Use It For
Use this as the classic information-rights case before moving to the 2023 Company Law’s express inclusion of accounting vouchers and subsidiary materials.
Brief English Introduction
The case treats accounting books and vouchers as central to meaningful shareholder inspection. A company cannot refuse inspection merely by speculating that the shareholder has another dispute-related motive.
Teaching Notes
This is a good case for asking students what evidence a company should need before invoking the improper-purpose defense.