"The grossly inadequate $20 million value of the proposed settlement cannot be justified under any circumstances," Paul Paradis, a New York-based lawyer for Bank of America investors who sued in Delaware, claiming the bank overpaid for Merrill Lynch, said in a filing yesterday. If the accord is approved, it could wipe out the Delaware claims. A federal judge in Manhattan still must decide whether to approve Charlotte, North Carolina-based Bank of America's $2.43 billion settlement of shareholder suits that claimed management hid Merrill losses ahead of the 2009 deal. The accord is separate from the $20 million settlement of so-called derivative claims against directors. The shareholders claimed former Chief Executive Officer Kenneth D. Lewis and other board members misled them about the losses Merrill Lynch incurred before the $18.5 billion buyout and should have pulled the plug on the deal. Lawrence Grayson, a Bank of America spokesman, declined to comment on the objection to the settlement.