'Provisions in a company's articles provide little protection for minority shareholders. Such provisions are rarely enforceable, and too vulnerable to alteration by the majority.' Discuss. The answer must focus on you to use Section 33 CA 2006 and case law interpreting s.33, for example, Foss v Harbottle; Hickman v Kent; Pender v Lushington; Rayfield v Hands; Eley v Positive Government Security Life Assurance; Beattie v E and F Beattie, Salmon v Quin & Axtens. Academic commentary thereon, for example by Wedderburn, Baxter. On alteration: s.21 CA 2006 and relevant cases such as Allen v Gold Reefs, Greenhalgh v Arderne Cinemas. Academic commentary thereon, for example by Wedderburn, Baxter. On alteration: s.21 CA 2006 and relevant cases such as Allen v Gold Reefs, Greenhalgh v Arderne Cinemas. Mention the articles, their enforcement under s.33, or their alteration under s.21. A good answer would explore the judicial construction and application of this test, through the relevant case law. It is generally applied as a subjective test, and the requirement of 'benefit of the company as a whole seems to come down to a rather easily satisfied requirement to avoid discrimination against the minority, well-advised minorities to prevent future alteration through the use of 'provisions for entrenchment' under s.22 CA 2006 or the creation of 'class rights.