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In *R.C. Cooper v. Union of India* (also known as the Bank Nationalisation case), the Supreme Court ruled on the test for determining whether a shareholder's right is impaired. What was the holding?

Answer & Solution
Correct answer: D.
1. In **R.C. Cooper v. Union of India, AIR 1970 SC 564** (the Bank Nationalisation case), the Supreme Court significantly modified its earlier view that a company is a distinct entity from its shareholders so far as fundamental rights are concerned. 2. The Court held that the **test for determining whether the shareholder's right is impaired is not formal but essentially qualitative**. 3. Where the State action impairs the rights of the shareholders as well as of the company, the Court will not deny itself jurisdiction to grant relief merely because the company has a separate legal personality. 4. *Bennett Coleman & Co.* (AIR 1973 SC 106) extended this — the shareholders' rights are equally affected if the rights of the company are affected. _Source: ICSI CS Executive — Lesson 2, 'Corporations' under Article 19 discussion, p. 41._
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