Personal rights invaded:
A shareholder may sue to protect from invasion their own individual rights as members. This is illustrated by Pender v Lushington (101)
Fraud on a minority and the wrongdoers are in control of the company
"It has been further pointed out that where what has been done amounts to what is generally called in these cases a fraud on the minority and wrongdoers are themselves in control of the company, the rule is comfortable in favor of the aggrieved minority who are allowed to bring what is recognized as a minority shareholders' action on behalf of themselves and all others. The reason for this is like as, whether they were denied that right, their grievances could never reach the court because the wrongdoers themselves, being in control, and then would not allow the company to sue," (per Jenkins, L.J.)