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In
Orzeck v. Englehart, 195 A.2d 375 (Del. 1963), the Delaware Supreme Court adopted what the Court of Chancery subsequently described as a bedrock doctrine of Delaware corporate law - the Doctrine of Independent Legal Significance .
Warner Communications Inc. v. Chris-Craft Indus., Inc., 583 A.2d 962, 970 (Del. Ch.),
aff’d, 567 A.2d 419 (Del. 1989). The Delaware high court defined the doctrine as being applied as follows:
action taken under one section of that law is legally independent, and its validity is not dependent upon, nor to be tested by the requirements of other unrelated sections under which the same final result might be attained by different means.
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