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Oppression claim failed where appellant sought removal as shareholder.
The appellant sought an oppression remedy under s. 241 of the Canada Business Corporations Act after being removed from the corporation’s share register.
The appeal turned on whether he had a reasonable expectation of continued shareholder treatment and whether non-compliance with statutory transfer formalities, in these facts, constituted oppressive conduct.
The majority held the trial findings established that the appellant had asked to cease being a shareholder, so the alleged expectation was not reasonable and the oppression claim failed.
The Court confirmed that statutory non-compliance alone does not automatically establish oppression absent frustration of reasonable expectations.
