In Wiraflor (Malaysia) Sdn Bhd v Bio Science
Capital Sdn Bhd  MLJU 514, it was held that:-
"...The Law Relating to the Removal
of a Liquidator
Section 232(1) of the Companies Act 1965provides that the Court may remove a liquidator
'on cause shown':-
"A liquidator appointed by the court may resign or
on cause shown be removed by the court.'
In Abric Project Management & Anor v Palmshine
Plaza Sdn. Bhd. & Anor.  5 MLJ 685 Ramly Ali J. (now CJA)
reviewed the leading cases of Re Sir John Moore Gold Mining Co  12
LR Ch D 325, Re Adam Eyton Limited; Ex parte Charlesworth 
36 Ch 299 as well as several other cases and adopted the tests set out therein.
I respectfully adopt His Lordship's decision formulating the relevant test to
In Re Sir John Moore Gold Mining Co. (above),
Jessel MR defined the words due cause to mean 7 should say that as a general
rule, they point to some unfitness of the person - it may be from personal
character, or from his connection with other parties, or from circumstances in
which he is mixed up - some unfitness in a wide sense of the term.'
And in Re Adam Eyton Cotton LJ in commenting on
the judgment of Jessel MR above held "...if the court is satisfied on the
evidence before it that it is against the interest of the liquidation, by which
I mean all those who are interested in the company being liquidated, that a
particular person should be made liquidator, then the court has power to remove
the present liquidator and of course then appoint some other person in his
In the same case Bowen L.J. stated:-
"..the due cause is to be measured by reference to
the real, substantial, honest interest of the liquidation and to the purpose
for which the liquidator is appointed. Of course fair play to the liquidator
himself is not to be left out of sight, but the measure of due cause is the
substantial and real interest of the liquidation."
And in Re George A Bond & Co. Ltd. (1932) 32
SR (NSW) 301 Long Innes J. said:-
"..ln my view neither suspicion alone, nor even a
prima facie case which might be rebutted, would either justify or require
removal unless there were reason for apprehension that the interests of the
liquidation would be imperilled by the continuance in office of the suspect, or
unless it were shown that such removal would before the advantage of those
interested in the assets of the company."
In Advance Housing Pty. Ltd. (in liq) v Newcastle
Classic Developments Pty Ltd.  14 ACSR, Santow J. held inter alia
that there must be a real and not merely theoretical possibility of conflict
and that the guiding principle in the appointment by the court of a liquidator
is that he must be independent and must be seen to be independent. The
foregoing comprise a summary of the accepted principles with regards to the
removal of a liquidator. ..."