1.3.1.0 Introduction

A comparative approach is employed in this research, founded on the belief that "law is the result of human wisdom for the benefit of mankind"1 and no one nation has a monopoly on wisdom, which applies to human society and thus to the field of law. But law is not sealed off from human society. Different ideologies, cultures, and legal traditions result in different approaches to legislation. Comparative law research reveals the function and methods of provisions in one's own system, which are often taken for granted.2 In this way, the comparative law study provides a mirror for a nation itself. It also offers a window to the outside world by providing access to a range of different solutions to a common problem.

The two exit remedies in this research are long established and well developed in the UK and US, but are new in China. Although the structuren of close companies in the UK and US make them different from those in China, the problems of illiquidity and oppression in close companies are universal. Given the similarity of problems faced by minority shareholders in close companies in these jurisdictions, insight into the remedies of the UK and US legal communities is useful in analyzing the comparable remedies under Chinese law.