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Representative action:
Where individual shareholders have suffered personal loss in addition to the injury to the company one shareholder may bring a representative action on behalf of himself and all the other shareholders who have suffered similar injury. If the action is successful the plaintiff will obtain a declaration that the improper conduct has been proved. Each injured party may then claim damages without further need to prove improper conduct.
An example is Hogg v Cramphorn (1966)
Personal rights invaded: A shareholder may sue to protect from invasion their own individual rights as members. This is illustrated by Pender v Lushington
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