What is the effect of the Foss v Harbottle rule on shareholder litigation?

The policy grounds underlying the rule include the avoidance of a multiplicity of actions. This policy was described by Mr. Justice McKenzie in Rogers (S.C.) as follows at p. 87: It has been stated many times that the rule in Foss v. Harbottle was designed to eliminate the possibility of multiple or futile litigation. I quote from Gower’s Principles of Modern Company Law, 4th ed. (1979), p. 642: The fact is that the courts have ceased to be moved by pure questions of principle but have instead given weight to the practical advantages of the Foss v. Harbottle rule. And these practical advantages are: (a) insistence on action by the company itself prevents multiplicity of suits. If each shareholder were permitted to sue, the company might be harassed by a succession of actions started and discounted by innumerable plaintiffs. (b) if the irregularity complained of is one which can be effectively ratified by the general meeting it is futile to have litigation about it except with consent of the general meeting.