Relief under Section 181 of the Companies Act necessitates demonstrating oppression impacting shareholders in their capacity as members, not as directors.

Headnote:(A) Companies Act 1965 - Section 181 - Petition for oppression - Application to strike out several prayers was made, seeking to cancel resolutions and orders against directors - Court held that remedies under s. 181 must show oppression in a member's capacity as a member, not as a director.

(B) Prayer (a) for cancellation of removal of a Managing Director struck out;

(C) Prayers (b)(i) and (ii) regarding project ownership struck out as related to civil disputes;

(D) Prayer (c) prohibiting Managing Director's functions struck out; (E) Prayer (d) for damages ordered to be amended for basis connection; (F) Prayer (e) for Receiver and Manager struck out; (G) Prayer (f) for accounting not struck out as potential oppression unclear. (Paras 1-20)

Facts of the case:
The petitioners sought relief against alleged oppression as shareholders, challenging various decisions affecting management and projects of the company.

Findings of Court:
The court determined that grievances predominantly affected the petitioners in their executive roles rather than as members, hence relief under the Companies Act was limited.

Issues: Whether alleged management grievances constituted oppression impacting shareholders as members.

Ratio Decidendi: The court emphasized that a complaint must demonstrate oppression in the capacity of a member for relief under s. 181 of the Act, reaffirming that management disputes are not actionable.

Result: The application to strike out several prayers was granted except for the amendment of prayer (d) and denial of striking out prayer (f).

KHOR LYE HOCK & ANOR vs MAKASSAR ENGINEERING & CONSTRUCTION SDN BHD & ORS - 2010 MarsdenLR 2932