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30. In a decision of the Court of Appeal in Jermyn Street Turkish Baths Ltd., In re [1971] 3 All ER 184; [1971] 41 Comp Cas 999, where the question arose whether directors having majority voting power and drawing high remuneration for themselves without the consent of the company in general meeting, were conducting the affairs of the company in a manner oppressive to the minority shareholders, Buckley J., speaking for the court, thus explained the position (page 1020 of 41 Comp Cas) :

"In our judgment, oppression occurs when shareholders, having a dominant power in a company, either (1) exercise that power to procure that something is done or not done in the conduct of the company's affairs or (2) procure by an express or implicit threat of an exercise of that power that something is not done in the conduct of the company's affairs; and when such conduct is unfair or, to use the expression adopted by Viscount Simonds in Scottish Co-operative Wholesale Society Ltd. v. Meyer [1959] 29 Comp Cas 1 (HL); [1959] AC 324 'burdensome, harsh and wrongful' to the other members of the company or some of them, and lacks that degree of probity which they are entitled to expect in the conduct of the company's affairs. See also H. R. Hanner Ltd., In re [1959] 29 Comp Cas 305 (CA). We do not say that this is necessarily a comprehensive definition of the meaning of the word 'oppressive' in section 210, for the affairs of life are so diverse that it is dangerous to attempt a universal definition. We think, however, that it may serve as a sufficient definition for the present purpose. Oppression must, we think, import that the oppressed are being constrained to submit to something which is unfair to them as the result of some overbearing act or attitude on the part of the oppressor. If a director of a company were to draw remuneration to which he was not legally entitled or in excess of the remuneration to which he was legally entitled, this might no doubt found misfeasance proceedings or proceedings for some other kinds of relief, but it would not by itself amount to oppression. Nor would the fact that the director was a majority shareholder in the company make any difference unless he had used his majority voting powers to procure or retain the remuneration or to stifle proceedings by the company or other shareholders in relation to it."