Riverfront Nominees Pty Ltd v Beacon Minerals Ltd

In this case, Riverfront Nominees Pty Ltd sought an interlocutory injunction against Beacon Minerals Ltd, asserting breaches of directors' duties by the latter. The dispute arose in the Federal Court of Australia, where Riverfront, a shareholder in Beacon, alleged that Beacon's directors acted contrary to their statutory obligations under the Corporations Act 2001 (Cth). Riverfront claimed that Beacon's directors used a pre-completed proxy form to secure votes at a general meeting, which Riverfront argued was improper and prejudicial to minority shareholders.

The court was required to determine whether Beacon's directors had indeed breached their duties and whether such breaches warranted an interlocutory injunction. The central issue was whether the use of pre-completed proxy forms was permissible under the Corporations Act and, if not, whether an injunction should be granted to prevent further breaches. The court needed to balance the potential harm to Riverfront if the injunction was not granted against any prejudice that might be suffered by Beacon if the injunction was granted.

The court found that Beacon's directors had indeed breached their duties by using pre-completed proxy forms. The court considered that such actions undermined the principles of informed decision-making and equal treatment of shareholders. The court concluded that Riverfront had established a serious question to be tried and that the balance of convenience favoured the grant of an interlocutory injunction. The court issued an injunction to restrain Beacon from using pre-completed proxy forms in the future.