The Delaware Supreme Court has revived part of a shareholder derivative lawsuit over Earthstone Energy Inc.’s controller-led acquisition of Texas-based Bold Energy III LLC, ruling that deal negotiations had started before a special committee could establish protections for the oil-and-gas driller’s minority investors.

The ruling, published Friday by a three-judge panel of the state high court, applied the justices’ 2014 precedent in the case Kahn v. M&F Worldwide to deny business-judgment deference to the Earthstone board and reversed, in part, the Chancery Court’s dismissal of the case in its entirety last July.