How comparative laws of foreign jurisdictions may be used by South African courts to find the fair value of shares when shareholders use the appraisal remedy provided for in s 164 of the South African Companies Act 71 of 2008
A set method of determination of the fair value of shares is omitted from s164 of the South African Companies Act 71 of 2008 (the South African Act), which deals with the appraisal remedies of dissenting shareholders. This dissertation will consider how courts in the United Kingdom and the United States have dealt with the question of what is fair value in the context of oppression remedies and appraisal rights
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