Minority shareholders, as one of the providers of the company's initial capital and bearers of the highest commercial risk in the company's structure, are considered one of the beneficiaries of joint stock companies. The minority shareholders' interest in the legal system of any country makes the legislator ; He predicted rights for this group and also specified tools and mechanisms to defend their rights and interests with the help of these mechanisms; They can protect their rights and interests against groups such as managers and majority shareholders. Looking at the regulations of Iran's joint stock companies, it becomes clear that the rights and interests of minority shareholders are incompletely, limitedly and scatteredly considered by the legislator. Meanwhile, in the English law system, the legislator has paid more and more appropriate attention to the status and position of minority shareholders. Also, stronger and better mechanisms such as invoking the rule against unfair discrimination or the right to request the dissolution of the company to protect minority shareholders have been introduced. has seen Therefore, in this article, while examining the rights of minority shareholders in both countries, the challenges related to these rights of this group of shareholders have been identified, and then, according to internal sources, including jurisprudential sources, as well as British law, solutions have been proposed in order to solve these weaknesses and challenges. will be provided.

​