On December 11, 2023, Saba Capital Master Fund, Ltd announced that it had filed a Complaint in the United States District Court's Southern District of New York against the Tortoise Midstream Energy Fund, Inc, among others, seeking to invalidate as unlawful under the Investment Company Act of 1940, provisions in the Tortoise Midstream Energy Fund, Inc's governing documents purporting to strip voting rights with respect to a shareholder's acquisition of shares constituting as little as 10% of the Tortoise Midstream Energy Fund, Inc's voting power. On December 5, the Court granted summary judgment to the Saba Parties and declared the Vote Stripping Provisions to be in violation of Section 18(i) of the Investment Company Act and ordered rescission of the Vote Stripping Provisions.