[1] Albert Camus famously said "Democracy is not the law of the majority, but the protection of the minority." Much like sovereign democracy, shareholder democracy is also bound by one of the bulwarks of corporate law - majority rule, which enforces the will of the majority over and above individual shareholder interests. While this rule promotes efficiency, instances of abuse recur. The tyranny of the majority has often overridden the valid grievances of the minority. But company law has intervened through statute to ensure that the behaviour of the majority does not result in oppression or unduly prejudicial results adversely affecting the interests of the minority. One of these statutory interventions is captured in s 181 of the Companies Act 1965 , now s 346 of the Companies Act 2016 .