The law regarding sole shareholders' actions appears to be very clear. In most cases the corporate wrong can only be redressed by the corporation itself and in the corporate name. The few exceptions appear to have been allowed in good conscience by courts of equity, with each case being decided on its own merits. While other areas of the law are constantly changing, the law with respect to sole shareholders' actions has remained stable, with no indications that any changes will take place in the immediate future.
Julius E. Kovacs, Actions by a Sole Stockholder of a Corporation, 15 Clev.-Marshall L. Rev. 598 (1966)