When may a shareholder request an investigation pursuant to the Business Corporations Act (CQLR, c. S-31.1)? The Quebec Court of Appeal recently considered the analytical framework developed by the courts to determine the merits of such an application, whether requested as a stand-alone remedy or in the larger context of an oppression remedy. As the Court's decision in Abandonato v. Corporation Steckmar, 2022 QCCA 1405 demonstrates, obtaining that such an investigation be ordered is often difficult, and the involvement of nominee corporations in the company’s business model can complicate matters even further.

Our colleagues Joël Larouche and Marianne Paquet analyze the Court of Appeal’s decision in an article available here: EYB2023REP3579 (in French)