Singapore
HOU CHAO (In his personal capacity and also in his representative capacity on behalf of Yong Zhen Yuan Pte. Ltd.) v GU XIAOLAN & 2 Ors
A common law derivative action requires the plaintiff to demonstrate a prima facie case of wrongdoing and locus standi under the 'fraud on the minority' exception. The court retains discretion to deny leave if the action is not in the company's best interests or is an abuse of pr