BlackRock Credit Allocation Income Trust v. Saba Capital Master Fund, Ltd.

Summary

The court held that the funds’ bylaws clearly authorized the boards to request supplemental nominee information before the record date and required a response within five business days. Because Saba did not object or respond before that deadline, its nominees were ineligible, and the Court of Chancery erred by ordering the funds to count their votes. The court affirmed the ruling that laches did not bar Saba’s equitable claims and remanded for further proceedings.