Sections 459-461 of the Companies Act 1985 aim to protect minority shareholders from being mistreated by controlling shareholders. Recent court decisions, like Clark v. Cutland, have clarified the scope of these sections. The Clark v. Cutland case has made it easier for minority shareholders to use section 459 as an alternative to derivative actions for seeking remedies. This means that minority shareholders now have a more flexible and practical way to address issues within their company.