Land Surveys Pty Ltd as Trustee for the P Rullo Family Trust v Pg Rocket Holdings Pty Ltd

[2026] WASC 304

Supreme Court of Western Australia

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For Australian Law.

1. Corporations
1. Oppression action
1. Interlocutory Injunction
1. Injunction sought to prevent a majority shareholder from engaging in oppressive conduct though the directors it nominated to the board of the company pending determination of an oppression claim by the minority shareholder

An interlocutory injunction in an oppression proceeding under CA s 232 requires identification of specific proposed conduct for which there is a prima facie case of oppression; a prophylactic regime giving minority shareholders a general veto over categories of future board decisions, not tied to identified oppressive acts, lacks jurisprudential foundation under CA s 1324(1).
Where the final relief sought is a share buy-out under CA s 233(1)(e), the court's power to value shares on the basis that oppressive conduct had not occurred means that diminution in share value caused by impugned decisions can be reversed out at trial, weighing against a finding that economic compensation is inadequate.
An internal delegation of authority policy not shown to have been approved by the board cannot serve as the foundation for interlocutory restraints said to preserve the 'board-approved status quo'.

Citation[2026] WASC 304

CourtWASC

JurisdictionWestern Australia

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