Gazette Case: Pre-emption Bars Performance but Not Contract Validity

Gazette Case: Beijing Xin'ate Group Co., Ltd. v. China Huarong Asset Management Co.

The lawful exercise of another shareholder's pre-emption right in a limited liability company does not automatically invalidate the share transfer contract between the transferor and the outside transferee. Courts should distinguish the validity of the contract from the effectiveness of the share transfer itself, and where the contract remains valid, the transferee may still claim damages for non-performance.

Holding

The lawful exercise of another shareholder's pre-emption right in a limited liability company does not automatically invalidate the share transfer contract between the transferor and the outside transferee. Courts should distinguish the validity of the contract from the effectiveness of the share transfer itself, and where the contract remains valid, the transferee may still claim damages for non-performance.

Issues

shareholder pre-emption rightsvalidity of the share transfer contractdamages after supervening impossibility of performance