The foundational Indian application of the Salomon principle — a shareholder owns shares, not the company's property, and the agricultural character of a tea company's income does not pass through to dividends in the shareholder's hands.
A three-judge bench laid down a strict, impropriety-based six-fold test for piercing the corporate veil, holding that canteen workers engaged through a wholly-owned subsidiary were not workmen of the parent company.
A five-judge Constitution Bench delivered a foundational statement on separate corporate personality, the narrow grounds for lifting the corporate veil, and the shareholder's right to requisition a meeting irrespective of motive.