Prevention of Oppression and Mismanagement – CA Final Law Study Material

Prevention of Oppression and Mismanagement – CA Final Law Study Material is designed strictly as per the latest syllabus and exam pattern.

Prevention of Oppression and Mismanagement – CA Final Law Study Material

Question 1.
State the conditions which must be satisfied before filing an application for the prevention of oppression.
Answer:
Conditions to be satisfied before filing an application for prevention of oppression:
The conditions which are required to be satisfied before filing an application for the prevention of oppression can be enumerated as follows:
(i) Required number of members: As per Sec. 244 of Companies Act, 2013, in the case of a company having a share capital, not less than 100 members of the company or not less than 1/10th of the total number of its members, whichever is less, or any member or members holding not less than 1/10th of the issued share capital of the company, subject to the condition that the applicant or applicants has or have paid all calls and other sums due on his or their shares, shall have the right to apply u/s 241.
In case of a company not having share capital, atleast 1/5th of the total number of its members can apply for relief.

(ii) Complaints against which application may be made by members to Tribunal:
Any member of a company may apply to Tribunal, if he complains that –

(a) the affairs of the company have been or are being conducted in a manner prejudicial to public interest or prejudicial or oppressive to him or any other member or members or prejudicial to the interests of the company; or

(b) the material change has taken place in the management or control of the company, whether by an alteration in the Board of Directors, or manager, or in the ownership of the company’s shares, or if it has no share capital, in its membership, or in any other manner whatsoever, and that by reason of such change, it is likely that the affairs of the company will be conducted in a manner prejudicial to its interests or its members or any class of members.

Question 2.
The profits of ABC Limited for the financial year 2019-2020 fell considerably due to recession. The Board of directors of the company, therefore, bona fide did not recommend any dividend for the year. At the Annual General Meeting of the company, a group of members objected to the Board’s decision and wanted the Board to make recommendation for dividend.

On refusal by the Board, the members, who feel oppressed by the Board’s decision to skip the dividend, move to the Tribunal and complain against the Board on the ground of oppression and mismanagement.
Examining the provisions of the Companies Act, 2013, decide:
(a) Whether the members contention shall be tenable?
(b) Whether the act of Board of Directors not to recommend any dividend shall amount to oppression and mismanagement?
Answer:
Oppression and Mismanagement:

Terms Oppression and Mismanagement has not been defined under the Company law.
Oppression involves an element of lack of fair dealing to the member of his propriety rights as shareholder.
Oppression does not include mere domestic disputes between directors and members, or lack of confidence between one set of members and others.
Bona fide decisions consistent with the company’s memorandum and articles are not to be equated with mismanagement even if they turn out to be wrong in the circumstances or these cause temporary losses.
Directors’ bona fide decision not to declare dividend and to accumulate available profits into reserves is not mismanagement. (Thomas Vettom (V.J.) v. Kuttanad Rubber Co. Ltd.)
In the present case, due to fall in profits, Board of directors of the company, did not recommend any dividend for the year. At the AGM of the company, a group of members objected to the Board’s decision and wanted the Board to make recommendation for dividend.
On refusal by the Board, the members, who feel oppressed by the Board’s decision to skip the dividend, move to the Company Law Board and complain against the Board on the ground of oppression and mismanagement.

Conclusion:
(a) Contention of members shall not be tenable.
(b) The act of the Board of directors who acted bonafide, not to recommend any dividend shall not amount to oppression or mismanagement.

Question 3.
A group of shareholders holding 20% of the issued share capital of DEF Limited have filed a petition before the Tribunal alleging the following:
(i) Various acts of illegal, invalid and irregular transactions entered into the name of the company.
(ii) Losses Incurred due to mismanagement by the board of directors.
(iii) Non-declaration of dividend despite having sufficient profits In the past years.
Examine the merits of the above petitions made under section 241 of the Companies Act 2013 in the light of the judicial pronouncements made in this regard. [May 17(4 Marks)]
Answer:
Oppression and Mismanagement:

As per Sec. 244 of the Companies Act, 2013, in the case of a company having a share capital. not less than loo members of the company or not less than 1/10th of the total number of its members, whichever is less, or any member or members holding not less than 1/10th of the issúed share capital of the company, subject to the condition that the applicant or applicants has or have paid all calls and other sums due on his or their shares, shall have the right to apply u/s 241.

In the instant case, group holds 2O°/f the issued share capital, hence, they are entitled to file a petition before the Tribunal u/s 241 of the Companies Act, 2013.

Validity of Grounds on which petition is being filed:

(i) Mere illegal, invalid or irregular transactions entèred into in the name of the company do not constitute a ground for invoking the provisions óf section 241 unless it is proved that they are oppressive to any shareholder or prejudicial to the interest of the company or to the public interest. (Sheth Mohanlal Ganpatram v. Shri Sayaji jubilee Cotton and jute Mills Company Ltd.)

(ii) Losses incurred due to mismanagement by the board of directors, cannot, by itself, be regarded as oppression (Ashok Betelnut Co. R Ltd. y. M.L Chandrakanth).

(iii) Directors’ bonaJìde decision not to declare dividend and to accumulate available profits into reserves is not mismanagement. (Thomas Vettom (VI.) y. Kuttanad Rubber Co. Ltd.).

Conclusion: Petition filed by the group of shareholders will fail unless they can prove to the satisfaction of the Tribunal that the acts complained of in the petition are oppressive and prejudicial to the interest of the company and the public interest.

Question 4.
What is meant by oppression? State whether the aggrieved party would succeed in obtaining relief from Tribunal on the ground of oppression in the following cases:
(a) The majority of the Board of directors override the minority directors and the minority directors apply to Tribunal complaining oppression by majority directors.
(b) A petition by majority shareholders complaining oppression by minority shareholders. Give your answer according to the provisions of the Companies Act, 2013.
Answer:
Meaning of Oppression:

Term Oppression has not been defined under the Company law. Oppression involves an element of lack of fair dealing to the member of his propriety rights as shareholder.

Oppression does not include mere domestic disputes between directors and members, or lack of confidence between one set of members and others. It was observed in Rao (V.M.) v. Rajeshwari Ramakrishnan that the oppression complained off must affect a person in his capacity as a member of the company; harsh or unfair treatment in other capacity, e.g., as a director or a creditor is outside the purview of this chapter.

There must be a continuous act constituting oppression up to the date of the petition. The events have to be considered not in isolation but as a part of a continuous suffering.

(i) Oppression of a member as a director: Oppression dealt with by Sec. 241 of the Companies Act, 2013, is only oppression of members in their character as such. The harsh treatment, for instance, of a member who is a director or other officer or employee, by the Board of directors or management does not come within Sec. 241.
Conclusion: The minority directors will not succeed in getting relief from Tribunal on the ground of oppression.

(ii) ’Right not confined to minority: As per Sec. 244, the right to apply for relief u/s 241/242 is given to 100 members or 1/10th of the total number of members or any member or members holding not less than 1/10th of the issued share capital of the company. There is nothing in this section which suggests even indirectly that unless the application is made by minority shareholders it is not maintainable. The right to apply is, therefore, not confined to oppressed minority of the shareholders alone.

Question 5.
ABC Private Limited is a company in which there are eight shareholders. Can a member holding less than one-tenth of the share capital of the company apply to the Tribunal for relief against oppression and mismanagement? Give your answer according to the provisions of the Companies Act, 2013.
Answer:
Members right to apply for relief against oppression and mismanagement:

As per Sec. 244 of Companies Act, 2013, in the case of a company having a share capital, not less than 100 members of the company or not less than 1/10th of the total number of its members, whichever is less, or any member or members holding not less than 1/10th of the issued share capital of the company, subject to the condition that the applicant or applicants has or have paid all calls and other sums due on his or their shares, shall have the right to apply u/s 241.

In the given case, there are eight shareholders. As per above conditions, 10% of 8 i.e. 1 member can present a petition to the Tribunal, regardless of the fact that he holds less than 1/10th of the company’s share capital.
Conclusion: A single member can apply for relief against oppression and mismanagement.

Question 6.
The issued and paid up capital of MNC Limited is ₹ 5 crores consisting of 5,00,000 equity shares of ₹ 100 each. The said company has 500 members. A petition was submitted before the Tribunal signed by 80 members holding 10,000 equity shares of the company for the purpose of relief against oppression and mismanagement by the majority shareholders.
Examining the provisions of the Companies Act, 2013, decide whether the said petition is maintainable. Also explain the impact on the maintainability of the above petition, if subsequently 40 members, who had signed the petition, withdrew their consent. [MTP-April 18, RTP-May 18, MTP – March 19]
Answer:
Validity of Petition filed for relief against oppression and mismanagement:

As per Sec. 244 of Companies Act, 2 013, in the case of a company having a share capital, not less than 100 members of the company or not less than 1/10th of the total number of its members, whichever is less, or any member or members holding not less than 1/10th of the issued share capital of the company, subject to the condition that the applicant or applicants has or have paid all calls and other sums due on his or their shares, shall have the right to apply u/s 241.

In the present case, petition was signed by 80 members out of 500 members. Group of Applicant hold 10,000 shares out of 5,00,000 shares.

Conclusion: Petition made by 80 members meets the eligibility criteria specified u/s 244 of the Companies Act, 2013 as group of applicants consist of 80 members which is more than 1/10th of total 500 members. Therefore, the petition is maintainable.

Impact of subsequent withdrawal of consent: It has been held by the Supreme Court in Rajmimdhry Electric Corporation v. V. NageswarRao, that if some of the consenting members have subsequent to the presentation of the petition withdraw their consent, it would not affect the right of the applicant to proceed with the petition. Hence petition remains maintainable.

Question 7.
A group of members of XYZ Limited has filed a petition before the Tribunal alleging various acts of oppression and mismanagement by the majority shareholders of the company. The Petitioner group holds 12% of the issued share capital of the company.

During the pendency of the petition, some of the petitioner group holding about 5% of the issued share capital of the company wish to disassociate themselves from the petition and they along with the other majority shareholders have submitted before the Tribunal that the petition may be dismissed on the ground of non- maintainability. Examine their contention having regard to the provisions of the Companies Act, 2013. [MTP-May 20]
Answer:
Dismissal of petition on grounds of non-maintainability:

As per Sec. 244 of Companies Act, 2013, in the case of a company having a share capital, not less than 100 members of the company or not less than l/10th of the total number of its members, whichever is less, or any member or members holding not less than 1 /10th of the issued share capital of the company, subject to the condition that the applicant or applicants has or have paid all calls and other sums due on his or their shares, shall have the right to apply u/s 241.

It has been held by the Supreme Court in Rajmimdhry Electric Corporation v. V. Nageswar Rao, that if some of the consenting members have subsequent to the presentation of the petition withdraw their consent, it would not affect the right of the applicant to proceed with the petition.

Conclusion: Petition is maintainable as it is signed by requisite number of members. Subsequent withdrawal will not have any impact.

Question 8.
M/s DJ Limited, a listed company, as per the audited financial statements as at March 31, 2018 is having issued and paid-up equity share capital comprising of 10 lakhs share of ₹ 10 each and issued and paid-up preference share capital of 5 lakhs share of ₹ 10 each respectively. The members of the company after complying with the provisions of Sec. 169 of the Companies Act, 2013 removed one Mr. Satish from the directorship of the company on 1st August 2018 before the completion of his term of office.

Mr. Satish is also one of the members of the company holding 110000 fully paid-up equity shares. Mr. Satish has alleged oppression on his removal and has moved the jurisdictional Honorable National Company Law Tribunal (NCLT) u/s 241 read with Section 244 of the Companies Act, 2013. The Board of Directors of the company is of the opinion that the application is not maintainable as per the provisions of Section 244 of the Companies Act, 2013 Decide.
Also, state if any other recourse that is available with Mr. Satish under the provisions of the Companies Act, 2013. [Nov. 18 – Old Syllabus (4 Marks), KTP-May 19]
Answer:
Validity of Petition filed for relief against oppression and mismanagement:

However, the Tribunal may, on an application made to it in this behalf, waive all or any of the requirements specified above so as to enable the members to apply under section 241.

In the instant case, total issued share capital consists of 15 lakhs shares. The members of the company after complying with the provisions of Sec. 169 of the Companies Act, 2013 removed

one Mr. Satish from the directorship of the company on 1st August 2018 before the completion of his term of office. Mr. Satish is also one of the members of the company holding 110000 fully paid-up equity shares. Mr. Satish has alleged oppression on his removal and has moved the jurisdictional Honorable NCLT u/s 241 read with Section 244 of the Companies Act, 2013.

Share capital of Mr. Satish (1.1 Lakh Shares) is less than 1/10th of total issued share capital (15 Lakh Shares).
Conclusion: Petition is not maintainable as shares held by Mr. Satish is less than 1/10th of issued share capital of the company. However, as per proviso to section 244(1), Mr. Satish may make an application to the Tribunal in this behalf for the waiver of the above condition so that he may apply under section 241.

Question 9.
MNC Private Ltd. is a Company in which there are six shareholders. Mr. Srinath, who is a director and also the legal representative of a deceased shareholder holding less than one tenth of the share capital of the company made a petition to the Tribunal for relief against oppression and mismanagement. Examine under the provisions of the Companies Act, 2013 whether the petition made by Mr. Srinath is valid and maintainable? [Nov. 18 – New Syllabus (3 Marks)]
Answer:
Validity of Petition filed for relief against oppression and mismanagement:

In the present case, application is made by Mr. Srinath, who is a director and also the legal representative of a deceased shareholder holding less than one tenth of the share capital of the company. There are six shareholders. As per above conditions, 10% of 6 i.e. 1 member can present a petition to the Tribunal, regardless of the fact that he holds less than 1/10th of the company’s share capital.

It is also well settled principle that where a member dies and his name being still in the register of members, his legal representatives are entitled to make an application for prevention of oppressional and mismanagement even if their names are not yet entered in the register of members.
Conclusion: Petition made by Mr. Srinath is valid and maintainable.

Question 10.
A group of shareholders consisting of 30 members decide to file a petition before the Tribunal for relief against oppression and mismanagement by the Board of Directors of M/s. Aravalli Manufacturing Company Limited having a paid-up Share Capital of Rs. 1 crore.

The company has a total of 500 members and the group of 30 members holds one-tenth of the total paid-up share capital accounting for one-fifteenth of the issued share capital. The grievance of the group is that due to the mismanagement by the Board of Directors, the company is incurring losses and has not declared any dividend for the past five years. In the light of the provisions of the Companies Act, 2013, please advise the group of shareholders regarding the admission of the petition and relief thereof. [May 19 – New Syllabus (4 Marks)]
Answer:
Validity of Petition filed for relief against oppression and mismanagement:

In the present case, application is being sought by a group of shareholders consisting of 30 members out of 500 members. Group holds one-tenth of the total paid-up share capital accounting for one-fifteenth of the issued share capital.

Conclusion: Since the group of shareholders do not number loo or hold 1/10th of the issued share capital or constitute 1/10th of the total number of members, they have no right to approach the Tribunal for relief.

As regards obtaining relief from Tribunal, continuous losses cannot, by itself, be regarded as oppression. Similarly, failure to declare dividends or payment of low dividends also does not amount to oppression. Thus, the shareholders may not succeed in getting any relief from Tribunal.

Question 11.
Arctic Refrigerators Limited has got 5000 shareholders. Some of the members have decided to file an application under Sec. 241 of the Companies Act, 2013, for oppression and mismanagement. Discuss the qualification of members who have the right to apply to the tribunal.

Due to the fresh Issue of shares, the shareholding of the members who filed the petition gets reduced to below required % of the paid-up share capital. The main contention in the petition is challenging the validity of the Issue. Is the petition maintainable? Mr. Dina, one of the directors also, wants to file an application for oppression and mismanagement. Can he do so? [Nov 20- Old Syllabus (4 Marks))
Answer:
Validity of Petition flied for relief against oppression and mismanagement:

As per Sec. 244 of Companies Act, 2013, in the case of a company having a share capital, not less than loo members of the company or not less than 1/10th of the total number of its members, whichever is less, or any member or members holding not less than 1/10th of the issued share capital of the company, subject to the condition that the applicant or applicants has or have paid all calls and other sums due on his or their shares, shall have the right to apply u/s 241.

It has been held by the Supreme Court in Rajmundhry Electric Corporation vs. V. Nageswar Rao, that if some of the consenting members have subsequent to the presentation of the petition withdraw their consent, it would not affect the right of the applicant to proceed with the petition.

Applying the same principle, if due to the fresh issue of shares, the shareholding of the members who filed the petition gets reduced to below required % of the paid-up share capital, it would not affect the maintainability of the petition.

Filing of Application for relief against oppression by a director: Oppression dealt with by Sec. 241 of the Companies Act, 2013, is only oppression of members in their character as such. The harsh treatment, for instance, of a member who is a director or other officer or employee, by the Board of directors or management does not come within Sec. 241.

Question 12.
ABC limited used the business resources of the company in favour of the majority shareholders and completely excluded the minorities from the affairs of the company. As of consequences, minority members filed an application to Tribunal to look into the matter on the regulation of conduct of affairs of the company in future. State in the light of the Companies Act, 2013, the action to be taken by the Tribunal in the given situation.
Answer:
Action to be taken by Tribunal:
As per Sec. 242 of the Companies Act, 2013, on any application made u/s 241, the Tribunal may, with a view to bring to an end the matters complained of, make such order as it thinks fit, if it is of the opinion:

(a) that the company’s affairs have been or are being conducted in a manner

prejudicial or oppressive to any member or members or
prejudicial to public interest or
prejudicial to the interests of the company;

and

(b) that to wind up the company would unfairly prejudice such member or members, but that otherwise the facts would justify the making of a winding-up order on the ground that it was just and equitable that the company should be wound up.

Interim Order: The Tribunal may, on the application of any party to the proceeding, make any interim order which it thinks fit for regulating the conduct of the company’s affairs upon such terms and conditions as appear to it to be just and equitable.

Question 13.
Mr. B. Dutt is the Managing Director of Food Plaza Restaurants Private Limited (FPRPL). FPRPL was incorporated in furtherance of a Joint Venture Agreement (“JVA”) between Mr. B. Dutt and Jack India Pvt. Limited (JIPL) in 2017, both having 50% of equal share in the said company. FPRPL was to be governed by the terms and conditions set out in its Memorandum of Association and its Articles Dissociation.

During the course, JIPL held the Board meeting, without giving prior notice of such meeting to Mr. B. Dutt, took decision to remove Mr. B Dutt with an allegation of mismanagement of fund in FPRPL.
JIPL pressurised him to sell his shares at ₹ 5 Crores, against ₹ 15 crore which is much below the fair market price of Mr. B. Dutt shares.

Advise whether Mr. B. Dutt has right to claim any relief and would he succeed in obtaining relief from Tribunal on the ground of oppression by JIPL? [MTP-Aug. 18]
Answer:
Member’s right to apply for relief against oppression and mismanagement

In the instant case, Mr. Dutt is managing director and holding 50% equity shares of the company. Other Shareholder (JIPL) held the Board meeting, without giving prior notice of such meeting to Mr. B. Dutt, took decision to remove Mr. B Dutt with an allegation of mismanagement of fund in FPRPL. JIPL pressurised Mr. B Dutt to sell his shares at ₹ 5 Crores, against ₹ 15 crore which is much below the fair market price of Mr. B. Dutt shares.

The act of JIPL to remove Mr. B Dutt, a Managing director from FPRPL and pressurizing him to sell his shares much below the fair market price is an act of oppression. Mr. B Dutt was not given prior notice of board meeting and no chance to disprove the false allegations made against him.

Conclusion: Mr. B Dutt has right to apply to the Tribunal u/s 241.

Tribunal is well within its power u/s 242 to pass appropriate orders as to reappointment of Mr. B Dutt as the Managing director of the company and can also issue orders for the future conduct of the company along with provision of just and equitable relief to the applicant.

Question 14.
M/s Sunshine Oils Limited, a listed company as at 31st March, 2018 as per the audited financial ; statements is having 200 depositors with ₹ 50 Crores of deposit in the company. Out of the total 200 depositors 20 depositors of the company have formed a group and have appointed Mr. Ram (a practicing advocate who is not one of the depositor) as their representative to file an application in the National Company Law Tribunal (NCLT) to bring a Class Action suit against the management and conduct of affairs of the company are being conducted in a manner which is prejudicial to the ‘ interest of the depositors being oppressive.

Will the application of Mr. Ram be admitted by the ‘ Honourable Tribunal. Discuss with reference to the provisions of the Companies Act, 2013? [May 18 – Old Syllabus (4 Marks)]
Answer:
Validity of Application to bring a class action suit:

Sec. 245 (3)of the Companies Act, 2013 prescribes the required number of members or depositors to apply for class action suit. Accordingly, the requisite number of depositors to file an application shall not be less than 100 depositors or not less than such percentage of the total number of depositors as may be prescribed, whichever is less. No such percentage is being prescribed.

The requisite number of depositor or depositors to file an application u/s 245(1) shall be:
(a) 5% of the total number of depositors of the company; or 100 depositors of the company, whichever is less; or
(b) depositor or depositors to whom the company owes 5% of total deposits of the company.

As per Sec. 432, a party to any proceeding or appeal before the Tribunal or Appellate Tribunal as the case may be, may appear in person or authorize one or more Chartered Accountant or Company Secretaries or Cost Accountants’ or legal practitioners or any other person to present his case before the Tribunal or Appellate Tribunal as the case may be.

Sec. 245(10) states that subject to the compliance of this section, an application may be filed or any other action may be taken under this section by any person, group of persons or any association of persons representing the persons affected by any act or omission.

In the instant case, 20 depositors out of 200 depositors have formed a group and have appointed Mr. Ram (a practising Advocate who is not one of the depositors) as their representative to bring a class action suit against the management of the Company.

Conclusion: Application need to be admitted by the Tribunal as it satisfies the eligibility criteria. Mr. Ram can file application on behalf of depositors.

Question 15.
A group of depositors in M/s. Bright Limited, a listed company, appointed Mr. Fair, an advocate as a representative to file an application in the National Company Law Tribunal (NCLT) on the behalf of the depositors to bring a Class Action suit against the management of the company as they are of the opinion that the management and conduct of affairs of the company are being conducted in a manner which is prejudicial to the interest of the depositors being oppressive.

Examine in the given situation, whether the appointment of Mr. Fair is valid as regards to the filling of the application before the Tribunal in the light to the provisions of the Companies Act, 2013? [RTP-Nov. 18]
Answer:
Validity of Application to bring a class action suit:

Sec. 245 (3) of the Companies Act, 2013 prescribes the required number of members or depositors to apply for class action suit. Accordingly, the requisite number of depositors to file an application shall not be less than 100 depositors or not less than such percentage of the total number of depositors as may be prescribed/whichever is less. No such percentage is being prescribed.

As per Sec. 432, a party to any proceeding or appeal before the Tribunal or Appellate Tribunal as the case may be, may appear in person or authorize one or more Chartered Accountant or Company Secretaries or Cost Accountants or legal practitioners or any other person to present his case before the Tribunal or Appellate Tribunal as the case may be.

In the instant case, a group of depositors appointed Mr. Fair an Advocate as their representative to bring a class action suit against the management of the Company.

Conclusion: Appointment of Mr. Fair is valid and application of Mr. Fair who is a representative of depositors, will be admitted by the Hon’ble Tribunal, provided, the requirement of minimum number of members filing the application is fulfilled.

Question 16.
Agroup of members holding 380 lakh issued share capital in Zolo Ltd., a listed public company having total issued share capital of 15,000 lakhs as per latest financial statements alleged that company board of director is conducting an act which is beyond the scope of the articles or memorandum of the company without altering the memorandum or articles of the company. They make application to tribunal (NCLT) to restrain the company from doing such an act. With reference to the provision of Companies Act, 2013 ascertain whether the application will be admitted by tribunal (NCLT). [MTP-Oct. 20]
Answer:
Validity of Application to bring a class action suit:

Sec. 245 of Companies Act, 2013 provides that specified number of member or members, may, if they are of the opinion that the management or conduct of the affairs of the company are being conducted in a manner prejudicial to the interests of the company or its members, file an application before the Tribunal on behalf of the members for seeking an orders, to restrain the company from committing an act which is beyond the scope of or ultra-vires the articles or memorandum of the company.

Requisite number of members to make Application u/s 245(1) for Class Action for members is as prescribed in Rule 84(3) of the NCLT Rules, 2016. Accordingly, in case of a company having a share capital the requisite number of member or members to file an application u/s 245(1) shall be: –
(a) at least 5% of the total number of members of the company; or 100 hundred members of the company, whichever is less; or
(b) In case of a listed company, member or members holding not less than 2% of the issued share capital of the company.

In the given case, members hold 2.53% (380/15000*100) of issued share capital of Zolo Ltd. which is a listed company make application before tribunal (NCLT).

Conclusion: Application can be admitted by NCLT as requirement of number ofmembers holding not less than 2% of issued share capital is complied with.

Prevention of Oppression and Mismanagement – CA Final Law Study Material

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