In an inspection-rights action, can a shareholder demand access to the company’s bank account statements?
The law does not list ‘bank account statements’ as a standalone statutory object of inspection. If a claim to ‘inspect bank statements’ is pleaded as a separate item of relief, courts generally do not uphold it. Note, however, that bank statements constitute auxiliary ledgers within the accounting books and are also attachments to the original vouchers, and may therefore be inspected together with the accounting books and accounting vouchers. It is accordingly advisable to assert access to bank statements within the scope of the accounting books and accounting vouchers, rather than as a separate claim.
