppression. Section 198F does not extend to inspection of documents for proceedings brought in a member's capacity rather than a director's capacity. A winding up order may be appropriate relief where the company is no longer a going concern.
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