10 The derivative action as an exception to Foss v Harbottle, and the delicate balance struck in early 20 th century case law starting with Allen v Gold Reefs, which will be discussed in detail shortly. 11 The unfair prejudice petition in the Companies Act 1985, superseding the little-used and stringent oppression action in the previous Companies Act 1948. 12 The rise in the supervision of financial market intermediaries and activity under the Financial Services Act 1986 which established the Securities and Investments Board.