Global Gaming Ventures (Group) Ltd & Anor v Global Gaming Ventures (Holdings) Ltd & Anor

Global Gaming Ventures (Group) Ltd & Anor v Global Gaming Ventures (Holdings) Ltd & Anor

The appellants were entitled to disclosure of the Requested Documents under clause 5.1 of the Shareholders Agreement and as a director of Holdings; the judge erred in treating the request as subject to a requirement of reasonableness and in finding improper purpose; the urgency and nature of the relief required consideration of the strength of the claim, which was strong.

Parties
Claimant/appellant: Global Gaming Ventures (Group) Limited; Claimant/appellant: Anthony Stephen Wollenberg; Defendant/respondent: Global Gaming Ventures (Holdings) Limited; Defendant/respondent: Andrew William Herd
Jurisdiction
England and Wales
Judgment Date
30 January 2018
Procedural Posture
Civil Appeal / Appeal From High Court Decision on Interim Mandatory Disclosure Order
Outcome
Appeal allowed
Legal Topics
Directors' Rights of Inspection, Shareholder Information Rights, Interim Mandatory Injunctions, Disclosure Obligations Under Shareholders' Agreements

Case Brief

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Parties

Global Gaming Ventures (Group) Limited

Claimant/appellant

Anthony Stephen Wollenberg

Claimant/appellant

Global Gaming Ventures (Holdings) Limited

Defendant/respondent

Andrew William Herd

Defendant/respondent

Procedural Posture

Civil Appeal / Appeal From High Court Decision on Interim Mandatory Disclosure Order

  1. 1 Whether the appellants are entitled to disclosure of documents and information under clause 5.1 of the Shareholders Agreement
  2. 2 Whether a director's right of inspection extends to all company records for a proper purpose
  3. 3 Whether disclosure was sought for an improper purpose

Ratio Decidendi

The appellants were entitled to disclosure of the Requested Documents under clause 5.1 of the Shareholders Agreement and as a director of Holdings; the judge erred in treating the request as subject to a requirement of reasonableness and in finding improper purpose; the urgency and nature of the relief required consideration of the strength of the claim, which was strong.

Court Disposition

Appeal allowed

Orders

  • Disclosure of the Requested Documents to the appellants