Section 448, The Companies Act, 2009

(1) In deciding whether it is just and equitable to make anorder under paragraph (a) of subsection (1) of section 447, the court shall have regard to the following matters:- (a) the extent to which the related company took part in the management of the company in liquidation; (b) the conduct of the related company towards the creditors of the company in liquidation; (c) the extent to which the circumstances that gave rise to the liquidation of the company are attributable to the actions of the related (d) the extent to which the businesses of the companies have been combined; (e) such other matters as the court thinks fit. (3) The fact that creditors of a company in liquidation relied on the fact that another company is, or was, related to it is not a ground for making an order under section 447.