liquidation of companies – governed by the Companies Ordinance (New Version) (enacted in 1929). The new Companies Law – 1999 left intact the provisions of the Companies Ordinance regarding liquidation of companies and the related issue of charges^[1].
bankruptcy of individuals – governed by the Bankruptcy Ordinance.

Scholars recommend that statutory arrangements regarding liquidation of insolvent companies and the laws relating to individuals’ bankruptcy^[2] will be unified.

1.1 Types of liquidation under Israel law

Reasons for liquidation:

the company’s unstable financial condition – the majority of liquidations
deadlock between the company’s shareholders
the shareholders’ wish to make their investment liquid through dissolving the company^[3].

Israeli law recognizes three types of liquidation:

voluntary liquidation
judicial liquidation
judicially supervised liquidation (virtually not used and therefore not relevant).

2. Voluntary Liquidation

Voluntary liquidation –

occurs outside a court of law and conducted without judicial intervention
pursuant to the shareholders’ resolution - when there are no third parties (e.g., creditors) liable to be injured as a result of the liquidation
is appropriate mainly for the liquidation of solvent companies pursuant to a resolution of the shareholders
where the company has creditors - the creditors take an active part in the liquidation of the company.

Advantage of voluntary liquidation over mandatory judicial liquidation:

the simplicity of the proceeding =
no need to apply to the court in order to commence liquidation - Liquidation commences on the date when the resolution to liquidate is adopted^[4].
the consent of the authorized parties suffices
no temporary administrator is appointed
the official receiver takes no part in such liquidation
During liquidation the liquidator may carry out his work without the court’s involvement
Court intervention possible at the request of the liquidator, of a member or of a creditor^[5] - court decision on any issue arising out of the liquidation or court exercise of any power within mandatory judicial liquidation.

The Ordinance recognizes two types of voluntary liquidation:

voluntary liquidation initiated by the shareholders
voluntary liquidation initiated by the creditors.

2.1 Voluntary liquidation by shareholders’ resolution

The company’s shareholders may adopt a resolution regarding voluntary liquidation of the company, on 3 possible grounds (Section 319(1) of the Ordinance):

(1) the period that has been prescribed by its bylaws for its existence expired, or an event occurred, on the occurrence of which the company must according to a provision in its bylaws be liquidated, and the company in a general meeting resolved, in an ordinary resolution, on voluntary liquidation. Such provisions in bylaws are rare; note that given such provision, there is no automatic liquidation termination w/o action of the company.

A shareholder wishing to compel the company to voluntarily liquidate based on the provision of the bylaws may:

1. File a claim to compel the other shareholders to adopt a resolution to liquidate the company relying on the bylaws as a contractual obligation^[6].

2. Apply to the court to request liquidation of the company on the grounds of justice and equity^[7], i.e. mandatory judicial liquidation.

(2) the company adopted an extraordinary resolution to liquidate due to the fact that because of its liabilities it cannot continue in business - an extraordinary resolution (75% of the present voting members voted in favor of the resolution, and an advance notice as prescribed by the bylaws has been given^[8]. The reason for the requirement of an extraordinary resolution lies in the shortening of the period of advance notice for calling a meeting for the purpose of adopting such resolution, in comparison to a special resolution which by law requires 21 day’s advance notice, whereas regarding an extraordinary resolution - notice prescribed in the bylaws, which is usually shorter^[9], suffices.

(3) Where there are no objective grounds as above for voluntary liquidation, the shareholders may liquidiate by adopting a special resolution to liquidate voluntarily - i.e., a resolution adopted by a special majority of votes) to liquidate – i.e., 75% of those voting voted in favor of voluntary liquidation + 21 day’s advance notice of the meeting^[10].

Requisite majority for voluntary liquidation by the shareholder - of the shareholders present and voting at a meeting, subject to advance notice of the meeting to all the shareholders possessing a right to vote^[11].

2.1.1 The role of the court in adopting a resolution on voluntary liquidation

The court may invalidate a resolution if

· proceedings required for its adoption have not been observed

· such resolution is tainted with fraud or oppression of the minority^[12] - in Israel, the basis for a remedy against the oppression of a minority - section 235 of the Companies Ordinance; the remedy may include prevention of the liquidation of the company – but scholars (Zipora Cohen) object to the minority’s power to prevent liquidation – the controlling shareholders must have the right to liquidate where they do not have an efficient way to terminate their investment in the company^[13].

2.1.2 Voluntary liquidation proceeding

* Commencement of voluntary liquidation – upon the adoption of the resolution to liquidate^[14].

Appointment of Liquidator

Where the company is solvent = a solvency declaration by the company’s board of directors:

the liquidator (or any substitute liquidator) is appointed by the shareholders^[15] (absent a solvency declaration, appointment is invalid), and
the shareholders have the authority to supervise the manner in which the liquidator exercises his powers and they determine the liquidator’s remuneration.
Where a sole liquidator remains out of the several that were appointed, he may not continue liquidation alone, unless explicitly authorized in his letter of appointment.
Where two or more liquidators remain out of the several that were appointed, they may continue their activity^[16].
judicial intervention in the process of voluntary liquidation possible at the request of the liquidator, of any member or creditor who applies to the court (under section 335 of the Companies Ordinance) to decide on any matter arising out of the liquidation or to the exercise by the court of any of the powers granted to it in the framework of judicial liquidation – including enforcing payment demands.

Liquidator’s obligation upon termination of liquidation:

draw a report on the conduct of liquidation and the disposal of the company’s assets
call a final meeting of the shareholders in which the report would be explained^[17].
send a copy of the report to the Companies Registrar of the conduct of such meeting, within one week thereof.

Dissolution of the company

The process of liquidation is completed with the dissolution of the company.
The company is deemed to be dissolved within 3 months after the liquidator’s final report to the Registrar and the notice of the final meeting^[18].
The court is authorized based on the application of the liquidator or of any other interested person to postpone the date of the dissolution to another date.

2.2 Voluntary liquidation initiated by creditors

Voluntary liquidation

where the directors provided a declaration of solvency – liquidation initiated by the shareholders
where the company’s directors have not provided a declaration of solvency - liquidation will be deemed to be liquidation by the creditors, to give them control.

2.2.1 Voluntary liquidation where an application to liquidate has been filed

Once a creditor filed an application to the court to liquidate the company:

the company cannot resolve upon its voluntary liquidation without judicial approval, which will be granted if the court is satisfied that the court that voluntary liquidation is preferable
the court will not allow voluntary liquidation absent any advantage to the creditors or to the shareholders in voluntary liquidation, regardless of whether the resolution to liquidate was adopted prior to the application for mandatory liquidation of the company or subsequent to such application^[19].

2.2.2 Creditors’ control over the liquidation proceedings

The creditors’ control over voluntary liquidation is reflected in:

their right to appoint a liquidator (or any substitute liquidator^[20]) on their behalf, and their liquidator will be preferred to that appointed by the shareholders^[21]. Any director, member of the company or creditor, may request the court to appoint the company’s candidate or any other person as liquidator in lieu of the candidate of the creditors or together with him, within seven days of the date when the creditors’ candidate is proposed^[22].
the company is obligated to call a creditors’ meeting on the same date as the shareholders’ meeting or on the following day^[23], where the directors must submit a full report regarding the state of the company’s affairs, with a list of its creditors and an estimate of their claims, and where one of the directors must preside^[24].

(a) the appointment of the audit committee by the creditors - Section 326(a) of the Companies Ordinance - as Section 326(a) provides, creditors may appoint up to five members

(b) the creditors may disqualify the company-appointed (five additional) members of the audit committee unless the court rules otherwise

the creditors determine the liquidator’s remuneration. Section 327(1) of the Ordinance grants the power to determine the liquidator’s remuneration to the audit committee, and in the absence of such committee to the creditors themselves.
the creditors have the power to permit the board of directors to continue acting after the resolution on voluntary liquidation of the insolvent company^[25]

3. Judicial Liquidation

3.1 Grounds for judicial liquidation

The court may direct that a solvent company be liquidated (Section 257 of the Companies Ordinance) on five grounds:

mandatory liquidation where the company adopted a special resolution that it would liquidate – similar to voluntary liquidation but judicially supervised - occurs where the company resolved on liquidation but did not resolve on the manner of carrying it out; offers the advantages of judicial liquidation, such as stay of proceedings.

the company did not commence doing business within a year of its incorporation or ceased doing business for a year.

no longer relevant after the new Companies Law removed the requirement of a minimum of members in a corporation – where the number of members in the company fell under the minimum required by the Ordinance today.

where the company is insolvent.

a catch-all provision (Section 275(5)): liquidation based on justice and equity – case law applied to situations where the company was fraudulently managed, or a closely held company reached a management deadlock even though the company is profitable, or where the infrastructure of the company has disappeared, or where there is no possibility to attain the objects of the company, oppression, existence of grounds set forth in the bylaws, etc.

Insolvency warranting judicial liquidation

“Insolvency” under Section 258 of the Ordinance is:

constructive insolvency – occurs where a creditor of the company demanded payment of a judicially recognized debt (as opposed to disputed assertion of liability) and was not paid within three weeks - the company need not actually be insolvent, and the provision is used as a “collection mechanism” in order to threaten the company - a spurious liquidation request will be liable for punitive costs.

an unsatisfied execution order or judicial decision – then the presumption of constructive insolvency applies.

a situation of “actual” insolvency – where the court is satisfied that the company is unable to meet its liabilities, based on

(1) a test of balance - a balance of the value of the company’s assets and liabilities based on the present value in disregard of the acquisition value. If the sum total of the liabilities exceeds the sum total of the assets (liquid and not liquid), the company is deemed economically insolvent, or

(2) a test of liquidity, adopted by Israeli courts - the test of financial difficulty, i.e. where the company’s assets are not liquid and therefore at the time it has no wherewithal to pay its liabilities – i.e., is insolvent from the creditors’ point of view.

3.2 Who is entitled to request judicial liquidation

An application for judicial liquidation may be filed by any of the following:

the company^[26] – by its board of directors (Section 377 of the new Companies Law).

a creditor^[27] – any person to whom the company owes an outstanding debt not yet paid at the time of the filing of the application, including a conditional or future creditor^[28]

a member^[29] – including a present member, a member of the company within the year preceding the commencement of liquidation, and prior to the final determination of the members – also any person who claims that he is a member (Section 1 of the Companies Ordinance). A shareholder must have been such for at least six months during which the shares are registered in his name + must have an interest in liquidation. Even where a shareholder meets these requirements, the court has discretion

the Attorney General^[30] – on the grounds that the company has not commenced doing business within a year of its incorporation or that it ceased doing business for a year or liquidation on the grounds of justice and fairness.

the Official Receiver^[31

the Companies Registrar^[32] – by way of administrative penalty for the company’s repeated default in paying financial sanctions imposed by the Registrar (Section 354 of the Ordinance).

4. Liquidation Proceeding

Authority to rule on liquidation - the district court within whose jurisdiction the company’s registered office or its principal place of business is located^[33].

No special court system for liquidation of companies.

4.1 Filing of application

Application to liquidate must be served:

To the company’s registered office –if liquidation request is filed other than by the company (Regulation 3 of the Companies (Liquidation) Regulations–1987 (“Liquidation Regulations”) in order^[34]:

1. To give the company an opportunity to pay the debt before the publication of the application;

2. To permit the company, if it wishes to dispute the debt, to apply to the court to prevent publication.

to the Official Receiver.

4.2 Publication

the fact of filing an application for the liquidation of the company and the date of hearing of such application at least 14 days prior to such hearing (Regulation 6 of the Liquidation Regulations).

4.3 Participating in the court hearing

Proposed participant in a hearing concerning a company’s liquidation:

must notify the applicant at least seven days prior to the date set for the hearing – who notifies the court of intended participants^[35]
or by leave of the court.

Proposed opponent of liquidation

must file with the court a letter of opposition with an affidavit no later than 7 days before the date of the hearing
must deliver a copy to the applicant^[36].

4.4 Stay of liquidation proceedings

The court may order stay of liquidation proceedings after a liquidation order has been granted at the request of:

a creditor
a member
the Official Receiver^[37].

Grounds:

the company repays in full its liabilities to its creditors
the application for liquidation is filed by an unauthorized person purporting to act in the name of the designated applicant
the application for liquidation has not been delivered to the company.

4.5 Date of commencing liquidation

Mandatory liquidation - commences on the date when the application for liquidation is filed^[38] (in order to prevent smuggling assets from the company).

Compare: Voluntary liquidation - commences on the date when the resolution to liquidate is adopted

4.6 Completion of liquidation

Mandatory liquidation terminates with

the judicial order providing that the company be dissolved as of the date of the order.
The liquidator must notify the Companies Registrar of the dissolution order within 14 days of the granting of the order
the Registrar will record the dissolution in his records^[39].

5. Assets Covered by Liquidation

The sum total of the assets eligible for distribution to the creditors includes all of the company’s assets under laws of contract and property:

in Israel
abroad
held by the company
assets that the company is entitled to them and in order to get them into the company the liquidator must adopt measures^[40] e.g. a contractual right to receive an asset or a payment

Liquidation laws give the liquidator certain powers designed to increase the sum total of the assets available for distribution to creditors^[41]:

liquidator has the right to cancel transactions under general laws of contract on any legal basis (for example, in the case of fraud or mistake, etc.)

liquidator has the right to cancel transactions by force of the Companies Ordinance where transactions are contractually valid but nullified due to the company’s liquidation (sections 355, 356 and 359 of the Companies Ordinance).

A voided fraudulent transfer – any transfer, pledge, delivery, assignment and other disposition of an asset that would have been deemed a fraudulent transfer under the Bankruptcy Ordinance (Section 355).
an assignment of rights that would be invalid in bankruptcy is invalid in liquidation (Section 356).

A creditor can benefit from execution against the company’s assets only if he had completed it (meaning, tangible assets sold, real estate - seized) before the commencement of liquidation (Section 357 (a))

Exception: protection of a bona fide purchaser of an asset from the execution officer – purchase is valid against the liquidator (357(c)).

if execution proceedings against the company have started but have not been completed, after notification that a liquidator has been appointed to the company or liquidation order, the execution officer will, upon the liquidator’s request, deliver the assets seized or the proceeds of their sale to the liquidator (Section 358).

a floating charge over the company’s assets created within 6 months prior to commencement of liquidation will not be valid in excess of the amount paid to the company in consequence of such charge, plus interest, unless it is proven that after the creation of the charge the company was solvent (Section 359).

Any transactions entered after the commencement of liquidation are null and void (Section 268 of the Companies Ordinance).

the liquidator may renounce a burdensome asset, i.e. an asset the collection or obtaining of which will impose on the liquidator a burden exceeding the efficiency of the asset for the increase of the sum total of the company’s assets.

the liquidator may collect any outstanding debts owed by the shareholders.

Receivership of the company’s assets abroad (Israeli case law has not addressed the issue):

Israeli court will give a receivership order regarding the company’s assets
the liquidator will apply to the courts of the foreign jurisdictions where the company’s assets are located to recognize the Israeli order +
the liquidator will resort to the execution proceedings of such foreign jurisdiction. – subject to considerations of cost efficiency and the liquidator’s right to renounce “burdensome assets”.

5.1 Distribution of company’s assets when these are insufficient to cover its liabilities

Where the company’s assets do not suffice for payment of all its liabilities:

The order of distribution:

secured debts
priority debts
debts secured by a floating charge
unsecured debts
shareholders (equity)

The rules of distribution:

the horizontal distribution rule – the equality principle – if there is no debt that has priority over another debt, the assets are divided pro rata, i.e. according to the percentage at an equal rate.
the vertical distribution rule – the absolute priority rule – debts of a higher priority order receive priority over debts of a lower priority order.

5.2 Secured creditors

A secured creditor - possessing a charge or lien over the debtor’s assets by way of security^[42].
a fixed charge over the company’s assets = prevents the company from disposing in any way of the asset subject to the charge without consent of the secured creditor.
a floating charge over the company’s assets = permits the company to continue doing business at its discretion, adding to its assets or derogating from them, until the floating charge crystallizes into a fixed charge.

A secured creditor:

may initiate proceedings to realize his security even after the commencement of liquidation, notwithstanding the prohibition applicable to the company’s ordinary creditors (Section 20(b) of the Bankruptcy Ordinance + Section 353 of the Companies Ordinance).

5.3 Priority upon liquidation

Secured debts

First charge – statutory charge preceding the fixed charge over the asset, e.g. the first charge over real property vested in the tax authorities for any tax liabilities in respect of such lands (Section 11a(1) of the Tax (Collection) Ordinance).

Fixed charge –

· proprietary right over the asset

· right to a full repayment of his debt from the asset subject to the charge; if the debt exceeds the value of the asset, in respect of the balance of the debt the creditor will be deemed as an ordinary unsecured creditor

· right conditional upon the registration of such charge^[43] or the depositing of the charged asset with the creditor.

Special charges – e.g. cautionary notice over a real property asset, creditors possessing liens over the company’s assets.

Liquidation expenses

Liquidation expenses - after the secured debts and before priority debts^[44], unless served to preserve the integrity of the company’s assets or their realization = were of use to the secured creditors^[45].

Priority debts [that precede the crystallization of the floating charge]

Priority debts = debts payable (at nominal value) before the owners of the floating charge^[46] and before the ordinary creditors of the company, but after the liquidation expenses have been covered.

Priority debts (in the order of priorities): (Section 354 of the Ordinance):

· Salaries

· income tax deductions

· mandatory payments, taxes and rent

Debts secured by floating charge

Debts secured by a floating charge:

The floating charge

crystallizes upon commencement of liquidation^[47]
is subject to the issuance of the liquidation order
applies to all the assets that remain in the company to which the charge relates
precedes a subsequent charge made without obtaining his consent where the terms of the floating charge included consent requirement (Section 169(b) of the Companies Ordinance) unless such subsequent charge was made to secure credit used to purchase such asset (Section 169(d) of the Companies Ordinance).

[Priority debts arising after the crystallization of the floating charge.]

Unsecured (ordinary) debts

Ordinary debts

voluntary debtors = liability arising out of voluntary transaction (contract) with the company a contract between the parties, e.g. suppliers, financiers providing credit to the company, clients
involuntary creditors, e.g. tort liabilities, authorities to which the company owes various payments.

Debts to shareholders

Debts owed to shareholders in their capacity as such, for example: dividend.

Distribution of the balance of the assets after the repayment of all the debts.

Asset remaining after full repayment of debts will be distributed in equal shares between the company’s shareholders in accordance with the company’s founding documents.

6. International liquidation proceedings in Israel

International liquidation proceedings have not yet been statutorily regulated in Israel.

Israeli courts handle international liquidation and insolvency matters through the rules of private international law^[48].

The important Supreme Court case - TWA Inc. v. Berman et al.

6.1 Appointment of liquidator to a foreign company against which there are liquidation proceedings abroad

The Israeli court entertaining liquidation proceedings concerning a foreign company having assets in Israel may direct that a temporary liquidator be appointed over the company’s assets in Israel, even though there are liquidation proceedings against the company taking place abroad^[49].

TWA Inc. v. Berman

Facts: a U.S. airline undergoing reorganization in the U.S.; the acquiring company refused to acquire the Israel direction, and thus Israeli creditors, including the airline’s Israeli employees, faced the risk of dealing with a company devoid of its assets.

The district court, notwithstanding a judicial proceeding in the U.S. regarding the company

appointed a temporary liquidator in Israel as a subsidiary local liquidator to protect the interests of the Israeli creditors in general and of the petitioner company’s employees (priority creditors) in particular
the appointment of the Israeli liquidator related solely to creditors and assets in Israel
the liquidators received the power to seize the petitioner company’s assets in Israel (excluding the airplanes landing in Israel), to prevent the removal of its assets from Israel, to insure assets, and otherwise to act in accordance with the Israel Companies Ordinance
rejected the petitioner company’s request to give the temporary liquidators direction as to notification and joinder of the petitioner company to proceedings, and reporting of assets and liquidators’ acts [beyond the notification and reporting prescribed by the Ordinance], etc.

The Supreme Court concurred, noting the protection of the Israeli employees of the company.

6.2 Liquidation of foreign company registered in Israel

A foreign company = a “company registered outside Israel or any body corporate, excepting a partnership, registered or incorporated outside Israel” ^[50].

a foreign company (whether or not registered in Israel) that has assets in Israel - the provisions of the Ordinance regarding judicial or judicially supervised liquidation and regarding a company’s judicially supervised settlement with its creditors will apply mutatis mutandis (Section 280 of the Ordinance).
where the company has assets in Israel, the court may direct that such company be liquidated, as if it were any Israeli company undergoing liquidation
a foreign company that has no assets in Israel – to obtain the benefit of a freeze of proceedings, must apply to the Minister of Justice, who has discretion to grant such order on the grounds of “public good” – in the framework of Section 233 of the Ordinance if the company commences negotiation for a settlement with its creditors.

6.3 Recognition of individual’s bankruptcy proceeding conducted abroad

A foreign bankruptcy order is deemed a foreign judgment.

For recognition and enforcement in Israel under the Enforcement of Foreign Judgments Law – 1958, a foreign judgment must either

fall within the scope of an agreement between Israel and the foreign country, whereby Israel has undertaken to recognize foreign judgments of the given type. Israel is not a party to any bilateral agreement concerning recognition of bankruptcy judgments (Section 11(a)).

satisfy the court that law and equity demand its recognition = incidental (not direct) recognition of a foreign judgment (Section 11(b)).

A foreign declaration of bankruptcy by a competent foreign court cannot, by itself, cause the debtor’s bankruptcy declaration in Israel. To be declared a bankrupt in Israel, the requirements of the Bankruptcy Ordinance must be satisfied, including the debtor’s connection with Israel.^[51]

^[1] Section 367(a)(1) of the Companies Law.

[2] See section 11 of the explanatory notes to the Companies Law proposal –1996.

[3] See Zipora Cohen, Liquidation of Companies, at 15.

^[4]Section 320 of the Companies Ordinance.

^[5] Section 335 of the Companies Ordinance.

[6] See Zipora Cohen, Shareholders in the Company: Rights of Action and Remedies, 1991, 1-31.

[7] See, for example, Civil Case 45/53 Re “Even Chen” Limited, District Cases 7, 472, 473.

[8] Section 319(3) of the Ordinance.

[9] The period of time for an extraordinary resolution is not set out in the Ordinance; the Ordinance provides in Section 115(a)(1) and (2) for the giving of due notice.

[10] Section 319(2) of the Companies Ordinance.

[11] Z. Cohen, Liquidation of Companies, at 30.

[12] Menier v. Hooper’s Telegraph Works (1874) 9 Ch. App. 350, Kirtz v. Grossman 463 S.W. 2d 541 (1971), cited in Z. Cohen, Liquidation of Companies, at 37.

[13] Z. Cohen, Liquidation of Companies, at 39.

[14] Section 320 of the Companies Ordinance.

[15] Section 325B of the Companies Ordinance

[16] Section 332 of the Companies Ordinance

[17] Section 338(a) of the Companies Ordinance

[18] Section 339(a) of the Companies Ordinance

[19] Z. Cohen, Liquidation of Companies, at 46.

[20] Section 327(2) of the Companies Ordinance.

[21] See Section 325(c) of the Companies Ordinance.

[22] See Section 325(c) of the Companies Ordinance.

[23] Section 323(a) of the Companies Ordinance

[24] Section 323(c) of the Companies Ordinance

[25] Section 327(1) of the Companies Ordinance.

[26] Section 259(1) of the Ordinance.

[27] Section 259(2) of the Ordinance.

[28] Section 259(2) of the Ordinance.

[29] Section 259(3) of the Ordinance.

[30] Sections 261 and 257(5) of the Ordinance.

[31] Section 262 of the Ordinance.

[32] Section 363 of the Ordinance.

[33] Section 256 of the Ordinance and the definition of “the court” in Regulation 1 of the Companies (Liquidation) Regulations – 1987.

[34] Z. Cohen, Liquidation of Companies, at 220.

[35] Regulation 8 of the Liquidation Regulations.

[36] Regulation 9 of the Liquidation Regulations.

[37] Section 271(a) of the Companies Ordinance.

[38] Section 265(a) of the Companies Ordinance.

[39] Section 315 of the Companies Ordinance.

[40] Z. Cohen, Liquidation of Companies, at 505.

[41] Z. Cohen, Liquidation of Companies, at 505.

[42] Section 1 of the Bankruptcy Ordinance. This definition applies also to liquidation by force of Section 353 of the Companies Ordinance.

[43] Section 179(a) of the Ordinance.

[44] Section 354(d) of the Ordinance.

[45] Civil Appeal 353/62 Hart v. Official Receiver et al., PADI vol. 17, 496 at 503-504.

[46] Section 354(c) of the Ordinance.

[47] Civil Appeal 353/62 Hart v. Official Receiver et al., PADI vol. 17, 496.

[48] Collier International Business Insolvency Guide, at www.bender.com

[49] Leave of Civil Appeal 3546/01 TWA Inc. v. Berman, 56(1)498.

[50] .Section 1 of The Companies Ordinance

[51] Shlomo Levin, Asher Grones, Bankruptcy, 2^nd ed., at 401.

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