Merryweather (1867) LR 5 EQ 464n, per Page Wood VC Gambotto v WCP Limited (1995) 182 CLR 432 (Aus) Daniels v Daniels (1978) fraud in the context of derivative action means abuse of power whereby the directors or majority, who are in control of the company, secure a benefit at the expense of the company ...and see Greenhalgh v Arderne Cinemas Ltd for an example of what was not a fraud on the minority See also UK company law References 1843 in case law United Kingdom company case law 1843 in British law Court of Chancery cases