to alter articles to allow 90% shareholder to acquire shares of minority
Court refused to regard the ‘bona fide in the interests of the company’ test as
nor did court wish to leave issue to majority rule, coupled with requirement of
good faith on majority.
substituted objective ‘proper purposes’ test.
of shares could be allowed to save company from ‘significant detriment or
not allowed simply for purpose of advancing interests of company or majority of
test seemed almost entirely, if not wholly, objective.