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This paper adopts the comparative approach in its bid to compare the exceptions to the rule in Foss v Harbottle1 under the statutory provisions of the UK Companies Act 2006 (CA 2006), and Ghana’s Companies Act 1963 (Act 179). The rationale is to critically examine the differences and commonalities of the Companies Acts of both the UK and Ghana. The article argues that minority shareholders in Ghana are given more protection in terms of the avenues opened to them to bring actions against the company or the controlling majority shareholders as compared to what pertains in the United Kingdom.

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A Comparison of the Statutory Provisions of the United Kingdom (UK) Companies Act 2006 and Ghana’s Companies Act 1963 (Act 179), to the Rule in Foss v Harbottle