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This indepth comparative examination of the derivative action in Asia provides a framework for analyzing its function, history and practical application and examines in detail how derivative actions law works in practice in seven important Asian jurisdictions (China, Hong Kong, India, Japan, Korea, Taiwan and Singapore). These case studies allow an evaluation of a number of the leading Western comparative corporate law and governance theories which have come to define the field over the last decade. By debunking some of these critically important theories, this book lays the foundation for an accurate understanding of the derivative action in Asia and a reexamination of the regulation of the derivative action around the world.
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birth defects, or other reproductive harm.
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