CHAPTER IV

 

APPOINTMENTS, REMOVALS AND OTHER CHANGES

 

A.          Directors [Topic 59 to 75]

B.          Managing/ Whole‑time Director [Topic 76 to 80]

C.          Manager/Secretary [Topic 81 to 85]

D.         Officer in Default [Topic 86 to 891

E.          Auditors [Topic 90 to 105]

F.          Sole Selling Agents [Topic 106 to 107]

G.         Others [Topic 108 to 111]

 

1.          Appointment of firm or body corporate to an office or place of profit [Topic 108]

2.          Waiver of refund of paid money u/s. 314 [Topic 109]

3.          Appointment of constituted attorney [Topic 110]

4.          Appointment of Inspector to investigate [Topic 111]

 

 

A. Directors

 

(Topic 59 to Topic 75)

 

Topic 59

 

DO YOU WISH TO APPOINT A DIRECTOR IN THE GENERAL MEETING OTHER THAN THE RETIRING ONE?

 

1.          Appointment of a director other than the retiring one in the General Meeting will, in case of a private company not being a subsidiary of a public company, be governed by its Articles of Association. The items 2 to 8, therefore, will not apply to such a company. [Section 257(1) & (2)]

 

2.          Give a notice to the company that you wish to propose a person to be appointed as a director not less than fourteen days before a General Meeting. Alternatively, a person himself may give notice of his candidatuie as aforesaid.

 

3.          Ensure that the aforesaid notice is either given by the person who is not a retiring director or by some member.

 

4.          There is no prescribed form for this notice but ensure that such notice must be accompanied by a deposit of five hundred rupees per candidate which will be returned if the candidate is elected. [Section 257(1)].

 

5.          File the written consent of the person proposed, with the company, before appointment, unless he himself has notified his candidature. There is no prescribed form for this purpose also.

 

6.          The aforesaid formality shall, however, not be necessary where he, immediately before such appointment, was already the Board appointed director of the company. [Section 264(1)].

 

7.          Inform all the members about the aforesaid Oroposal or candidature by serving individual notices on them not less than seven days before the meeting. [Section 257(1)]

 

8.          But it shall not be necessary for the company to serve individual notices upon the members as aforesaid if the company advertises such candidature or intention not less than seven days before the meeting in at least two newspapers circulating in the place where the registered office of the company is located. [Section 257(1A) proviso]

 

9.          Out of the two newspapers one should be published in the English lan­guage in an English newspaper and the other in the regional language of that place where the registered office is situated in any regional newspaper, both the newspapers having wide circulation in that place. [Section 257(1A), Provisos].

 

10.        Forward three copies of this notice also to the Stock Exchange with which the shares of your company are listed. [Clause 31(c) of the Standard Listing Agreement].

 

11.        Hold the General Meeting and pass the Ordinary Resolution by simple majority for appointment. [Section 189(1)].

 

12.        If the Articles of Association of your company require passing of a Special Resolution for such appointment, then pass a Special Resolution by three fourths majority. [Section 189(2)].

 

13.        Send three copies of the notice and a copy of the proceedings of the General Meeting to the Stock Exchange with which the shares of our company are listed. [Clause 31(c) and (d) of the Standard Listing Agreement].

 

14.        The person so appointed cannot act as director unless he files his consent in Form No. 29 within thirty days of his appointment as a director with the concerned Registrar of Companies , after paying the requisite fee prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury challan. [Rule 22].

 

15.        The aforesaid condition shall not, however, be necessary in case where such a person immediately before his appointment as director was already the Board appointed director or a retiring director of the same company. [Section 264(2)].

 

16.        See that such director notifies about his appointment to other companies in which he is a director, managing director, manager or secretary within twenty days. [Section 305].

            

 17.       Keep in mind that if such director does not do so, he will be punishable with fine of upto Rs. 5,000/-. [Section 305(1)]

 

18.        File Form No. 321 in duplicate within thirty days of his appointment [Section 303(2)] with the concerned Registrar of Companies after paying the requisite fee' prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury challan. [section 303(2) read with Rule 22].

 

19.        Please keep in mind that if default is made in complying with the aforesaid requirements, the company, and every officer of the company who is in default will be punishable with fine upto Rs. 500/‑ for every day during which the default continues. [Section 303(3)]

 

20.        Refund the deposit of five hundred rupees mentioned in item 4 of this topic to the person who has given the notice of candidature of a director only when he is appointed, in the General Meeting and not otherwise.

 

21.        If the resolution passed is a Special Resolution, file the same with Explanatory Statement with the concerned Registrar of Companies in Form No. 23 within thirty days [Section 192(4)(a)] after paying the requisite fee as prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury challan. [Rule 22].

 

22.        Please keep in mind that, if default is made in complying with the aforesaid requirement, the company and every officer of the company will be punishable with fine upto Rs. 200/­for every day during which the default continues. [Section 192(5)]

 

23.        Make necessary entries in the Register of Directors Particulars. [Section 303(1)] in the Register of Directors Shareholdings, etc. [Section 307].

 

24.        Please also keep in mind that if default is made in complying with the requirements of sections 303(1) and 307(1), the company and every officer of the company who is in default will be punishable, with fine upto Rs. 500/- for every day during which the default continues in case of contravention of section 303(1) and in case of contravention of section 307(1) with fine upto Rs. 50,000/‑ and also with a further fine of upto Rs. 200/- for every day during which the default continues. [Section 303(3) read with section 307(8)]

 

25.        If the case falls under any of the Topics from 64 to 69 follow the proce­dure as mentioned therein.

 

26.        If this increases the number of directors mentioned in the Articles of As­sociation of the company, take note of Topic 70.

 

27.        Take note of the provisions of Sections 253, 274, 275, 278 and 284 of the Companies Act, 1956, as regards disqualifications, disabilities, etc., of the persons to be appointed as directors.

 

28.        Promptly notify to the Stock Exchange with which the shares of your company are listed the change in the company's directors. [Clause 30(a) of the Standard Listing Agreement]

 

29.        If you are a listed company, note­

 

A.          that the Board of directors of the company shall have an optimum combination of executive and non‑executive directors with not less than fifty percent of the board of directors comprising of non‑executive directors. The number of independent directors would depend whether the Chairman is executive or non‑executive. In case of a non‑executive chairman, at least one‑third of board should comprise of independent directors and in case of an executive chairman, at least half of Board should comprise of independent directors.

 

Explanation.‑For the purpose of this clause the expression 'independent directors' means directors who apart from receiving director's remuneration, do not have any other material pecuniary relationship ortransactions with the company, its promoters, its management or its subsidiaries, which in judgement of the board may affect independence of judgement of the director. Except in the case of government companies, institutional directors on the boards of companies should be considered as independent directors whether the institution is an investing institution or a lending. institution.

 

B.          that all pecuniary relationship or transactions of the non‑executive directors viz‑a‑viz the company should be disclosed in the Annual Report. [Clause 49(1) of the Standard Listing Agreement].

 

C.          that, in case of the appointment of a new director or re‑appointment of a director the shareholders must be provided with the following information:

 

(a)         A brief resume of the director;

 

(b)         Nature of his expertise in specific functional areas; and

 

(c)         Names of companies in which the person also holds the directorship and the membership of Committees of the board. [Clause 49. VI of Standard Listing Agreement]

 

30.        Further Note that if your company's paid‑up share capital is less than Rs. 50     lakhs but is or more than Rs. 10 lakhs, your company is required to obtain a Compliance Certificate from a secretary in whole‑time practice to be filed with the Registrar of Companies mentioning therein that the registers have been kept and maintained as stated in Annexure A of the certificate, the forms have been duly filed with the Registrar of Companies stated in Annexure B of the Certificate and the appointment of director has been duly made as per paragraphs 1, 2 and 14 of the Form of Compliance Certificate appended to the Companies (Compliance Certificate) Rules, 2001. [Section 383‑A(1) proviso].

 

Topic 60

 

DO YOU WISH TO RE‑APPOINT A DIRECTOR ON HIS RETIREMENT?

 

1.          Find out which director will retire by rotation pursuant to Section 256(1) that is whether the director in question falls within one‑third of two‑third of the directors liable to retire by rotation as per Section 255(1).

 

2.          Ascertain whether the retiring director is willing to be re‑appointed. Nor­mally, the consent can be taken for granted.

 

3.          Call a Board Meeting by gi ving notice to all the directors of the company as per Section 286 to approve the Accounts for the previous year and to consider the notice convening the Annual General Meeting.

 

4.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine of Rs. 1000/‑. [Section 286(2)]

 

5.          Issue noticest in writing at least twenty‑one days before the date of the General Meeting [Section 171(1)] to the shareholders and also send three copies of such notice to the recognised Stock Exchange with which the shares of your company are listed. [Clause 31(c) of the Standard Listing Agreement].

 

6.          Propose the appointment of the director as an Ordinary Resolutiont and have the Ordinary Resolution passed by simple majority. [Section 189(1)].

 

7.          Forward a copy of the proceedings of the Annual General Meeting to the Stock Exchange with which the shares of your company are listed. [Clause 31(d) of the Standard Listing Agreement].

 

8.          Keep in mind that if your company's paid‑up share capital is less than Rs. 50 lakhs but is or more than Rs. 10 lakhs, your company is required to obtain a Compliance Certificate from a secretary in whole‑time practice to be filed with the Registrar of Companies mentioning therein that the appointment of director has been duly made as per paragraph 14 of the Form of Compliance Certificate appended to the Companies (Compliance Certificate) Rules, 2001. [Section 383A(1) proviso]

 

Topic 61

 

DO YOU WISH TO APPOINT AN ADDITIONAL DIRECTOR?

 

1.          Consult the Articles of Association of your company to see whether they authorise the Board of Directors to appoint additional directors [Section 260]; if not, complete proceedings to alter them accordingly, vide Topic 26.

 

2.          In the case of a public company or its subsidiary, see that the written consent of the person to be appointed as an additional director is filed with the company. There is no prescribed form for the same.

 

3.          The aforesaid formality shall, however, be not necessary where he, immediately before such appointment, was already a director of the company. [Section 264(1)].

            

4.          Convene a Board Meeting after giving noticel to all directors of the company as per Section 286 and pass a resolution~ and appoint the additional director to hold office only up to the date of the next Annual General Meeting. [Section 260, First Proviso].

 

5.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/‑. [Section 286(2)]

 

6.          See that such director notifies about his appointment to other companies in which he is a director, managing director, manager or secretary within twenty days. [Section 305].

 

7.          Please also keep in mind that if such director does not do so, he will be punishable with fine upto Rs. 5000/-. [Section 305(1)]

 

8.          File Form No. 29 within thirty days of his appointment with the con­cerned Registrar of Companies after paying the requisite fee. [Section 264(2)] as prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury challan [Rule 22].

 

9.          The aforesaid condition shall not, however, be necessary in case where such a person immediately before his appointment as director was already the Board appointed director or a retiring director of the same company. [Section 264(2)].

 

10.        File Form No. 32 in duplicate within thirty days of his appointment with the concerned Registrar of Companies [Section 303(2)] after paying the requisite fee prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury challan. [Rule 22].

 

11.        Make necessary entries in the Register of Directors and in the Register of Directors shareholdings, etc. [Sections 303(1) & 307].

 

12.        Please keep in mind that if default is made in complying with the aforesaid requirements, the company and every officer of the company who is in default will be punishable with fine upto Rs. 500/- for every day during which the default continues in case of contravention of section 303(1) and in case of contravention of section 307(1) with fine upto Rs. 50,000/- and also with a further fine of upto Rs. 200/- for every day during which the default continues. [Section 303(3) read with Section 307(8)]

 

13.        Follow the procedure as stated in items 25 to 30 of Topic 59.

 

14.        See that the number of directors including the additional director does not exceed the maximum strength fixed for the Board by the Articles of Association of your company. [Section 260, Second Proviso].

 

15.        Note that co‑option of additional directors will fail for lack of bona fides if it can be shown that such an appointment was intended just to gain majority for the managing director in other subsequent meetings of the Board of Directors and the convening of the meeting at which the additional director was appointed and the resolutions passed thereat are also found to be invalid. [Dr. T.M. Paul v. City Hospital (P.) Ltd. & other, (1999) 35 CLA 164 (Ker)].

 

16.        Further note that if your company's paid‑up share capital is less than Rs. 50 lakhs but is or more than Rs. 10 lakhs, your company is required to obtain a Compliance Certificate from a secretary in whole‑time practice to be filed with the Registrar of Companies mentioning therein that the registers have been kept and maintained as stated in Annexure A of the Certificate and the forms have been duly filed with the Registrar of Companies as stated in Annexure B of the certificate and the appointment of additional director has been duly made as per paragraphs 1, 2 and 14 of the Form of Compliance Certificate appended to the Companies (Compliance Certificate) Rules, 2001. [Section 383‑A(1) proviso]

 

Topic 62

 

DO YOU WISH TO APPOINT AN ALTERNATE DIRECTOR?

 

1.          Consult the Articles of Association of your company to see whether they authorise the Board of directors to appoint an alternate director. Otherwise, either complete proceedings to alter them accordingly vide Topic 26 or pass a resolutiont in your company’s General Meeting authorising the Board of directors of your company to make such appointment. [Section 313(1)].

 

2.          In case of a public company or its subsidiary, see that the written consent of the person to be appointed as an alternate director is filed with the company. There is no prescribed form for the same.

 

3.          The aforesaid formality shall, however, be not necessary where he immediately before    such appointment was already a director of the company. [Section 264(1)].

 

4.          Convene a Board Meeting after giving notice to all the directors of the company as per Section 286 and pass a resolutiont and appoint the alternate director to act for the original director during his absence for a period of not less than three months from the State in which the meetings of the Board are ordinarily held. [Section 313(1)].

 

5.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/‑. [Section 286(2)]

 

6.          The said alternate director will not hold office as such for a period longer than that permissible for the original director in whose place he has been appointed and shall vacate office if and when the original director returns to the State in which Board Meetings are ordinarily held. [Section 313(2)].

 

7.          See that the director notifies about his appointment to other companies in which he is a director, managing director, manager or secretary within twenty days. [Section 305]

 

8.          Please also keep in mind that. if such a director does not do so, he will be punishable with fine upto Rs. 5000/‑. [Section 305(1)]

 

9.          File Form No. 29 within thirty days of his appointment with the concdmed Registrar of Companies [Section 264(2)] after paying the requisite fee as prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury challan. [Rule 22]

 

10.        The aforesaid condition shall not, however, be necessary in case where such a person immediately before his appointment as director was already a director of the same company.

 

11.        File Form No. 32 in duplicate within thirty days of his appointment with the Registrar of Companies, [Section 303(2)] after paying the requisite fee prescribed under Schedule. X to the Companies Act, 1956, either in cash, or treasury challan. [Rule 22]

 

12.        Make necessary entries in the Register of Directors and in the Register of Directors Shareholdings. [Sections 303(1) & 307]

 

13.        Further keep in mind that if default is made in complying with the aforesaid requirements, the company and every officer of the company who is in default will be punishable with fine upto Rs. 500/‑ for every day during which the default continues in case of contravention of section 303(1) and in case of contravention of section 307(1) with fine upto Rs. 50,000/‑ and also with a further fine of Rs. 200/- for every day during which the default continues. [Section 303(3) read with section 307(8)]

 

14.        Follow the procedure as stated in item 27 of Topic 59.

 

15.        If the office of the original director is determined before that director returns and the alternate director is continuing his office then the provision of automatic reappointment of retiring directors in default of another appointment shall not apply to the alternate director. [Section 313(3)]

 

16.        Note that if your company's paid‑up share capital is less than Rs. 50 lakhs but is equal to or more than Rs. 10 lakhs, your company is required to obtain a Compliance Certificate from a secretary in whole‑time practice to be filed with the Registrar of Companies mentioning therein that the registers have been kept and maintained as stated in Annexure A of the Certificate, the forms have been duly filed with the Registrar of Companies as stated in Annexure B of the certificate and the appointment of alternate director has been duly made as per paragraphs 1, 2 and 14 of the Form of Compliance Certificate appended to the Companies (Compliance Certificate) Rules, 2001. [Section 383‑A(1) proviso]

 

6.          For the text of the Rules, see Appendix 18 and for check points thereunder see Guidance Note on Compliance Certificate issued by ICSI the text of which is given in Appendix 42.

 

Topic 63

 

DO YOU WISH TO HAVE A CASUAL VACANCY IN THE OFFICE OF A DIRECTOR TO BE FILLED UP BY YOUR BOARD?

 

1.          In the case of a public company or its subsidiary, see that the wifffiten consent from the person who is proposed to be appointed in the casual vacancy is filed with the company. There is no prescribed form for the same.

 

2.          The aforesaid formality, however, shall not be necessary where he immediately before such appointment was already a director of the company. [Section 264(1)].

 

3.          Convene a Board Meeting after giving notice to all the directors of the company as per section 286 and pass a resolutiont and appoint the director to hold office up to the period up to which the director in whose place he is appointed would have held office if it had not been vacated. [Section 262(2)].

 

4.          Please keep in mind that every officer of the company whose dutyis to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/‑.[Section 286(2)]

 

5.          In the case of a private company, not being a subsidiary of a public com­pany, the procedure of appointment will be governed by its Articles of Association.

 

6.          In the case of other companies, the procedure as given in items 1, 2 and 3 above will apply in respect of filling up of casual vacancies in the offices of those directors who were originally appointed in General Meeting subject to any provisions in the Articles of Association to the contrary, if any, in this regard. [Section 262(1)].

 

7.          The person so appointed cannot act as director unless he files his consent in Form No. 29 within thirty days with the concerned Registrar of Companies after paying the requisite fee prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury challan. [Rule 22].

 

8.          The aforesaid condition shall not, however, be necessary in case where such a person immediately before his appointment as director was already a director of the same company. [Section 264(2)].

 

9.          See that the director notifies about his appointment to other companies in which he is a director, managing director, manager or secretary within twenty days. [Section 305].

 

10.        Please also keep in mind that if such a director does not do so he will be punishable with fine upto Rs. 5000/-. [Section 305(1)]

 

11.        File Form No. 32 in duplicate within thirty days of his appointment with the concerned Registrar of Companies [Section 303(2)], after paying the requisite fee prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury challan. [Rule 22].

 

12.        Make necessary entries in the Register of Directors and in the Register of Directors Shareholdings. [Sections 303(1) & 307].

 

13.        Further keep in mind that if default is made in complying with the aforesaid requirements, the company and every officer of the company who is in default will be punishable with fine upto Rs. 500/- for every day during which the default continues in case of contravention of section 303(1) and in case of contravention of section 307(1) with fine upto Rs. 50,000/- and also with a further fine of Rs. 200/- for every day during which the default continues. [Section 303(3) read with Section 307(8)]

 

14.        Follow the procedure as stated in item 27 of Topic 59.

 

15.        Note that if your company's paid‑up share capital is less than Rs. 50 lakhs but is equal to or more than Rs. 10 lakhs, your company is required to obtain a Compliance Certificate from a secretary in whole‑time practice to be filed with the Registrar of Companies mentioning therein that the registers have been kept and maintained as stated in Annexure A of the Certificate, the forms have been duly filed with the Registrar of Companies as stated in Annexure B of the certificate and the appointment of director has been duly made as per paragraphs 1, 2 and 14 of the Form of Compliance Certificate appended to the Companies (Compliance Certificate) Rules, 2001. [Section 383‑A(1) proviso]

 

Topic 64

 

DO YOU WISH TO APPOINT A DIRECTOR TO THE VACANCY CREATED BY REMOVAL OF A FORMER DIRECTOR?

 

1.          While obtaining special notice from a member for removing a director, vide Topic 71, obtain simultaneously special notice also for appointing another person as a director in his place. [Section 284(2) & (5)].

 

2.          Inform the members about the special notice having been received by the company, vide Topic 151.

 

3.          In the case of a public company or its subsidiary, see that the written consent of the persons to be appointed are filed with the company. There is no prescribed form for the same.

 

4.          The aforesaid formality is not necessary where he, immediately before such appointment, was already an additional or alternate director of the company. [Section 264(1)].

 

5.          Convene a Board Meeting after giving notice$ to all the directors of the company as per Section 286 and take the decision of such appointment and also to fix the date, time and place of the General Meeting.

 

6.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/‑. [Section 286(2)]

 

7.          Issue noticest in writing at least twenty‑one days before the date o the General Meeting proposing the Ordinary Resolution with suitable Explanatory Statement. [Section 171(1) read with section 173(2)].

 

8.          Hold the General Meeting and pass an Ordinary Resolution by ordinary majority [Section 189(1)] appointing the director in place of the one removed to hold office until the date up to which his predecessor would have held office had he not been so removed. [Section 284(5)].

 

9.          Forward three copies of the notice and a copy of the proceedings of the General Meeting to the Stock Exchange with which the shares of your company are listed. [Clause 31(c) and (d) of the Standard Listing Agreement].

 

10.        Alternatively, do not appoint him in the general meeting but appoint him in a board meeting in the manner in which a casual vacancy is filled up, vide Topic 63. [Section 284(6)].

 

11.        Promptly notify to the Stock Exchange with which the shares of your company are listed, the change in your company's Board of directors. [Standard Listing Agreement].

 

12.        The person so appointed cannot act as director unless he files his consent in Form No. 29 within thirty days with the concerned Registrar of Companies, after paying the requisite fee prescribed under Schedule X to the Companies Act, 1956 either in cash or by way of treasury challan. [Rule 22(1)]

 

13.        The aforesaid condition shall not, however, be necessary in case where such a person was immediately before his appointment as director already a director of the same company [Section 264(2)] that is if he is a director reappointed after retirement or an additional or alternate director, or a director filling a casual vacancy or a director named in the company's Articles of Association.

 

14.        See that the director notifies about his appointment to other companies in which he is a director, managing director, manager or secretary within twenty days. [Section 305].

 

15.        Please also keep in mind that if such a director does not do so, he will be punishable with fine upto Rs. 5000/‑ [Section 305(1)]

 

16.        File Form No. 32 in duplicate within thirty days of his appointment with the concerned Registrar of Companies [Section.303(2)], after paying the requisite fee prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury challan. [Rule 22].

 

17.        Make necessary entries in the Register of Directors and in the Register of Directors' Shareholdings. [Sections 303(1) & 307].

 

18.        Further keep in mind that if default is made in complying with the afore­said requirements, the company and every officer of the company who is in ­default will be punishable with fine upto Rs. 500/_6 for every day during which the default continues in case of contravention of section 303(1) and in case of contravention of section 307(1) with fine upto Rs. 50,000/- and also with a further fine of upto Rs. 200/- for every day during which the default continues. [Section 303(3) read with Section 307(8)]

 

19.        Follow the procedure as stated in item 27 of Topic 59.

 

20.        Note that if your company's paid‑up share capital is less than Rs. 50 lakhs but is equal to or more than Rs. 10 lakhs, your company is required to obtain a Compliance Certificate from a secretary in whole‑time practice to be filed with the Registrar of Companies mentioning therein that the registers have been kept and maintained as stated in Annexure A of the Certificate, the forms have been duly filed with the Registrar of Companies as stated in Annexure B of the certificate and the appointment of director has been duly made as per paragraphs 1, 2 and 14 of the Form of Compliance Certificate appended to the Companies (Compliance Certificate) Rules, 2001. [Section 383‑A(1) proviso]

 

Topic 65

 

DO YOU WISH TO APPOINT A DIRECTOR WHO WILL NOT BE LIABLE TO RETIRE BY ROTATION?

 

1.          Consult the Articles of Association of your company to see whether they authorise the appointment of directors not liable to retire by rotation subject, of course, to Sections 255 and 256 (which provide that not less than two‑thirds of the total number of directors are liable to retire by rotation and one‑third of these two‑thirds must retire at every Annual General Meeting); if not, complete proceedings to alter them accordingly vide Topic 26.

 

2.          Convene a Board Meeting after giving noticet to all the directors of the company as per Section 286 and take the decision of such appointment, and also to fix the date, time and place of the general meeting.

 

3.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/- [Section 286(2)]

 

4.          Central Government's approval is not needed where the appointment or re‑appointment of managerial personnel is made in terms of Section 269 read with Schedule XIII of the Act.

 

5.          See that the number of non‑retiring directors does not exceed one‑third of the total number of directors. [Section 255].

 

6.          The ordinary resolution passed at the general meeting should be subject to Central Government's approval if such appointment is not made in terms of Section 269. [Circular No. 3 of 1989 File No. 3/19/88‑CL‑V, dated 13‑4‑1989].

 

7.          Make an application to the Central Government for the approval of the appointment of a director who will not be liable to retire by rotation. [Section 268].

 

8.          Before making such an application give a general noticet to all the mem­bers indicating the nature of the application.

 

9.          Publish the notice at least once in a newspaper in the principal language of the district in which the registered office of the company is situated and circulating in that district and at least once in English in an English newspaper circulating in that district. [Section 640B].

 

10.        The application to the Central Government shall be in Form 25B and shall have the following enclosures:­

 

(i)          Two certified true copies each of the notices published in the newspapers together with a certificate by the company as to the due publication thereof. [Section 640B].

 

(ii)         A certified true copy of the Memorandum and Articles of Association together with a certified true copy of the changed Articles, where they have been altered.

 

(iii)         A treasury challan or demand draft evidencing the payment of requisite fee prescribed under the Companies (Fees on Application) Rules, 1999.

 

(iv)        A certified true copy of the resolution of the Board or of the General Meeting, as the case may be.

 

11.        If the application fee is paid by way of treasury challan, then pay the requisite fee of minimum Rs. 500/‑ and maximum Rs. 2000/‑, as the case may be, in cash and as prescribed by the Companies (Fees on Application) Rules, 1999, by way of treasury challan prepared in triplicate and paid into any of the specified branches of the Punjab National Bank for credit.

 

12.        The description of the Head of account of the treasury challan should be as prescribed under Rule 22(2) of the Companies (Central Government's) General Rules and Forms, 1956 and as amended vide GSR 251(E), dated 21‑6‑1996 (w.e.f. 21‑6‑1996). For account head and code please see Rule 22(2) in Appendix 1.

 

13.        Two copies of the challan will be given back to the depositor who should file the original copy along with the documents mentioned in item 10.

 

14.        If the application fee is paid by way of demand draft, then draw the demand draft in favour of "Pay and Accounts Officer, Department of Company Affairs, New Delhi", and payable at any bank located in New Delhi, and the said demand draft should be filed along with the documents mentioned in item 10.

 

15.        Send a copy of the application with all enclosures to the concerned Regis­trar of Companies . [Rule 20A].

 

16.        See that the written consent of the proposed director is filed with the company. There is no prescribed form for the same. This formality, however, shall not be necessary where he inuptediately before such appointment was already a director of the company. [Section 264(1)].

 

17.        Appoint the person concerned as a director not liable to retire by rotation either in the General Meeting or in the Board Meeting as per the terms of Articles of Association.

 

18.        If the Articles of Association is silent on such matter then the first appointment of a director not liable to retire by rotation should be through the General Meeting. [Section 255(2)].

 

19.        Issue noticesl at least twenty‑one days before the date of the General Meeting proposing the Ordinary Resolution with Suitable Explanatory Statement. [Section 171(1) read with section 173(2)].

 

20.        Hold the General Meeting and pass the ordinary Resolutiont by simple majority for appointment. [Section 189(1)].

 

21.        Send three copies of the notice and a copy of the proceedings of the General Meeting to the Stock Exchange with which the shares of Y, our company are listed. [Clause 31(c) and (d) of the Standard Listing Agreement ].

 

22.        The person so appointed cannot act as director unless he files his consent in Form No. 29 within thirty 6 days with the concerned Registrar of Companies, after paying the requisite fee prescribed under Schedule X to the Companies Act, 1956, either in cash, demand draft or treasury challan. [Rule 22].

 

23.        The aforesaid condition shall not, however, be necessary in case where such a person was immediately before his appointment as director already a director of the same company. [Section 264(2)].

 

24.        See that the director notifies about his appointment to other companies in which he is a director, managing director, manager or secretary within twenty days. [Section 305].

 

25.        Please keep in mind that if such a director does not do so, he will be pun­ishable with fine upto Rs. 5000/‑. [Section 305(1)]

 

26.        File Form No. 32 in duplicate within thirty days of his appointment with the concerned Registrar of Companies [Section 303(2)], after paying the requisite fee prescribed under Schedule X to the Act, either in cash, demand draft or treasury challan. [Rule 22].

 

27.        Make necessary entries in the Register of Directors and in the Register of Directors Shareholdings. [Sections 303(1) & 307].

 

28.        Please keep in mind that if default is made in complying with the aforesaid requirements, the company and every officer of the company who is in default will be punishable with fine upto Rs. 500/‑ for every day during which the default continues in case of contravention of section 303(1) and (2) and in case of contravention of section 307(1) with fine upto Rs. 50,000/‑ and also with a further fine of upto Rs. 200/‑ for every day during which the default continues. [Section 303(3) read with Section 307(8)]

 

29.        Follow the procedure as stated in item 27 of Topic 59.

 

30.        If your company is a Goverment company then Central Government's approval is not required for the appointment of such a director.

 

31.        If the appointment is as per the terms of Section 269 read with Schedule XIII of thw Act, then ttle a return in Form No. 25C within 90 days of such appointment.

 

32.        If such a director also becomes the managing director of the company then the Ordinary Resolution should be filed in Form No. 23 within 30 days of its passing with the concerned Registrar of Companies [Section 192(4)(c)] after paying the requisite fee prescribed under Schedule X to the Act either in cash, demand draft or treasury challan. [Rule 22].

 

33.        Please also keep in mind that if your company fails to comply with the aforesaid filing, the company and every officer of the company who is in default will punishable with fine of Rs. 200/‑ for every day during which the default continues. [Section 192(5)]

 

34.        If your company is a Government Company then provisions of Section 268 will not apply to your company.

 

35.        Note that as per the Citizen's Charter of the Department of Company Affairs, Schedule I, Serial No. 9, the application will be processed within 30 days. [No. 5/25/99‑CL‑V,‑ Press Note 9/99, dated 9‑8‑1999].

 

36.        Please keep in mind that if your company is a public company and is also having a paid‑up share capital of Rs. 5 crores or more and has a director appointed by small shareholders of your company, he need not have to retire by rotation and for that no application has to be made to the Central Government. [Section 268 read with Rule 4(6) of the Companies (Appointment of the Small Shareholders Director Rules, 2001.]

 

37.        Note that if your company's paid‑up share capital is less than Rs. 50 lakhs but is equal to or more than Rs. 10 lakhs, your company is required to obtain a Compliance Certificate from a secretary in whole‑time practice to be filed with the Registrar of Companies mentioning therein that the registers have been kept and maintained as stated in Annexure A of the Certificate, the forms have been duly filed with the Registrar of Companies and the Central Government as stated in Annexure B of the certificate and the appointment of director has been duly made as per paragraphs 1, 2 and 14 of the Form of Compliance Certificate appended to the Companies (Compliance Certificate) Rules, 2001. [Section 383A(1) proviso]

 

Topic 66

 

DO YOU WISH TO APPOINT AN EXECUTIVE OF YOUR COMPANY ON THE BOARD OF DIRECTORS?

 

A. As a director (other than as a managing director or whole‑time director) :

 

1.          Convene a Board Meeting by giving noticet to all the directors of the Company as per Section 286 and consider the terms and conditions on which the Executive is to be appointed as a director and fix up day, time, place and agenda for convening a General Meeting for passing a Special Resolution in this regard. [Section 314].

 

2.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meetings as aforesaid and who fails to do so will be punishable with fine of Rs. 1000/‑. [Section 286(2)]

 

3.          Ensure that a person, firm or body corporate connected with a Director is not appointed to an office or place of profit carrying a total monthly remuneration of Rs. 10,000/‑, or more [Rule 10C(1)] without the consent of the company accorded by a Special Resolution.

 

4.          To do so obtain a declaration from the person proposed to be appointed to any such office or place of profit in writing to the effect that he is connected with a director of the company in any one of the ways referred to in Section 314(1)(b) either before or at the time of such appointment. [Section 314(2A)].

 

5.          Issue noticesl in writing at least twenty‑one days before the date of the General Meeting with suitable Explanatory Statement. [Section 171(1) read with section 173(2)].

 

6.          Hold the General Meeting and pass the Special Resolutiont by three fourths majority. [Section 189(2)].

 

7.          Forward promptly to the Stock Exchange with which the shares of your company are listed, three copies of the notice and a copy of the proceedings of the General Meeting. [Clause 31(c) and (d) of the Standard Listing Agreement].

 

8.          Complete the formalities prescribed for appointment of a Director vide Topic 59.

 

9.          If the person so appointed is a partner or relative of the director or manager of your company and he draws as an executive of the company a total monthly remuneration of not less than twenty thousand rupees [Rule 10C(2)], then in addition to the Special Resolution obtain approval of the Central Government vide Topic 69.

 

10.        File with the concerned Registrar of Companies' the copy of Special Resolution with Explanatory Statement in Form No. 23 within thirty days of passing of the resolution [Section 192(4)(a)] after paying the requisite fee prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury challan. [Rule 22].

 

11.        Please keep in mind that if your company fails to comply with the aforesaid filing, the company and every officer of the company who is in default will be punishable with fine upto Rs. 200/‑ for every day during which the default continues. [Section 192(5)]

 

12.        Note that if your company's paid‑up share capital is less than Rs. 50 lakhs but is equal to or more than Rs. 10 lakhs, your company is required to obtain a Compliance Certificate from a secretary in whole‑time practice to be filed with the Registrar of Companies mentioning therein that your company has obtained necessary approvals from the Board of Directors and members of your company pursuant to section 314 and that the appointment of director has been duly made as per paragraphs 11 and 14 of the Form of Compliance Certificate appended to the Companies (Compliance Certificate) Rules, 2001. [Section 383‑A(1) proviso]

 

B.          As a wholetime director/managing Director:

 

1.          Same as above in A except that section 314 will not apply by virtue of the exemption contained in sub‑section (3) thereof.

 

2.          But after the meeting approves the appointment, unless such appointment is made in accordance with the conditions specified in Parts I, II and III of Schedule XIII to the Companies Act, 1956, apply to the Central Government in Form No. 25A. [Section 269(2)].

 

3.          The aforesaid application should be made after giving general noticet to members of your company indicating the nature of the application to be made to the Central Government by publishing the said notice at least once in the regional languages in a newspaper of the principal language of the district in which the registered office of the company is situated and circulating in that district and at least once in English in an English newspaper circulating in that district. [Section 640 B].

 

4.          Forward three copies of the general notice published in the newspaper to the Stock Exchange with which the shares of your company are listed. [Clause 31(e) of the Standard Listing Agreement].

 

5.          Forward to the Stock Exchange with which the shares of your company are listed, a copy of the proceedings of the General Meeting and three copies of the notice of the General Meeting. [Clause 31(c) and (d) of the Standard Listing Agreement].

 

6.          Make the application in Form No. 25A within ninety days from the date of appointment and enclose the following:­

 

(a)         A certified true copy of the existing and proposed agreement in this regard, if any;

 

(b)         A certified true copy of the resolution passed;

 

(c)         A certified true copy of the audited balance‑sheet and the profit and loss account of the company for the last two years;

 

(d)         Where the company has not yet commenced any business or whose accounts have not been audited:

 

(i)          a certified true copy of the prospectus, if issued;

(ii)         particulars of capital proposed;

(iii)         amount of long‑term loans and sources of such loans;

(iv)        expected date of commencement of production/business;

(v)         estimated turnover and profit for the next three years;

(vi)        details of industrial licence, if any;

(vii)        extent of foreign collaboration, if any;

 

(e)         A certified true copy of the Memorandum and Articles of Association revised up‑to‑date marking the relevant Article or the authority under which the appointment is made;

 

(f)          Certified true copies of the notices published in the newspaper(s) certified by the company to have been duly published;.

 

(g)         A treasury challan or demand draft evidencing the payment of requi­site fee prescribed under the Companies (Fees on Applications) Rules, 1999. Fees will be paid in double as the prescribed Form con­sists of two approvals, one for appointment and payment of remunera­tion and another for payment of minimum remuneration and therefore equivalent to making two applications;

 

(h)         Send a copy of the application along with all the documents to the concerned Registrar of Cornpanies [Rule 20A].

 

7.          If the application fee is paid by way of treasury challan, then pay the req­uisite fee of minimum Rs. 500/‑ and maximum of Rs. 2000/‑, as the case may be, as prescribed by the Companies (Fees on Applications) Rules, 1999, by way of treasury challan prepared in triplicate and paid into any of the specified branches of the Punjab National Bank'o for credit.

 

8.          The description of the Head of account of the treasury challan should be as prescribed under Rule 22(2) of the Companies (Central Government's) General Rules and Forms, 1956 and as amended vide GSR 251(E), dated 21‑6‑1996 (w.e.f. 21‑6‑1996). For account head and code please see Rule 22(2) in Appendix 1.

 

9.          Two copies of the challan will be given back to the depositor by the said branch of the bank and, the original copy should be filed along with the documents mentioned in item 6.

 

10.        If the application fee is paid by way of demand draft, then draw the demand draft in favour of "Pay and Accounts Officer, Department of Company Affairs, New Delhi", and payable at any bank located in New Delhi, and the said demand draft should be filed along with the documents mentioned in item 6.

 

11.        Send to every member within twenty‑one days of the passing of the Board resolution an abstract of the terms of the contract. [Section 302(7)].

 

12.        Please keep in mind that if any, default is made in complying with the aforesaid requirement, the company and every officer of the company who is in default will be punishable with fine upto Rs. 10,000/‑. [Section 302(5)]

            

13.        It is usual to hold the General Meeting after the approval of the Central Government is received.

 

14.        If the General Meeting is held earlier, the resolution should preferably provide for modification of the terms by the Board of directors so that the need to hold another General Meeting for adopting the modifications is avoided if the Central Government varies the terms.

 

15.        Where the Articles of Association of the company do not have any provision for the appointment of a Whole‑Time or Managing Director, it is necessary to alter the Articles of Association accordingly vide Topic 26.

 

16.        Note that as per the Citizen's Charter of the Department of Company Affairs, the application to the Central Government will be processed within 30 days. [No. 5/25/99‑CL‑V, Press Note No. 9/99, dated 9‑8‑1999].

 

17.        Further note that if your company's paid‑up share capital is less than Rs. 50 lakhs but is equal to or more than Rs. 10 lakhs, your company is required to obtain a Compliance Certificate from a secretary in whole‑time practice to be filed with the Registrar of Companies mentioning therein that the form as mentioned in Annexure B of the certificate has been duly filed with the Central Govemment and that the appointment of director has been duly made as per paragraph 14 of the Form of Compliance Certificate appended to the Companies (Compliance Certificate) Rules, 2001.[Section 383‑A(1) proviso]

 

Topic 67

 

DO YOU WISH TO APPLY FOR APPOINTMENT OF A GOVERNMENT DIRECTOR? (STEPS TO BE TAKEN BY MIEMBERS)

 

1.          Make your application to the Company Law Board, Principal Bench, New Delhi, or to the Additional Principal Bench Chennai as the case may be, by way of a petition to be prepared in Form No. 1 in Annexure II to the Company Law Board, Regulations, 1991 and annex thereto the following:

 

(i)          Documentary and/or other evidence in support of the statements made in the petition, as are reasonably open to the petitioner.

 

(ii)         Documentary evidence in proof of the eligibility and status of the petitioner with the voting power held by each of them.

 

(iii)         Affidavit verifying the aforesaid petition.

 

(iv)        Demand draft evidencing payment of the fee of Rs. 2,500/-.

 

(v)         Certified true copy of the Memorandum and Articles of Association of the company.

 

(vi)        Certified true copy of the latest audited balance‑sheet and profit and loss account with the Directors' and Auditors' Reports.

 

(vii)        Memorandum of Appearance in Form No. 5 of the Company Law Board Regulations, 1991 with a certified true copy of the authorisation from the individual members who are applicants or the executed Vakalatnama, as the case may be. If the member is a company then certified true copy of the board resolution of that company.

 

(viii)       Original acknowledgment of the concerned Registrar of Companies.

 

2.          The affidavit should be prepared on a non‑judicial stamp paper of the req­uisite value prevalent in the State and should be either notarised by the Notary Public or sworn before the Oath Commissioner.

 

3.          The said affidavit should be drawn up in first person and shall state the full name, age, occupation and complete residential address of the deponent and shall be signed by the deponent. [Regulation 14(5) of the Company Law Board Regulations, 1991].

 

4.          If the deponent is not personally known to the person, before whom the affidavit is sworn, he shall be identified by a person who is known to the person before whom the affidavit is sworn. [Regulation 14(6) of the Company Law Board Regulations, 1991.

 

5.          The said affidavit should clearly and separately indicate the statements which are true to the knowledge of the deponent, information received by the deponent belief of the deponent and information based on legal advice. [Regulation 14(7) of the Company Law Board Regulations, 1991].

 

6.          The affidavit shall also include the name and complete residential address of the person from whom the information has been received by the deponent and whether the deponent believes that information to be true or not, where any statement is stated to be true to the information received by the deponent. [Regulation 14(8) of the Company Law Board Regulations, 1991].

 

7.          Please ensure that the aforesaid petition is written, type‑written, cyclostyled or printed, neatly and legible on one side of the substantial paper of foolscap size in double space and separate sheets shall be stitched together and every page consecutively numbered. Numbers and dates specified therein should be expressed in figures as well as in words. [Regulation 11 of the Company Law Board Regulations, 1991].

 

8.          The petition should be divided into separate paragraphs which should be numbered serially and shall state thereon the matter and the name of the company to which it relates. [Regulation 12 of the Company Law Board Regulations, 1991].

 

9.          Please also ensure that the aforesaid petition is presented by the petitioner in original and four extra copies thereof in person or through authorised representative to the office of the Bench or be sent by registered post with acknowledgement due addressed to the Secretary or Bench officer of the Bench concemed, as the case may be. [Regulation 14(1) of the Company Law Board Regulations, 1991].

 

10.        Affix court fee stamps of the requisite value 4 on the original petition, be­fore submission.

 

11.        Please furnish a copy of the complete set of the petition to the concerned Registrar of Companies before filing it with the Company Law Board and attach a photocopy of his endorsement to the petition. [Regulation 14(3) of the Company Law Board Regulations, 1991].

 

12.        Please furnish a copy of the complete set of the petition to the Central Government, Department of Company Affairs, Shastri Bhavan, 5th Floor, 'A' Wing, Dr. Rajendra Prasad Road, New Delhi, before filing it with the' Company Law Board and attach a photocopy of their endorsement to the petition. [Regulation 14(3), second proviso of the Company Law Haard Regulations, 1991].

 

13.        Pay the filing fee of Rs. 2,500/- as per Rule 3 read with Rules 4 and 5 of the Company Law Board (Fees on Applications and Petitions) Rules, 1991, by way of demand draft drawn in favour of Pay and Accounts Officer, Department of Company Affairs, New Delhi and payable at New Delhi.

 

14.        Ensure that the petition is made by not less than one hundred members of the company or by members of the company holding not less than one‑tenth of the total voting power therein. [Section 408(1)].

 

15.        Also ensure that the petition explains the circumstances under which the appointment of Government Directors is necessary to prevent the affairs of the Company being conducted either in a manner which is oppressive to any members of the company or in a manner which is prejudicial to the interests of the Company or to public interest.

 

16.        Also ensure that the petition sets forth the name of the company, with its status, date of incorporation, the address of its registered office, authorised capital, paid up capital with division of different classes of shares and terms of issue, if any, in the case of preference shares, main objects in relief for which the company is formed, present business activities of the company and should also set forth the grounds for making the petition and the nature of reliefs prayed for. [Regulation 16 of the Company Law Board Regulations, 1991].

 

17.        Ensure that the petition is based upon a single cause of action and seeks one or more reliefs provided that they are consequential to one another. [Regulation 20 of the Company Law Board Regulations, 1991].

 

18.        Actually the concerned Bench Office is required to serve a copy of a complete set of the petition on all the respondents but in actual practice to save time, the petitioner should serve a copy of the complete set of the petition on all the respondents by registered A/D post.

 

19.        After such service the petitioner should file an affidavit attaching original postal receipts to the effect that a copy of the complete set of petition has been duly served on all the respondents.

 

Topic 68

 

DO YOU WISH TO APPOINT DIRECTORS BY PROPORTIONAL REPRESENTATION IN YOUR PUBLIC COMPANY OR ITS SUBSIDIARY?

 

1.          Consult the Articles of Association of your company to see whether they authorise the appointment of directors by proportional representation; otherwise, complete proceedings to alter them accordingly vide Topic 26.

 

2.          State in the Articles of Association that not less than two‑thirds of the total number of your directors shall be appointed according to the principle of proportional representation, whether by a single transferable vote or by a system of cumulative voting or otherwise, the appointment being made once in every three years and casual vacancies being filled as usual under Section 262.

 

3.          The precise mode of such proportional representation has to be spelt out in the Articles of Association. [Section 265].

 

4.          In cumulative voting system several directors are voted for at the same time by casting votes for the total number of shares multiplied by the number of directors to be elected i.e. each shareholder for one share has as many votes as there are directors to be elected.

 

5.          A shareholder in respect to each share can give all votes due from him to a single candidate or distribute it between two or more candidates. Thus the majority group can cast all their votes in favour of one candidate and secure his election.

 

6.          There are two main systems of proportional voting which provides for representation also of minority viz., (i) cumulative voting, and (ii) voting by single transferable vote. These are explained below.

 

7.          Cumulative voting is the system by which several directors are to be voted for at the same time by casting votes for the whole number of shares held multiplied by the number of directors to be elected for a candidate or distributing the votes among a part of the vacancies to be filled instead of straight voting or casting votes according to the number of shares held, for all the vacancies.

 

8.          Thus a minority is allowed to secure representation on the Board of direc­tors.

 

9.          Without a cumulative voting a bare majority of the shareholders may elect the full Board and thus the control of the company could be exercised without having representatives of the minority on the Baord.

 

Examples : Suppose there are 1000 shares, 800 shares from a majority group and the other 200 shares from a minority group. The shareholders have to elect five directors to the Board. A, B, C, D and E are nominated by the majority group and F is nominated by the minority group. Since five directors have to be elected, each shareholder has five votes for holding one share. Shareholders, in respect of each share, can give all the five votes to a single candidate or distribute it to two or more candidates.

 

Total votes castwill be: 1000 x 5 = 5000

 

Total number of vacancies : 5

 

Each candidate receiving = 5000/5 =           1000 votes

 

or more shall be deemed to be elected to the Board although those who get less may also be considered elected. Therefore, the result will depend on the cumulative voting secured.

 

The minority group can cast all their votes in favour of F. F will get 200 x 5 = 1000 votes.

 

A, B, C, D and E will together get 800 x 5 = 4000 votes. Average votes for each of the candidates in this group will be 4000/5 = 800 votes. Each and everybody among A, B, C, D and E cannot get more than 800 votes. If any of them gets single additional vote i.e. 801 votes, another of them will get less than 801 votes. If the minority concentrates on one candidate, he is very likely to get elected unless the minority is negligible.

 

10.        Under the system of voting by single transferable vote all the names of the candidates for election are entered in the ballot paper. Each voter has only one vote.

 

11.        Each voter has to indicate his first, second, third preferences and so on by marking in the ballot paper for the candidates.

 

12.        The above mentioned preferences will be equal to the number of candi­dates to be elected.

 

13.        In the first instance, only the first preferences are counted and any candi­date who receives the number of votes called "quota" is declared elected.

 

14.        The quota is calculated as follows :­

 

The quota is = Total number of votes polled / (Number of candidates to be elected + 1) + 1

 

15.        If there are four candidates to be elected as directors and the votes polled are 500, then the quota is 500/(4+1) +1 = 101

 

16.        If four candidates get 101 votes each they will get elected. They will together get 404 votes. The balance is 96 votes. Even if all their remaining votes go to a single candidate, he cannot be elected.

 

17.        Every person who can obtain the support of 101 votes among 500 votes will surely get elected as a director.

 

18.        If a person obtains more than the quota number of votes, the surplus votes in his favour will be transferred to other candidates in order of preference.

 

19.        The surplus vote are added to the first preference votes obtained by the candidates until some of them also get the quota number of votes.

 

20.        The aforesaid process is repeated until all the required number of candi­dates for the directorate obtain the quota number of votes.

 

21.        When the candidates do not get the quota number of votes even after distribution of surplus votes the candidate who has obtained the least number of first preference is eliminated.

 

22.        The second preferences on these ballot papers are transferred to other can­didates against whose names they are marked.

 

23.        Thus the aforesaid process is repeated until sufficient number of candi­dates get the quota number of votes.

 

Example : Let it be assumed that five directors are to be elected and seven candidates A, B, C, D, E, F and G are contesting.

 

The first preferences are counted

 

  A gets 200 votes

B gets 95 votes

C gets 93 votes

D gets 74 votes

E gets 60 votes

F gets 58 votes

G gets 20 votes

 

Total 600 votes. The quota is 600/(5+1) + 1 = 101

 

A gets more than the quota and he is declared elected, and if A has surplus 99 votes in his favour, his papers are scrutinised and the second preference found in them are counted.

 

It is found that second preference   on D are= 25

on E are = 5

on F are = 10

on G are = 60

Total : 200

 

Surplus first preference of A

 

to be transferred to D 25/(200) x 99 = 12

            

to be transferred to E 5/(200) x 99 = 2

 

to be transferred to F 10/(200) x 99 = 4

            

to be transferred to G 160/(200) x 99 = 2

            

Total votes of A transferred = 99

 

Now the poll is :-

 

A =       200

B =        95

C =       93

D =       74 + 12 =           86

E =        60 + 2 =             62

F =        58 + 4 =             62

G =       20 + 81 =           101

 

G gets the quota and he is deemed to be elected. There is no surplus vote in favour of G. F who has got the lowest first preference is eliminated. His 58 papers are scrutinised and the second preference in favour of 

 

B =        6

do         D =       16

             do         E =        30

             C=        6

             58

 

After transferring 2nd preference in F's papers to the appropriate candidate the poll is :-

 

A =                                  200

B =        95 + 6 =             101

C =       93 + 3 =             96

D =       86 + 16=            102

E =        62 + 30 =           92

F =                                  62

G =                                  101

 

B and D get elected having obtained the quota. Now E who has got the next lowest first preference of 60 is eliminated. His ballot papers are scrutinised and it is found that there are 27 second preferences on C. These are ordered C's votes. Now C's votes will be 99 + 27 = 126

 

The final poll will be :-

 

A =       200

B =        101

C =       126

D =       102

E =        62 (eliminated)

F =        62 (eliminated)

G =       101

 

A, B, C, D and G are elected as directors.

 

24.        By these systems, a majority of 51 % or more of the shareholders cannot monopolise all the directorships. A minority of respectable strength is enabled to elect their representatives and while the minority is given representation, the majority still elects directors proportionate to their strength.

 

25.        File Form No. 29 within thirty days of his appointment with the concerned Registrar of CompanieS [Section 264(2)] after paying the requisite fee as prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury challan. [Rule 22].

 

26.        File Form No. 32 in duplicate within thirty days of his appointment with the concerned Registrar of Companies [Section 303(2)], after paying the requisite fee prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury challan. [Rule 22].

 

27.        Make necessary entries in the Register of Directors and in the Register of Directors Shareholdings. [Sections 303(1) & 307].

 

28.        Please keep in mind that if default is made in complying with the aforesaid requirements, the company and every officer of the company who is in default will be punishable with fine upto Rs. 500/- for every day during which the default continues in case of contravention of section 303(1) and in case of contravention of section 307(1) with fine upto Rs. 50,000/- and also with a further fine of Rs. 200/- for everyday during which the default continues. [Section 303(3) read with Section 307(8)]

 

29.        Follow the procedure as stated in item 27 of Topic 59.

 

30.        Note that if your company's paid‑up share capital is less than Rs. 50 lakhs but is equal to or more than Rs. 10 lakhs, your company is required to obtain a Compliance Certificate from a secretary in whole‑time practice to be filed with the Registrar of Companies mentioning therein that the registers have been kept and maintained as stated in Annexure A of the Certificate, the forms have been duly filed with the Registrar of Companies as stated in Annexure B of the certificate and the appointment of director has been duly made as per paragraphs 1, 2 and 14 of the Form of Compliance Certificate appended to the Companies (Compliance Certificate) Rules, 2001. [Section 383‑A(1) proviso]

 

Topic 69

 

DO YOU WISH TO APPOINT A DIRECTOR OR HIS RELATIVE ETC. TO AN OFFICE OR PLACE OF PROFIT IN YOUR COMPANY OR ITS SUBSIDIARY?

 

1.          Take a declaration in writing from the individual, being proposed to be appointed to any office or place of profit carrying a total monthly remuneration of ten thousand rupees or more [Rule 10C(1)] stating that he is connected with a director in any of the ways mentioned in Section 314(1)(b). [Section 314(2A)].

 

2.          Convene a Board Meeting after giving noticet to all the directors of the company as per Section 286 to consider the proposal and to fix up the date, time, place and agenda for the General Meeting to pass Special Resolutiont taking the consent for holding the office or place of profit. [Section 314].

 

3.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meetings as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/‑. [Section 286(2)]

 

4.          Such consent can also be accorded in the General Meeting held for the first time after the holding of such office or place of profit where a relative or a partner of a director has been appointed to such office or place of profit without the knowledge of the director concerned.

 

5.          The aforesaid consent can be obtained within three months of such appointment even if the first General Meeting has been held earlier than that. [Section 314(1), First and Second Provisos].

 

6.          However, if the persons mentioned in Section 314(1B)(a) are appointed to any office or place of profit carrying total monthly remuneration of not less than Rs. 20,000/‑ [Rule 10C(2)], prior consent of the company in General Meeting by Special Resolution and approval of the Ceiftral Government is necessary.

 

7.          No such declaration need be obtained and no such Special Resolution need be passed if the individual is a relative of a director who does not hold any office or place of profit in the company. [A.R. Sundarsanam v. Madras Pursawalkam Hindu Janopakara Saswatha Nidhi Ltd., (1985) 57 Com Cases 776 (Mad)].

 

8.          Apply to the Central Government in Form No. 24W along with the fol­lowing documents or papers:­

 

(a)         A certified true copy of the Special Resolution passed by the Company.

 

(b)         A treasury challan or demand draft evidencing the payment of the requisite fee, prescribed under the Companies (Fees on Applications) Rules, 1999.

 

(c)         A certified true copy of annual accounts together with directors' and auditors' reports for the last three financial years.

 

(d)         A copy of the rules of the company relating to terms and conditions in regard to perquisites as applicable to its employees. If there are no rules, a certificate from the secretary or a director of the company to the effect that similar perks at the same rates are being paid to other employees of the company in the equivalent grade.

 

9.          If the application fee is paid by way of treasury challan, then pay the req­uisite fee of minimum Rs. 500/‑ and maximum of Rs. 2000/‑, as the case may be, and as prescribed by the Companies (Fees on Applications) Rules, 1999, by way of treasury challan prepared in triplicate and paid by cash into any of the speci­fied branches of the Punjab National Bank for credit.

 

10.        The description of the Head of account of the treasury challan should be as prescribed under Rule 22(2) of the Companies (Central Government's) General Rules and Forms, 1956 and as amended vide GSR 251(E), dated 21‑6‑1996 (w. ef 21‑6‑1996). For account head and code please see Rule 22(2) in Appendix 1.

 

11.        Two copies of the challan will be given back to the depositors by the said branch of the bank and the original copy should be filed with the form mentioned in item 8.

 

12.        If the application fee is paid by way of demand draft, then draw the de­mand draft in favour of "Pay and Accounts Officer, Department of Company ­Affairs, New Delhi", and payable at any bank located in New Delhi, and the said demand draft should be filed along with the form mentioned in item 8.

 

13.        Deliver a copy of the application along with a copy of all enclosures to the concerned Registrar of Companies.

 

14.        No such application need be made to the Central Government if the incumbent is not in receipt of remuneration month by month, every month. [Ravinder Kumar Sangal v. Auto Lamps Ltd., (1984) 55 Comp Cas 742 (Delhi)].

 

15.        Issue noticest in writing at least twenty‑one days before the general meeting along [Section 17(1) read with section 173(2)] with suitable Explanatory Statement.

 

16.        Hold the General Meeting, and pass the Special Resolution by three fourths majority. [Section 189(2)].

 

17.        Forward three copies of notices issued to the shareholders and a copy of the proceedings of the General Meeting to the Stock Exchange with which the shares of your company are listed. [Clause 31(c) and (d) of the Standard Listing Agreement].

 

18.        File a copy of the Special Resolution with Explanatory Statement in Form No. 23 with the concerned Registrar of Companies within thirty days of the passing [Section 192] after paying the requisite fee prescribed under Schedule X to the Act, either in cash, demand draft or treasury challan. [Rule 22].

 

19.        Please keep in mind that, if default is made in complying with the aforesaid requirement, the company and every officer of the company who is in default will be punishable with fine of upto Rs. 200/‑ for every day during the default continues. [Section 192(5)]

 

20.        If a relative of a managing director or a whole‑time director is appointed to an office or place of profit carrying a monthly remuneration of Rs. 20,000/‑ or more, then approval of the Central Government will not be necessary under Section 314 (1B) since such approval is already taken under Sections 198, 269, 310 or 311 but the special resolution required under Section 314 (1B) will have to be passed by the company. [Vide Circular No. 14/75 [8/12/314 (1B)]/75‑CL‑V, dated 5‑6‑1975].

 

Note.‑   If a director receives remuneration for performing functions of his office, the provisions of Section 314 will not apply. In case the director, his relative, partner or other individual, firm or company [as mentioned in Section 314(1)] is appointed to such an office or place, then the said provisions will only apply if the total monthly remuneration amounts to rupees five hundred or more in each case. Where office or place of profit is held by a director on the company's subsidiary, then also these provisions will not apply if the remuneration so received is paid over to the company or its holding company. The provisions of Section 314 also do not apply in respect of appointment of a managing director, manager, banker or trustee for the debenture holders of the company. Any remuneration for services rendered by any managing or whole‑time director for services rendered by him in any other capacity shall not be included in his remuneration calculated as per provisions of Section 198. [Section 309(1), Proviso].

 

21.        Note that as per the Citizen's Charter of the Department of Company Affairs, Schedule I Serial No. 10, the application will be processed within 30 days. [No. 5/25/99‑CL‑V; Press Note No. 9/99, dated 9‑8‑1999]

 

22.        Further note that if your company's paid‑up share capital is less than Rs. 50 lakhs but is equal to or more than Rs. 10 lakhs, your company is required to obtain a Compliance Certificate from a secretary in whole‑time practice to be filed with the Registrar of Companies mentioning therein that the forms have been duly filed with the Registrar of Companies and Central Government as stated in Annexure B of the certificate and the company has obtained necessary approvals from the Board of Directors and members of your company pursuant to section 314 and that the appointment of director has been duly made as per paragraphs 2, 11 and 14 of the Form of Compliance Certificate appended to the Companies (Compliance Certificate) Rules, 2001. [Section 383‑A (1) proviso]

 

Topic 70

 

DO YOU WISH TO INCREASE OR REDUCE THE NUMBER OF DIRECTORS ON YOUR COMPANY'S BOARD?

 

A.          In case a reduction in number is proposed :

 

1.          In the case of a private company or a deemed public company [section 43A], the number of directors should not go below two, and in the case of any other public company three. [Section 252].

 

2.          The Articles of Association may provide for an even higher number of minimum directors, and in that case, the number cannot go below that unless the Articles are altered accordingly vide Topic 26.

 

3.          Obtain resignation from the director to vacate office or pass an ordinary resolution to reduce the number under Section 258 or remove him under section 284 as per Topic 71, and keep in mind that the resignation takes effect from the date of resignation. [S. B. Shankar v. Amman Steel Corporation, (2002) 110 Comp. Cas. 50].

 

4.          In any case, file with the concerned Registrar of Companies the particulars regarding change in the number of directors in Form No. 32 in duplicate within thirty days of such change [Section 303] after paying the requisite fee prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury challan. [Rule 22].

 

5.          Please keep in mind that if default is made in complying with the aforesaid requirement, the company and every officer of the company who is in default will be punishable with fine upto Rs. 500/- for every day during which the default continues. [Section 303(3)]

 

7.          If the shares of your company are listed on a recognised Stock Exchange, promptly notify to it such change in the number of directors. [Clause 30(a) of the Standard Listing Agreement].

 

8.          See that the director notifies the change so occurred to other companies in which he is a director, managing director, manager or secretary within twenty days. [Section 305].

 

9.          Please keep in mind that if the said director does not notify as above, he will be punishable with fine upto Rs. 5000/- [Section 305(1)]

 

B.          In case an increase in number is proposed

 

1.          The number of directors cannot be increased exceeding the limit fixed by the Articles of Association unless they are suitably altered.

 

2.          In the case of a public company, or any of its subsidiary company, an increase in the number of directors cannot be made even by altering Articles of Association except with the previous approval of the Central Government:

 

(a)         in the case of a company which was in existence on the 21st day of July, 1951, an increase which was within the permissible maximum under its Articles of Association as in force on that date; and

 

(b)         in the case of a company which comes or may come into existence after that date, an increase which is within the permissible maximum under its Articles of Association as first registered if the increase is beyond the number of twelve [Section 259].

 

3.          For the increase within the number twelve make only the necessary changes in the Articles of Association by Special Resolutions, if any, vide Topic 26.

 

4.          Government directors appointed under Section 408 and nominee directors of certain financial institutions governed by special statutes which dispense with the requirements of these provisions of the Act, will not be taken into account while counting the number of directors for the above purpose.

 

5.          In case the number of directors is exceeded beyond twelve irrespective of whether the said number is fixed by the Articles of Association of the company or not:

 

(i)          Convene a Board Meeting after giving noticet to all the directors of the company as per Section 286 to consider the increase in number beyond the limits stated in item I above, and fix up the date, time, place and agenda for convening a General Meeting to (a) pass an Ordinary Resolution, and (b) appoint director as per Topic 59 both effective from the date of approval of the Central Government;

 

(ii)         Issue notices in writing at least twenty‑one days before the date of the General Meeting proposing the Ordinary Resolution with suitable Explanatory Statements. [Section 171(1) read with section 173(2)];

 

(iii)         Forward three copies of such notice to the Stock Exchange with which the shares of your company are listed. [Clause 31(c) of the Standard Listing Agreement];

 

(iv)        Hold the General Meeting and pass the Ordinary Resolution by simple majority. [Section 189(1)];

 

(v)         Forward a copy of the proceedings of the General Meeting to the Stock Exchange with which the shares of your company are listed. [Clause 31(d), of the Standard Listing Agreement];

 

(vi)        Where an application is to be made to the Central Government:­

 

(a)         Give general noticet to all the members indicating the nature of the application to be made to the Central Government;

 

(b)         Publish the aforesaid notice at least once in a newspaper of the principal language of the district in which the registered office of the company is situate and circulating in that district and at least once in English language in an English newspaper circulating in that district. [Section 640B];

 

(c)         Make the application in Form No. 24 and enclose the following:

 

(i)          Certified true copies of each of the Memorandum and Articles of Association and of those which were in force on 21st July, 1951 or, if the company came into existence later on, then on the date of its registration;

 

(ii)         A certified true copy of the Ordinary Resolution passed and the full proceedings of the General Meeting with full details about votings in a separate sheet;

 

(iii)         A treasury challan or demand draft evidencing the payment of requisite fee prescribed under the Companies (Fees on Applications) Rules, 1999;

 

(iv)        Certified true copies of the notices together with a certificate by the company as to the due publication thereof,

 

(d)         Forward three copies of the general notice published in the newspapers to the Stock Exchange with which the shares of your company are listed. [Clause 31(e) of the Standard Listing Agreement];

 

(e)         Send a copy of the application along with a copy of all the documents enclosed to the application to the concerned Registrar of Companies. [Rule 20A].

 

6.          The appointment of the director made in the General Meeting stated above will be effective only on receipt of the approval of the Central Government.

 

7.          Alternatively, the appointment of the director may not be made at that meeting; but on receipt of the Government's approval, it may be made in the Board Meeting as an additional director under Section 260 as per Topic 61.

 

8.          The aforesaid procedure is to be followed only by public companies and their subsidiaries.

 

9.          If the application fee is paid by way of treasury challan, then pay the requisite fee of minimum Rs. 500/‑and maximum Rs. 2000/‑, as the case may be, and as prescribed by the Companies (Fees on Applications) Rules, 1999, by way of treasury challan prepared in triplicate and paid in cash into any of the specified branches of the Punjab National Bank 12 for credit.

 

10.        The description of the Head of account of the treasury challan should be as prescribed under Rule 22(2) of the Companies (Central Government's) General Rules and Forms, 1956 and as amended vide GSR 251(E), dated 21‑6‑1996 (w.e.f. 21‑6‑1996). For account head and code please see Rule 22(2) in Appendix 1.

 

11.        Two copies of the challan will be given back to the depositor by the said branch of he bank and the original copy should be filed with the documents mentioned in item 5(vi)(c).

 

12.        If the application fee is paid by way of demand draft, then draw the demand draft in favour of "Pay and Accounts Officer, Department of Company Affairs, New Delhi", and payable at any bank located in New Delhi, and the said demand draft should be filed along with the documents mentioned in item 5(vi)(c).

 

13.        In case the number of directors exceed twelve and the Articles of Associa­tion of the company have fixed the number at less than twelve,­

 

(i)          Follow the steps given in item 5 of this Topic except that instead of Ordinary Resolution, there will be a Special Resolution to alter the Articles of Association to first have the number of directors more than twelve.

 

(ii)         File the Special Resolution with Explanatory Statement with the concerned Registrar of Companies in Form No. 23 within thirty days of its passing [Section 192] after paying the requisite fee prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury challan. [Rule 22].

 

14.        Please keep in mind that if the Special Resolution is not filed as aforesaid, the company and every officer of the company who is in default will be punishable with fine upto Rs. 200/‑ for every day during which the default continues. [Section 192(5)]

 

15.        In any other case:­-

 

Either appoint the director as an additional director under Section 260 as per Topic 61 or appoint him in the General Meeting as per Topic 59 and complete the respective formalities as stated in the said respective Topics.

 

16.        If your company is a Government company then provisions of Section 259 will not apply to your company.

 

17.        Note that, as per the Citizen's Charter of the Department of Company Affairs, Schedule I Serial No. 8, the application made to the Central Government is to be processed within 30 days. [No. 5/25/99‑CL‑V,‑ Press Note No. 9/99, dated 9‑8‑1999.

 

Topic 71

 

DO YOU WISH TO REMOVE A DIRECTOR?

 

1.          Note that the following directors cannot be removed unless otherwise specifically stipulated in the terms of their appointment. [Section 284(1) and proviso and sub‑section (7)(b)] :

 

(a)         In the case of a private company, a director who is holding office for life on the 1st day of April, 1952;

 

(b)         All the directors, where the company has adopted the proportional representation method of appointment of directors in accordance with Section 265;

 

(c)         A director appointed by the Central Government under Section 408;

 

(d)         A director appointed by the Industrial Finance Corporation or a State Financial Corporation [Section 25(2)] under the Industrial Finance Corporation Act, 1948 and Section 27(2) of the State Financial Corporation Act, 1951] or any other financial institution where the Act constituting such financial institution makes a similar provision.

 

2.          For removing any other director, obtain a special noticet from a member proposing an Ordinary Resolution for removing the director. [Section 284(2)]. Such special notice must comply with the provisions of Section 188 of the Act. Pedley v. Inland Waterways Association Ltd., (1977) 1 All ER 209 (Ch D).

 

3.          Forthwith send a copy of the special noticet to the director concerned.[Section 284(3)].

 

4.          Issue noticesf of the General Meeting in writing at least twenty‑one days before the meeting stating about the special notice and proposing the Ordinary. Resolution for removal. [Section 171(1) read with section 173(2)].

 

5.          State in the notice the fact about representations, if any, made by the di­rector concerned and enclose the copy of the representation.

 

6.          If the representation could not be sent along with the notice for the reason of having been received late, send the same later on. [Section 204(4)].

 

7.          Forward three copies of the notice to the recognised Stock Exchange with which the shares of your company are listed. [Clause 31(c) of the Standard Listing Agreement].

 

8.          Hold the General Meeting and pass the Ordinary Resolutiont by simple majority. [Section 189(1)].

 

9.          If the representations were not sent to the members earlier for the reason that they were received too late or because of default of the company, read out the same in the meeting if the director concerned so requires.

 

10.        The director concerned has also the right to be heard at the meeting. But in certain circumstances, the Court can exempt the company from sending or reading out the representations. [Section 284(4)].

 

11.        Forward a copy of the proceedings of the General Meeting to the Stock Exchange with which the shares of your company are listed. [Clause 31(d) of the Standard Listing Agreement].

 

12.        Notify the change promptly to the Stock Exchange with which the shares of your company are listed. [Clause 30(a) of the Standard Listing Agreement].

 

13.        File Form No. 32 in duplicate with the concerned Registrar of Companie within thirty days of the change in the appointment of directors to notify the change [Section 303(2)] after paying the requisite fee prescribed under Schedule X to the Act, either in cash, or treasury challan. [Rule 22].

 

14.        Please keep in mind that if default is made in complying with the aforesaid requirement, the company and every officer of the company who is in default will be punishable with fine upto Rs. 500/- for every day during which the default continues. [Section 303(3)]

 

15.        See that the director so removed notifies the change to the other companies in which he is a director, managing director, manager, or secretary within twenty days. [Section 305].

 

16.        Please also keep in mind that if the said director does not do so, he will be punishable with fine upto Rs. 5000/‑. [Section 305(1)]

 

17.        A director can be removed in any other manner also if there is any specific condition in that regard in the terms of his appointment. [Section 284].

 

18.        Note that if a person functions as a director when he knows that the office of director held by him has become vacant, he will be punishable with fine upto Rs. 5000/‑ for each day on which he so functions as a director. [Section 283(1)(k) & (2A)]

 

Topic 72

 

DO YOU HAVE A CASE WHERE THE OFFICE OF A DIRECTOR STANDS VACATED UNDER SECTION 283?

 

1.          Verify the instances in which the office of a director becomes vacated as mentioned in Section 283(1)(a) to (1).

 

2.          If your company is a private company which is not a subsidiary of a public company, it may by its Articles of Association provide that the office of director shall be vacated on any grounds in addition to those specified in section 283(1)(a) to (b). [Section 283(3)]

 

3.          Convene a Board Meeting after giving noticel to all the directors of the company as per Section 286 and pass the necessary Resolution directing the Secretary of the company to inform the concerned director.

 

4.          Please keep in mind that if default is made in complying with the aforesaid requirement, the company and every officer of the company who is in default will be punishable with fine of upto Rs. 1000/‑. [Section 286(2)]

 

5.          Inform the director immediately about his vacating the office, by way of a letter.

 

6.          See that the office of the director gets vacated not before thirty days from the date of the adjudication, sentence or order, if the office of the director becomes liable to be vacated for any of the following three reasons, namely:

 

(i)          the director is adjudged an insolvent;

 

(ii)         the director is convicted by a court and sentenced to imprisonment for 6 months or more;

 

(iii)         the director becomes disqualified by an order of the Court restraining fraudulent persons from managing companies under Section 203. [Section 283(2)(a)].

 

7.          If in any of the above three cases an appeal is preferred, then see that the office of the director gets vacated not before seven days from the date on which such appeal is disposed of. [Section 283(2)(b)].

 

8.          If in any of these cases a further appeal is preferred within the aforesaid seven days, then see that such vacation takes place after such further appeal is disposed of. [Section 283(2)(c)].

 

9.          Please also keep in mind that if a person functions as a director when he knows that the office of director held by him has become vacant on account of any of the disqualifications specified in item 1 above, he will be punishable with fine upto Rs. 5000/- for each day on which he so functions as a director. [Section 283(2A)]

 

10.        File Form No. 32 in duplicate with the concerned Registrar of Companies within thirty days of the vacation of office of the director to notify the change [Section 303(2)] after paying the requisite fee as prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury challan. [Rule 22].

 

11.        Further keep in mind that if default is made in complying with the aforesaid requirements, the company and every officer of the company will be punishable with fine upto Rs. 500/- for every day during which the default continues. [Section 303(3)]

 

Topic 73

 

DO YOU WISH TO APPOINT A DIRECTOR OF YOUR SUBSIDIARY COMPANY?

 

1.          Check first whether your subsidiary company is a board controlled sub­sidiary under Section 4(1)(a) or a shareholding subsidiary under Section 4(1)(b).

 

2.          If your subsidiary is a board controlled subsidiary then do the following:

 

(a)         Check whether the Articles of Association of the subsidiary provide for the appointment of the majority of directors of that subsidiary and also remove. them.

 

(b)         If so, then convene a Board Meeting of the subsidiary after giving noticesl to the directors of the subsidiary as per Section 286 and pass a resolution appointing directors of your subsidiary.

 

3.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meetings as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/‑. [Section 286(2)]

 

4.          Once such directors are appointed they will hold office at the discretion of the Board of Directors of the holding company and need not face election or appointment by the general meeting of the subsidiary. Neither they will be required to retire by rotation.

 

5.          Within thirty days of such appointment your subsidiary company should file Form No. 32 in duplicate [section 303(2)] and Form No. 29 [section 264] with the concerned Registrar of Companies after paying the requisite fee prescribed under Schedule X to the Act either in cash, or treasury challan (Rule 22).

            

6.          Please also keep in mind that if default is made in complying with filing Form No. 32. as aforesaid, the company and every officer of the company who is in default will be punishable with fine upto Rs. 500/- for every day during which the default continues. [Section 303(3)]

 

7.          If the shares of your subsidiary company are listed on a recognised Stock Exchange, promptly notify to it the appointment of directors [Clause 30(a) of the Standard Listing Agreement].

 

8.          See that directors so appointed in the subsidiary notify such appointment to other companies in which they are directors, within twenty days. [Section 305]

 

9.          Please keep in mind that if the directors so appointed do not notify their appointments as above, the directors will be punishable with fine upto Rs. 5000/-. [Section 305(1)]

 

10.        Note that if your subsidiary company's paid‑up share capital is less than Rs. 50 lakhs but is equal to or more than Rs. 10 lakhs, then it is required to obtain a Compliance Certificate from a secretary in whole‑time practice to be filed with the Registrar of Companies mentioning therein that the forms as stated in Annexure B of the certificate have been duly filed with the Registrar of Companies and that the appointment of director has been duly made as per paragraphs 2 and 14 of the Form of Compliance Certificate appended to the Companies (Compliance Certificate) Rules, 2001 .[Section 383‑A (1) proviso]

 

Topic 74

 

DO YOU WISH TO APPOINT A NOMINEE DIRECTOR OF YOUR COMPANY TO BE ELECTED BY THE SMALL SHAREHOLDERS? [Section 252(1) Proviso read with the Cokipanies (Appointment of the Small Shareholders Director) Rules, 2001]

 

1.          Check first whether your company is a public company or not and if so whether the paid‑up share capital of your company is Rs. 5 crores or more or not.

 

2.          Further check whether your company has 1,000 or more small shareholders holding shares of nominal value of Rs. 20,000/‑ or less in your public company.

 

3.          If aforesaid is the case then your company may have at least one director of your company elected by the said small shareholders in the manner as given in the Companies (Appointment of the Small Shareholder Director) rules, 2001.

 

4.          Keep in mind that while appointing a small shareholder's director, your company may either act sue motu and elect such a director from amongst small shareholders or upon the notice of small shareholders who are not less than one tenth of the total small shareholders and have proposed the name of a person who shall also be a small shareholder of your company. [Rule 4(1) of the aforesaid Rules.]

 

5.          Where small shareholders of your company are proposing a person's name to be elected as a director, see that the notice of their intention for such proposal is left with your company at least 14 days before the meeting under the signature of at least 100 small shareholders specifying name, address, shares held and folio number and particulars of shares with differential rights to dividend and voting if any of the person whose name is being proposed for the post of director and of other small shareholders proposing such person as a candidate for the post of director of small shareholder (Rule 4(2) of the said Rules]

 

6.          Also see that the person whose name has been proposed for the post of small shareholders' director has signed and filed with your company his consent in writing to act as a director. [Rule 4(3) of the said Rules]

 

7.          Ensure, that the person proposed to be appointed as small shareholders' director of your company does not suffer from the following disqualifications:­

 

(i)          he has been found to be of unsound mind by a court of competent jurisdiction and the finding is in force;

 

(ii)         he is an undischarged insolvent;

 

(iii)         he has applied to be adjudicated as an insolvent and his application is pending;

 

(iv)        he has been convicted by a court of any offence involving moral turpitude and sentenced in respect thereof imprisonment for not less than 6 months and a period of 5 years has not elapsed from the date of expiry of the sentence;

 

(v)         he has not paid any call in respect of shares of the company held by him, whether alone or jointly with others and 6 months have elapsed from the last day fixed for the payment of the call; or

 

(vi)        an order disqualifying him for appointment as director has been passed by a Court in pursuance of section 203 and is in force unless the leave of the Court has been obtained for his appointment in pursuance of that section. [Rule 5 of the aforesaid Rules].

 

8.          Convene a Board Meeting after giving notices to the directors of your company as per section 286 to take the decision of the requirement of the aforesaid appointment and also to fix the date time and place of the General Meeting where such a director will be elected by the small directors.

 

9.          If your public company is a listed company then ensure that the resolution to appoint a nominee director under section 252(1) proviso is passed only through postal ballot. [Section 192A read with Rule 4(h) of the Companies (Passing of the Resolution by Postal Ballot) Rules, 2001.]

 

10.        Please keep in mind that every officer of the company whose duty is to give notice of Board Meetings as aforesaid and who fails to do so will be punishable with fine upto Rs. 1000/‑. [Section 286(2)]

 

11.        See that the number of directors including the director elected by the small shareholders of our company does not exceed the number of directors fixed by your company's Articles of Association.

 

12.        Issue notices at least twenty‑one days before the date of the General Meeting proposing the Ordinary Resolution with suitable Explanatory Statement. [Section 17(1) read with Section 173(2)]

 

13.        Hold the General Meeting and have the director elected by simple majority by the          small shareholders of your company, by passing an Ordinary Resolution.

 

14.        Ensure that the tenure of small shareholders' director is for a maximum period of years subject to meeting the requirement of the provisions of the Companies Act, 1956 except that he need not have to retire by rotation. [Rule 4(6) of the aforesaid Rules.

 

15.        Keep in mind that the same person if so desired by small shareholders, may be elected again for another period of 3 years on the expiry of his tenure. [Rule 4(7) of the aforesaid Rules].

 

16.        Send three copies of the notice and a copy of the proceedings of the General Meeting to the Stock Exchange with which the shares of our company are listed. [Clause 31(c) and (d) of the Standard Listing Agreement ]

 

17.        The person so appointed cannot act as a director unless he files his consent in Form No. 29 within thirty days with the concerned Registrar of Companies after paying the requisite fee prescribed under Schedule X of the Companies Act, 1956, either in cash, demand draft or treasury challan. [Rule 22].

 

18.        See that the director so appointed notified about his appointment to other companies in which he is a director, managing director or manager or secretary within twenty days. [Section 305]

 

19.        Please keep in mind that if such director does not do so, he will be punish­able with fine upto Rs. 5000/‑. [Section 305(1)]

 

20.        File Form No. 32 in duplicate within thirty days of his appointment with the concerned Registrar of Companies [Section 303(2)], after paying the ­requisite fee prescribed under Schedule X to the Act, either in cash, demand draft or treasury challan. [Rule 22]

 

21.        Make necessary entries in the Register of Directors and in the Register of Directors Shareholdings. [Section 303(1) & 307]

 

22.        Please keep in mind that if default is made in complying with the aforesaid requirements, the company and every officer of the company who is in default will be punishable with fine upto Rs. 500/- for every day during which the default continues in case of contravention of section 303(1) and (2) and in case of contravention of section 307(1) with fine upto Rs. 50,000/‑ and also with a further fine of Rs. 200/‑ for every day during which the default continues. [Section 303(3) read with section 307(8)]

 

23.        Take note of the provisions of Sections 253, 274, 275, 278 and 284 of the Companies Act, 1956 as regards disqualifications, disabilities, etc. of the person appointed as a director.

 

24.        Promptly notify to the Stock Exchange with which the shares of your company are listed the change in the company's directors. [Section 30(a) of the Standard Listing Agreement].

 

25.        Treat the small shareholders' director appointed as above as director for all other purposes except for appointment as whole‑time director or managing director [Rule 4(8) of the aforesaid Rules]

 

26.        Ensure that the small shareholders' director appointed as above does not hold office at the same time as small shareholders' director in more than two companies. [Rule 7 of the aforesaid Rules.]

 

27.        Note that if your company's paid‑up share capital is less than Rs. 50 lakhs but is equal to or more than Rs. 10 lakhs, your company is required to obtain a Compliance Certificate from a secretary in whole‑time practice to be filed with the Registrar of Companies mentioning therein that the registers have been kept and maintained as stated in Annexure A to the certificate, the forms have been duly filed with the Registrar of Companies stated in Annexure B of the Certificate and the appointment of director has been duly made as per paragraphs 1, 2 and 14 of the Form of Compliance Certificate appended to the Companies (Compliance Certificate) Rules, 2001. [Section 383‑A(1) proviso].

 

Topic 75

 

DO YOU HAVE A CASE WHERE THE OFFICE OF A SMALL SHAREHOLDERS'DIRECTOR STANDS VACATED?

 

1.          Verify the instances in which the office of a small shareholders' director becomes vacated as mentioned under Rule 6 (i) to (viii) of the Companies (Appointment of the Small Shareholders Director) Rules,2001.

 

2.          Convene a Board Meeting by giving notice to all the directors of your company as per section 286  and pass the necessary Resolutiont directing the Secretary of the your company to inform the concerned director.

 

3.          Please keep in mind that every offi6er of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine up to Rs. 1000/-. [Section 286(2)].

 

4.          Inform the director immediately about his vacating the office, by way of a letter.

 

5.          File with the concerned Registrar of Companies in Form No. 32 in duplicate within thirty days of the vacation of office of the small shareholders' director to notify the change,[Section 303(2)], after paying the requisite fee prescribed under Schedule X of the Companies Act, 1956, either by cash, demand draft or treasury challan. [Rule 22].

 

6.          Further keep in mind that if default is made in complying with the afore­ said requirement, the company and every officer of the company who is in ­default will be punishable with fine of up to Rs.500/‑ for every day during which the default continues. [Section 303(2)].

 

7.          Note the provisions of Rule 6 of the Companies (Appointment of the Small Shareholders' Director) Rules,2001 for vacation of office of a small shareholders' director as given below :

 

(i)          if such person so elected, as director of small shareholders ceases to be a small shareholder' director on and from such date on which he ceased to be a small shareholder;

 

(ii)         if he has been rendered disqualified by virtue of Rule 5(i) as being found to be of unsound mind by a Court of competent jurisdiction and the finding is in force;

 

(iii)         if he fails to pay any call in respect of shares of the company held by him, whether alone or jointly with others, within six months from the last date fixed for the payment of the call;

 

(iv)        if he absents himself from three consecutive meetings of the Board of Directors, or from all meetings of the Board of Directors for a continuous period of three months, whichever is longer, without obtaining leave of absence from the Board of Directors;

 

(v)         if he is a partner of any private company of which he is a director, accepts a loan, or any guarantee or security for a loan, from the company in contravention of section 295;

 

(vi)        if he acts in contravention of section 299;

 

(vii)        if he becomes disqualified by an order of Court under section 203;

 

(viii)       if he is removed in pursuance of section 284.

 

 

 

B. Managing/Whole‑time Director

 

(Topic 76 to Topic 80)

 

Topic 76

 

DO YOU WISH TO APPOINT ONE OF YOUR DIRECTORS TO BE A MANAGING DIRECTOR?

 

1.          Convene a Board Meeting after giving notice to all the directors of the company as per Section 286 and approve the draft agreement or the ten‑ns and conditions on which the managing director is proposed to be appointed and appoint the managing director and fix up the date, time, place and agenda of the General Meeting to pass an Ordinary Resolution or a Special Resolution for the appointment.

 

2.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meetings as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/-. [Section 286(2)]

 

3.          Note that if your company has a director appointed by your company's small shareholders', he cannot be appointed as a managing director. [Section 252(1) proviso read with Rule 4(8) of the Companies (Appointment of Small Shareholders' Director) Rules,2001.]

 

4.          Comply with the provisions of Sections 297 and 299 regarding disclosure of interest of directors etc. and in the case of public companies and their subsidiaries and holding companies those of Section 300 also regarding abstaining from discussion and voting etc.

 

5.          Please also keep in mind that if default is made in complying with the pro­visions of sections 299 and 300, every director who fails to comply will be pun­ishable with fine upto Rs. 50,000/‑. [Sections 299(1) & 300(4)]

 

6.          In the case of public companies and their subsidiaries, where the proposed managing director is already a managing director in another company, a Board resolutiont will be necessary, of which prior notice should have been given and all the directors present at the meeting should have consented to that resolution. [Section 316].

 

7.          Issue noticest in writing of the general meeting at least twenty‑one days before the date of the meeting along with the relevant explanatory statement. [Section 171(1) read with section 173(2)].

 

8.          Hold the General Meeting and appoint the managing director by passing an Ordinary Resolution by simple majority. [Section 189(1)].

 

9.          If the managing director to be appointed has not attained the age of 25 years but has attained the age of majority or if the proposed managing director has attained the age of 70 years then have the appointment approved by passing a Special Resolution without the approval of the Central Government. [Schedule XIII, Part I(C)].

 

10.        If special resolution is to be passed then hold the General Meeting and appoint the managing director by passing a Special Resolution by three fourths majority. [Section 189(2)].

 

11.        In the case of a public‑ company, or its subsidiary, the appointment in the Board Meeting and the General Meeting will be effective only on approval of the Central Government if the appointment is not made in accordance with the conditions specified in Parts I, Il and III of Schedule XIII to the Act.

 

12.        Where application is to be made to the Central Government as aforesaid, then do the following:

 

(a)         Give general noticet to all the members indicating the nature of the application to be made to the Central Government;

 

(b)         Publish the notice at least once in the regional language in a newspaper of the principal language of the district in which the registered office of the company is situated and circulating in that district and at least once in English in an English newspaper circulating in that district. [Section 640B];

 

(c)         Forward three copies of the general notice published in, the newspaper to the Stock Exchange if the shares of your company are listed on a recognised Stock Exchange. [Clause 31(e) of the Standard Listing Agreement];

 

(d)         Forward to the Stock Exchange with which the shares of your company are listed, a copy of the proceedings of the General Meeting and three copies of the notice of the General Meeting. [Clause 31(c) and (d) of the Standard Listing Agreement];

 

(e)         Make the application in Form No. 25A within ninety days from the date of appointment and enclose the following:

 

(i)          A certified true copy of the existing and proposed agreement in this regard, if any;

 

(ii)         A certified true copy of the Board as well as the General Meeting resolution;

 

(iii)         A certified true copy of the audited balance‑sheet and the profit and loss account for the last two years;

 

(iv)        Where the company has not yet commenced any business or whose accounts have not been audited :

 

(a)         a certified true copy of the Prospectus, if issued;

(b)         particulars of capital proposed;

(c)         amount of long term loans and sources of such loans;

(d)         expected date of commencement of production/business;

(e)         estimated turnover and profit for the next 3 years;

(f)          details of industrial licence, if any;

(g)         extent of foreign collaboration, if any;

 

(v)         A certified true copy of the Memorandum and Articles of Association revised up‑to‑date marking the relevant article or the authority under which the appointment is made;

 

(vi)        Certified true copies of the notices published in the newspaper(s) certified by the company as to the due publication thereof;

 

(vii)        A treasury challan or demand draft evidencing payment of requisite fee prescribed under the Companies (Fees on Applications) Rules, 1999.

 

13.        If the application fee is paid by way of treasury challan, then pay the req­uisite fee of minimum Rs. 500/‑ and maximum Rs. 2000/‑, as the case may be, and as prescribed by the Companies (Fees on Applications) Rules, 1999 by way of treasury challan prepared in triplicate and paid in cash into any of the specified branches of the Punjab National Bank for credit.

 

14.        The description of the Head of account of the treasury challan should be as prescribed under Rule 22(2) of the Companies (Central Government's) General Rules and Forms, 1956 and as amended vide GSR 251(E), dated 21‑6‑1996 (w.ef 21‑6‑1996). For account head and code please see Rule 22(2) in Appendix 1.

 

15.        Two copies of the treasury challan will be given back to the depositor and original copy should be filed along with documents mentioned in item 12(e).

 

16.        If the application fee is paid by way of demand draft, then draw the demand draft in favour of "Pay and Accounts Officer, Department of Company Affairs, New Delhi", and payable avany bank located in New Delhi, and the said demand draft should be filed along with the documents mentioned in item 12(e).

 

17.        Send a copy of the application along with all the documents to the con­cerned Registrar of Companies. [Rule 20A]

 

18.        Send an abstract of the ten‑ns of the contract to all the members within twenty‑one days from the date of entering into the contract and a memorandum clearly specifying the interest or concern of any other director in the contract, if any. [Section 302(2)]

 

19.        Forward promptly to the Stock Exchange with which the shares of your company are listed, three copies of the above abstract and memorandum. [Clause 31 (c) of the Standard Listing Agreement]

 

20.        File a certified true copy of the resolution of the Board or agreement executed and the Ordinary Resolution appointing the managing director with the concerned Registrar of Companies in Form No. 23 within thirty days of the passing or making thereof [Section 192], after paying the requisite fee as prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury challan. [Rule 22]

 

21.        Please keep in mind that if default is made, in complying with the afore­ said requirement, the company and every officer of the company who is in de­fault will be punishable with fine of upto Rs. 200/‑ for every day during which the default continues. [Section 192(5)]

 

22.        See that the managing director files a consent in writing with the company to act as a director after appointment if he was not a director before his appointment.

 

23.        File Form No. 29 with the concerned Registrar of Companies within thirty days of his appointment [Section 264(2)], after paying the requisite fee as prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury challan. [Rule 22]. This will be done if such a person is not a director in the same company before his appointment.

 

24.        File Form No. 32 in duplicate with concerned Registrar of Companies within thirty days of the appointment [Section 303], after paying the requisite fee as prescribed under Schedule X to the Companies Act, 1956, either in cash, postal order, or treasury challan. [Rule 22]

 

25.        Please keep in mind that if default is made in complying with the aforesaid requirements, the company and every officer of the company, will be punishable with fine upto Rs. 500/- for every day during which the default continues. [Section 303(3)]

 

26.        See that the managing director notifies about his appointment to other companies in which he is a director, managing director, manager or secretary within twenty days. [Section 305]

 

27.        Please keep in mind that if the managing director fails to do so, he will be punishable with fine upto Rs. 5000/‑. [Section 305(1)]

 

28.        Make necessary entries in the Register of Directors' Particulars etc. [Sec­tion 303(1)]

 

29.        Please also keep in mind that if the required entries as aforesaid are not made, the company and every officer of the company who is in default will be punishable with fine of upto Rs. 500/‑ for every day during which the default continues. [Section 303(3)]

 

30.        Take note of the provisions of Sections 197A, 267, 316 and 317 regarding disqualifications, disabilities etc. of a person to be appointed as a managing director.

 

31.        Where application to the Central Government is not required to be made, then file within ninety days from the date of appointment in the General Meeting a return in Form No. 25C with the concerned Registrar of Companies [Section 269(2)], after paying the requisite fee as prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury challan, along with a certificate either from the auditor or secretary of the company or a secretary in the whole time practice stating that the requirement of Schedule XIII have been complied with.      

 

32.        If your company is either a public company or a private company which is a subsidiary of a public company and also if your company's paid‑up share capital is rupees five crores or more, then appointment of either a managihg director or a whole‑time director or a manager is a must. [Section 269(1) read with Rule 10A(1)].

 

33.        If your company is a Government Company then provisions of Section 269 will not apply to your company.

 

34.        Note that as per the Citizen's Charter of the Department of Company Affairs, Schedule I Serial no. 10, the application if made to the Central Government will be processed within 30 days. [No. 5/25/99‑CL‑V, Press Note no. 9/99, dated 9‑8‑1999].

 

35.        Further note that if the application of a person as a managing director is not approved by the Central Government, he should vacate office as such on the date on which the decision of the Central Government is communicated to the compa,n and if he omits or fails to do so he will be punishable with fine upto 5000/‑ for every day during which he omits or fails to vacate such office. [Section 269(6)]

 

36.        Note also that if your company's paid‑up share capital is less than Rs. 50 lakhs but is equal to or more than Rs. 10 lakhs, your company is required to obtain a Compliance Certificate from a secretary in whole‑time practice to be filed with the Registrar of Companies mentioning therein that the registers have been kept and maintained as stated in Annexure A of the certificate, the forms have been duly filed with the Registrar of Companies and the Central Government as stated in Annexure B of the Certificate and the appointment of director has been duly made and that the said appointment has been made in compliance with the provisions of section 269 read with Schedule XIII and the approval of the Central Government has been obtained in respect of such appointment not being in terms of Schedule XIII as per paragraphs 1, 2, 14 and 15 of the Form of Compliance Certificate appended to the Companies (Compliance Certificate) Rules, 2001. [Section 383‑A(1) proviso].

 

Topic 77

 

DO YOU WISH TO VARY THE TERMS OF APPOINTMENT OF A MANAGING DIRECTOR, WHOLE‑TIME DIRECTORS, NON-ROTATIONAL DIRECTOR?

 

1.          See whether your company is a public company or a subsidiary of a public company. A public company which has become so under Section 43A [(Provisions of section 43A except sub‑section (2A) have been made inapplicable by the Companies (Amendment) Act, 2000 vide sub‑section (11) of that section] is also included.

 

2.          Keep in mind that a director appointed by small shareholders' of a public company having a paid‑up share capital of Rs. 5 crores or more although is a director but he is not to retire by rotation and the provisions of section 268 will not apply to him. [Rule 4(6) of the Companies (Appointment of Small Shareholders' Director) Rules, 2001.

 

3.          Convene a Board Meeting after giving notice to all the directors of the company as per Section 286 and take the decision for the amendment to be made in any provision relating to the appointment or re‑appointment.

 

4.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meetings as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/-. [Section 286(2)]

 

5.          Also decide in the aforesaid board meeting the contents of the proposed amendment.

 

6.          Publish a general notice to the members indicating the nature of the application proposed to be made to the Central Government regarding such amendment of the provision of appointment or re‑appointment. [Section 640B(2)(a)].

 

7.          The general notice aforesaid should be published at least once in a regional newspaper in the principal language of the district in which the registered office of the company is situate and circulating in that district and at least once in English in an English newspaper circulating in that district. [Section 640B(2)(b)].

 

8.          Prepare a draft of proposed amendment.

 

9.          Hold a Board Meeting after giving notice to all the directors of the com­pany as per Section 286 or a General Meeting, after giving notice in writing at least twenty‑one days before the date of the meeting [Section 171(1)] whichever is required to be held as per your company's Articles of Association, and place and approve the amendment prepared as above by a resolution.

 

10.        Please keep in mind that every officer of the company whose duty is to give notice of the Board Meetings as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/‑. [Section 286(2)]

 

11.        Send an abstract of the terms of variation to every member of the company within twenty‑one days of passing of the resolution making such variation in the terms of appointment. [Section 302]

 

12.        Please keep in mind that if default is made in complying with the aforesaid requirements, the company and every officer of the company who is in default will be punishable with fine upto Rs. 10,000/-. [Section 302(5)]

 

13.        If the amendment is to be made in any provision relating to the appointment or re‑appointment of any managing, whole‑time or non rotational director contained in the company's Memorandum or Articles of Association, then alter the Memorandum or the Articles of Association as per Topic 26 or Topic 29.

 

14.        If the amendment leads to a variation in any existing provision of the Articles of Association, then the approval of the Central Government is needed in addition to Special Resolution. But if the amendment leads to an insertion of a new provision in the Articles, no approval of the Central Government is needed [Clarification vide Letter No. 1(12)/CL‑I/ 65, dated 4‑11‑1965].

 

15.        Apply to the Central Government in Form No. 25W along with the fol­lowing documents:

 

(i)          Receipted treasury challan or demand draft in token of payment of the requisite fees, as prescribed by the Companies (Fees on Applications) Rules, 1999;

 

(ii)         Seven certified true copies of the resolution passed in the Board or General Meeting for approving the amended provision;

 

(iii)         A certified true copy of each document in which the amendments is proposed to be made, both original and revised (Articles, Memorandum, Agreement, Board or General Meeting resolution);

 

(iv)        Two certified true copies of each notice (English and vernacular) published under Section 640B.

 

16.        Forward a copy of the application together with a copy of each of the documents enclosed in the above application, simultaneously to the concerned Registrar of Companiess. [Rule 20A].

 

17.        File a certified copy of the Board or General Meeting resolution along with the copy of the Explanatory Statement in Form No. 23 with the concerned Registrar of Companies within thirty days after the passing thereof [Section 19,2(4)(c)], after paying the requisite fee as prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury challan. [Rule 22].

 

18.        Please also keep in mind that if default is made in complying with the aforesaid requirements, the company and every officer of the company who is in default will be punishable with fine upto Rs. 200/- for every day during which the default continues. [Section 192(5)]

 

19.        Pay the requisite fees pursuant to the Companies (Fees on Applications) Rules, 1999, on the application to be made to the Central Government for such amendment, either through treasury challan or by demand draft.

 

20.        If the application fee is paid by way of treasury challan, then pay the requisite fee of minimum Rs. 500/‑ and maximum Rs. 2000/‑, as the case may be and as prescribed by the Companies (Fees on Applications) Rules, 1999, by way of treasury challan prepared in triplicate and paid in cash into any of the specified branches of the Punjab National Bank for credit.

 

21.        The description of the Head of account of the treasury challan should be as prescribed under Rule 22(2) of the Companies (Central Government's) General Rules and Forms, 1956 and as amended vide GSR 251(E), dated 21‑6‑1996 (w.ef 21‑6‑1996). For account head and code please see Rule 22(2) in Appendix 1.

 

22.        Two copies of the treasury challan will be given back to the depositor and the original copy should be filed along with documents mentioned in item 15.

 

23.        If the application fee is paid by way of demand draft, then draw the demand draft in favour of "Pay and Accounts Officer, Department of Company Affairs, New Delhi", and payable at any bank located in New Delhi, and the said demand draft should be filed along with the documents mentioned in item 15.

 

24.        If your company is a Government Company then provisions of Section 268 will not apply to your company.

 

25.        Note that as per the Citizen's Charter of the Department of Company Affairs, Schedule I, Serial No. 9, the said application of the Central Government will be processed within 30 days. [No. 5/25/99‑CL‑V, Press Note No. 9/99, dated 9‑8‑1999]

 

Topic 78

 

DO YOU WISH TO APPOINT A MANAGING DIRECTOR WHO IS ALREADY A MANAGING DIRECTOR OR MANAGER IN ANOTHER COMPANY?

 

1.          Verify whether your company is a public company or its subsidiary. Deemed public companies [Section 43A] are also subjected to the restrictions. [Section 316(2)].

 

2.          Convene a Board Meeting after giving noticet to all the directors of the company as per Section 286 and approve the appointment or employment of the company's managing director who is a managing director or manager of another company, whether public or private, in the Board Meeting with the consent of all the directors of the company present at that Meeting and pass a resolution. [Section 316(2), Proviso].

 

3.          Please keep in mind that every officer of the company whose duty is to give notice of the, Board Meetings as aforesaid and who fails to do so will be punishable with fine of Rs. 1000/-. [Section 286(2)]

 

4.          Before holding the Board Meeting as aforesaid, give specific noticet of the Board Meeting to all the directors of the company then in India along with resolution to be moved thereat regarding the above appointment. [Section 316(2), Proviso].

 

5.          Verify whether there is an order of the Central Government permitting any person to be appointed as a managing director of more than two companies for the purpose of proper working of these companies as a single unit under a common managing director.

 

6.          In the aforesaid case, no Board approval is necessary [Section 316(4)].

 

7.          Also verify if the Central Government has imposed a restriction on the Managing Director not to be appointed as a Managing Director of any other company, under Section 637A of the Act.

 

8.          Further verify whether the managing director to be appointed in more than one company draws remuneration from one or both companies the total of which does not exceed the higher maximum limit admissible as per Part II Section I and Section II of Schedule XIII from any one of those companies. [Schedule XIII, Part I (d) read with Part II, Section III].

 

9.          If there is no such order and you want to obtain an order from the Central Government to permit appointment of a managing director in more than two companies, then do the following :-

 

(a)         Prepare an applicationj in the forrn of a representation stating the facts and reasons on the basis of which you are asking for the order;

 

(b)         Attach the following documents along with it :­

 

(i)          A certified true copy of the latest audited balance‑sheet of each of the companies;

 

(ii)         A certified true copy of the Memorandum and Articles of Association of each of the companies;

 

(iii)         Certified true copies of the Board's resolution of each of the companies;

 

(iv)        A detailed bio‑data of the managing director to be appointed as such;

 

(v)         Treasury challan or demand draft evidencing payment of requisite fee as per the Companies (Fees on Application) Rules, 1999.

 

10.        If the application fee is paid by way of treasury challan, then pay the requisite fee of minimum Rs. 500/‑ and maximum Rs. 2000/‑, as the case may be, and as prescribed by the Companies (Fees on Application) Rules, 1999, by way of treasury challan prepared in triplicate and paid in cash into any of the specified branches of the Punjab National Bank for credit.

 

11.        The description of the Head of account of the treasury challan should be as prescribed under Rule 22(2) of the Companies (Central Government's) General Rules and Forms, 1956 and as amended vide GSR 251(E), dated 21‑6‑1996 (w.e.f 21‑6‑1996). For account head and code please see Rule 22(2) in Appendix 1.

 

12.        Two copies of the treasury challan will be given back to the depositor and the original copy should be filed along with documents mentioned in item 9(b).

 

13.        If the application fee is paid by way of demand draft, then draw the demand draft in favour of "Pay and Accounts Officer, Department of Company Affairs, New Delhi", and payable at any bank located in New Delhi, and the said demand draft should be filed along with the documents mentioned in item 8(b).

 

14.        If your company is a Government Company then provisions of Section 316 will not apply to your company.

 

15.        Note that under sub‑section (4) of section 316 the Central Government may by order permit any person to be appointed as a managing director of more than two companies if it is satisfied that it is necessary that companies should for their proper working function as a single unit and have a common managing director.

 

16.        Note that if your company's paid‑up share capital is less than Rs. 50 lakhs but is equal to or more than Rs. 10 lakhs, your company is required to obtain a Compliance Certificate from a secretary in whole‑time practice to be filed with the Registrar of Companies mentioning therein inter alia that the appointment of managing director has been duly made in compliance with the provisions of section 269 read with Schedule XIII to the Act and approval of the Central Government has been obtained in respect of such appointment not being in terms of Schedule XIII as per paragraphs 14 and 15 of the Form of Compliance Certificate appended to the Companies (Compliance Certificate) Rules, 2001. [Section 383A (1) proviso].

 

Topic 79

 

DO YOU WISH TO APPOINT ONE OF YOUR DIRECTORS TO BE A WHOLE‑TIME DIRECTOR?

 

1.          See that the Articles of Association of the company provide for the office of the whole‑time director and if not, then such provision has to be made by passing a resolution of the General Meeting.

 

2.          Call a Board Meeting after giving noticet to all the directors of the company as per Section 286 and consider the terms and conditions on which the whole‑time director is to be appointed.

 

3.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meetings as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/‑. [Section 286(2)]

 

4.          Please also keep in mind that if your company has a director appointed by your company's small shareholders under section 252(1) proviso, he cannot be appointed by your company as a whole‑time director. [Rule 4(8) of the Companies (Appointment of the Small Shareholders' Director) Rules, 2001.

 

5.          In the same Board Meeting also fix up the date, time, place and agefida for calling a General Meeting.

 

6.          If the whole‑time director to be appointed has not attained the age of 25 years but has attained the age of majority or if the proposed whole‑time director has attained the age of 70 years then have the appointment approved by passing a Special Resolution without the approval of the Central Government. [Schedule XIII, part I(C)].

 

7.          In the case of a public company or its subsidiary, the appointment has to be in the General Meeting and approval of the Central Government will be necessary unless such appointment is made in accordance with the conditions specified in Parts I, II and III of Schedule XIII to the Act. [Section 269(2)].

 

8.          Issue notices at least twenty‑one days before the date of the meeting with suitable Explanatory Statement and hold the General Meeting, and pass the Ordinary Resolutionj or a Special Resolution as the case may be. [Section 171(1) read with sections 173(2) and 189(1)].

 

9.          Forward three copies of the notice and a copy of the proceedings of the General Meeting to the Stock Exchange with which the shares of your company are listed. [Clause 31(c) and (d) of the Standard Listing Agreement

 

10.        Where an application is to be made to the Central Government, as afore­ said, adopt the same procedure as described under item 12 of Topic 76.

 

11.        If your company is a Government company, then Government approval is not required for his appointment.

 

12.        If any executive of the company is elected to the Board as a director, then he also becomes a deemed whole‑time director by the Explanation given in Section 269 and thus he will also be appointed in the manner mentioned above provided he is in the whole‑time employment of the company as a director and he continues to be in the whole‑time employment as a director and not as an executive.

 

13.        If the application fee is paid by way of treasury challan, then pay the requisite fee of minimum Rs. 500/‑ and maximum Rs. 2000/‑, as the case may be, and as prescribed by the Companies (Fees of Applications) Rules, 1999, by way of treasury challan prepared in triplicate and paid in cash into any of the specified branches of the Punjab National Bank for credit.

 

14.        The description of the Head of account of the treasury challan should be as prescribed under Rule 22(2) of the Companies (Central Government's) General Rules and Forms, 1956 and as amended vide GSR 251(E), dated 21‑6‑1996 (w.e.f 21‑6‑1996). For account head and code please see Rule 22(2) in Appendix 1.

 

15.        Two copies of the treasury challan will be given back to the depositor and the original copy should be filed with documents enclosed to the application to the Central Government.

 

16.        If the application fee is paid by way of demand draft, then draw the demand draft in favour of "Pay and Accounts Officer, Department of Company Affairs, New Delhi" and payable at any bank located in New Delhi, and the said demand draft should be filed with the documents enclosed to the application to the Central Government.

 

17.        Send a copy of the application along with all the documents to the con­cerned Registrar of Companies. [Rule 20A].

 

18.        Send an abstract of the terms of the contract to all the members within twenty‑one days from the date of entering into the contract and a memorandum clearly specifying the interest or concern of any other director in the contract, if any. [Section 302(2)]

 

19.        Please keep in mind that if default is made in complying with the aforesaid requirements, the company and every officer of the company who is in default will be punishable with fine upto Rs. 10,000/‑.[Section 302(5)]

 

20.        Forward promptly to the Stock Exchange with which the shares of your company are listed, three copies of the above abstract and memorandum. [Clause 31 (c) of the Standard Listing Agreement]

 

21.        File a certified true copy of the resolution of the Board or agreement executed and the Ordinary Resolution appointing the whole‑time director with the concerned Registrar of Companies in Form No. 23 within thirty da s of the passing or making thereof, [Section 192], after paying the requisite fee as prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury challan. [Rule 22]

 

22.        Please also keep in mind that if default is made in complying with the aforesaid requirements, the company and every officer of the company who is in default will be punishable with fine upto Rs. 200/‑ for every day during which the default continues. [Section 192(5)]

 

23.        See that the whole‑time director files a consent in writing with the company to act as a director after appointment if he was not a director before his appointment.

 

24.        File Form No. 291 with the concerned Registrar of Companies within thirty days of his appointment [Section 264(2)], after paying the requisite fee as prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury challan. [Rule 22]. This will be done if such a person is not a director in the same company before his appointment as a whole‑time director.

 

25.        File Form No. 32 in duplicate with the concerned Registrar of Compa­nies within thirty days of the appointment [Section 303], after paying the requi­site fee as prescribed under Schedule X to the Companies Act, 1956, either in cash, postal order, or treasury challan. [Rule 22]

 

26.        Further keep in mind that if default is made in complying with the aforesaid requirements, the company and every officer of the company who is in default will be punishable with fine upto Rs. 500/- for every day during which the default continues. [Section 303(3)]

 

27.        See that the whole‑time director notifies about his appointment to other companies in which he is a director, managing director, manager or secretary within twenty days. [Section 305]

 

28.        Further keep in mind that if the whole‑time director fails to do so, he will be punishable with fine upto Rs. 5000/‑. [Section 305(1)]

 

29.        Make necessary entries in the Register of Directors' Particulars etc. [Sec­tion 303(1)]

 

30.        Further keep in mind that if the required entries as aforesaid are not made, the company and every officer of the company who is in default will be punishable with fine upto Rs. 500/­- for every day during which the default continues. [Section 303(3)]

 

31.        If your company is either a public company or a private company which is a subsidiary of a public company and also if your company's paid‑up share capital is rupees five crores or more, then appointment of either a managing director or a whole‑time director or a manager is a must. [Section 269(1) read with Rule 10A(1)].

 

32.        Note that if your company's paid‑up share capital is less than Rs. 50 lakhs but is equal to or more than Rs. 10 lakhs, your company is required to obtain a Compliance Certificate from a secretary in whole‑time practice to be filed with the Registrar of Companies mentioning therein inter alia that the registers have been kept and maintained as stated in Annexure A of the Certificate, the forms have been duly filed with the Registrar of Companies as stated in Annexure B of the Certificate and the appointment of director has been duly made and also the appointment of whole time director has been made in compliance with the provisions of section 269 read with Schedule XIII to the Act and approval of Central Government has been obtained in respect of the said appointment not being in terms of Schedule XIII as per paragraphs 1, 2, 14 and 15 of the Form of Compliance Certificate appended to the Companies (Compliance Certificate) Rules, 2001.

 

Topic 80

 

DO YOU WISH TO REMOVE A MANAGING[WHOLE‑TIME DIRECTOR BEFORE THE EXPIRY OF HIS TERM OF OFFICE?

 

1.          Please Note.‑ That appointment of a Managing or a Whole‑time Director is a contract between him and the company. Removal in breach of contract will entail payment of compensation under Section 318. Nevertheless, only the appointing authority can remove him. Thus he can be removed by the Board or the General Meeting depending on whether the Board or the General Meeting had appointed him.

 

2.          As there is no specific provision for the removal of the managing or the whole‑time director, provisions, if any, made in the Articles of Association should be followed failing which Section 284 relating to removal of director shall apply whereupon they will cease to hold such office as soon as they cease to be directors on the Board.

 

3.          See that a special notice regarding such removal is furnished to the company before fourteen days of the date of the General Meeting, exclusive of the day it is posted and the day of the meeting. [Section 190(1) read with Section 284(2)]

 

4.          As soon as the special notice is received, send a copy of the notice to the managing or the whole‑time director concerned. [Section 284(3)]

 

5.          Give noticel to the members regarding the special notice received by the company to remove the managing or the whole‑time director within seven days of the date of the General Meeting either by advertisement or by any mode allowed by the Articles of Association of the company. [Section 190(2)]

 

6.          Send a copy of the representations, if any, made by the aggrieved managing or the whole‑time director to every member of the company to whom notice of the General Meeting has been sent.

 

7.          If the aforesaid representation cannot be so sent, then see that the repre­sentations are read out at the meeting.

 

8.          Do not send a copy of the representation to the members or do not allow it to be read in the meeting if you get a Company Law Board's order restricting such action, on the application either of your company or any person who claims to be aggrieved. [Section 284(4), Proviso].

 

9.          Convene a Board Meeting after giving notice to all the directors of the company as per section 286 to fix the date, time, place and agenda of the General Meeting to remove the managing or the whole‑time director by passing an Ordinary Resolution.

 

10.        Please keep in mind that every officer of the company whose duty is to give notice of the Board Meetings as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/‑. [Section 286(2)]

 

11.        Issue notice at least twenty‑one days before the date of the General Meeting along with the relevant Explanatory Statement. [Section 171(1) read with section 173(2)].

 

12.        Hold the General Meeting and pass an Ordinary Resolution by simple majority removing the managing or the whole‑time director. [Section 189(1)].

 

13.        Promptly forward to the Stock Exchange with which the shares of your company are listed, three copies of the notice and a copy of the proceedings of the General Meeting. [Clause 31(c) and (d) of the Standard Listing Agreement].

 

14.        File Form No. 32 in duplicate with the concerned Registrar of Companie within thirty days of the passing of the Ordinary Resolution removing the managing or the whole‑time director [Section 303(2)], after paying the requisite fee as prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury challan. [Rule 22].

 

15.        Please keep in mind that if default is made in complying with the aforesaid requirements the company and every officer of the company who is in default will be punishable with fine upto Rs. 500/‑ for every day during which the default continues. [Section 303(3)]

 

 

C. Manager/Secretary

 

(Topic 81 to Topic 85)

 

Topic 81

 

DO YOU WISH TO APPOINT A MANAGER?

 

1.          Convene a Board Meetin g after giving noticel to all the directors of the company as per Section 286 and approve the draft agreement or the terms and conditions on which the manager is proposed to be appointed and fix up the date, time, place and agenda of the General Meeting for the appointment.

 

2.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meetings as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/‑. [Section 286(2)]

 

3.          Issue notices in writing at least twenty‑one days before the date of the meeting along with the relevant Explanatory Statement. [Section 171(1) read with Section 173(2)]

 

4.          Comply with the provisions of Sections 297 and 299 regarding disclosure of interest of directors etc. and in case of public companies and their subsidiaries and holding companies those of Section 300 also regarding abstaining from discussion and voting etc.

 

5.          In the case of public companies and their subsidiaries, where the proposed manager is already a manager or managing director in another company, a Board resolution will be necessary, of which prior notice should have been given and all the directors present at the meeting should have consented to the resolution. [Section 386(2)].

 

6.          Hold the General Meeting and appoint the manager by passing an Ordi­nary Resolution by simple majority. [Section 189(1)]

 

7.          If the manager to be appointed has not attained the age of 25 years but has attained the age of majority or if the proposed manager has attained the age of 70 years then have the appointment approved by passing a Special Resolution. [Schedule XIII, Part I(c)]

 

8.          If Special Resolution is to be passed then hold the General Meeting and appoint the manager by passing a Special Resolution by three‑fourths majority. [Section 189(2)]

 

9.          In the case of a public company, or its subsidiary, the appointment in the Board Meeting and the General Meeting will be effective only on approval of the Central Government if the appointment is not made in accordance with the conditions specified in Parts I, II and III of Schedule XIII to the Act. [Section 269 read with section 388]

 

10.        Where application is to be made to the Central Government as aforesaid do the following ‑.­

 

(a)         Give general notice to all the members indicating the nature of the application to be made to the Central Government;

 

(b)         Publish the notice at least once in a newspaper of the principal language of the district in which the registered office of the company is situated and circulating in that district and at least once in English in an English newspaper circulating in that district. [Section 640B read with section 3881;

 

(c)         Forward three copies of the general notice published in the newspaper to the Stock Exchange with which the shares of your company are listed. [Clause 31(e) of the Standard Listing Agreemene];

 

(d)         Forward to the Stock Exchange with which the shares of your company are listed a copy of the proceedings of the General Meeting and three copies of the notice of the General Meeting. [Clause 31(c) and (d) of the Standard Listing Agreement];

 

(e)         Make the application in Form No. 25A within ninety days from the date of appointment and enclose the following:

 

(i)          A certified true copy of the existing and proposed agreement in this regard, if any;

 

(ii)         A certified true copy of the Board as well as the General Meeting resolution;

 

(iii)         A certified true copy of the audited balance‑sheet and the profit and loss account for the last two years;

 

(iv)        Where the company has not yet commenced any business or whose accounts have not been audited :

 

(a)         a certified true copy of the Prospectus, if issued;

            

(b)         particulars of capital proposed;

 

(c)         amount of long‑term loans and sources of such loans;

 

(d)         expected date of commencement of production/business;

 

(e)         estimated turnover and profit for the next three years;

 

(f)          details of industrial licence, if any;

 

(g)         extent of foreign collaboration, if any;

 

(v)         A certified true copy of the Memorandum and Articles of Association revised up‑to‑date marking the relevant article or the authority under which the appointment is made;

 

(vi)        Certified true copies of the notices published in the newspaper(s) certified by the company as to the due publication thereof,

 

(vii)        A treasury challan or demand draft evidencing payment of requisite fee prescribed under the Companies (Fees on Application) Rules, 1999.

 

11.        If the application fee is paid by way of treasury challan, then pay the requisite fee of minimum Rs. 500/‑ and maximum Rs. 2000/‑, as the case may be, and as prescribed by the Companies (Fees on Applications) Rules, 1999, by way of treasury challan prepared in triplicate and paid in cash into any of the specified branches of the Punjab National Bank for credit.

 

12.        The description of the Head of account of the treasury challan should be as prescribed under Rule 22(2) of the Companies (Central Government's) General Rules and Forms, 1956 and as amended vide GSR 251(E), dated 21‑6‑1996 (w.ef 21‑6‑1996). For account head and code please see Rule 22(2) in Appendix 1.

 

13.        Two copies of the treasury challan will be given back to the depositor by the said branch of the bank and the original copy should be attached to the application mentioned in item 10(e).

 

14.        If the application fee is paid by way of demand draft, then draw the demand draft in favour of."Pay and Accounts Officer, Department of Company Affairs, New Delhi", and payable at any bank located in New Delhi, and the said demand draft should be attached to the application mentioned in item 10(e).

 

15.        If any director of the company is in any way, whether directly or indirectly concerned or interested in the appointment of the manager, then send an abstract of the terms of the contract to all the members within twenty‑one days from the date of entering into the contract and a memorandum clearly specifying the interest or concern of any other director in the contract, if any. [Section 302(1)(a)]

 

16.        Forward promptly to the Stock Exchange with which the shares of your company are listed, three copies of the above abstract and memorandum. [Clause 31(c) of the Standard Listing Agreement]

 

17.        See that the manager files a consent in writing with the company to act as a manager after a          ppointment if he was not a director or manager before his appointment.

 

18.        File Form No. 32 in duplicate with the concerned Registrar of Companies' within thirty days of the appointment [Section 303], after paying the requisite fee as prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury challan. [Rule 22]

 

19.        Please also keep in mind that if default is made in complying with the aforesaid requirements, the company and every officer of the company who is in default will be punishable with fine upto Rs. 500/- for every day during which the default continues. [Section 303(3)]

 

20.        See that the manager notifies about his appointment to other companies in which he is a director, managing director, manager or secretary within twenty days. [Section 305]

 

21.        Further keep in mind that if the manager fails to do so, he will be punish­able with fine upto Rs. 5000/‑. [Section 305(1)]

 

22.        Make necessary entries in the Register of Directors' Particulars etc. [Sec­tion 303(1)]

 

23.        Further keep in mind that if the required entries as aforesaid not made, the company and every officer of the company who is in default will be punishable with fine upto Rs. 500/‑ for every day during which the default continues. [Section 30‑3(3)]

 

24.        Take note of the provisions of Sections 197A, 317, 384, 385, 386 and 388 regarding disqualifications, disabilities, etc. of a person to be appointed as a manager.

 

25.        Where application to the Central Government is not required to be made, then file within ninety days from the date of appointment in the General Meeting a return in Form No. 25C with the concerned Registrar of Companies [Section 269(2) read with Rule 10A(2)], after paying the requisite fee as prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury challan [Rule 22]

 

26.        The aforesaid return should be accompanied by a certificate either from the auditor or secretary of the company or a secretary in the whole‑time practice stating that the requirements of Schedule XIII have been complied with.

 

27.        If your company is either a public company or a private company which is a subsidiary of a public company and also if your company's paid‑up share capital is rupees five crores or more, then appointment of either a managing director or whole‑time director or a manager is a must. [Section 269(1) read with Rule 10A(1)]

 

28.        If your company is a Government Company then provisions of Sections 386 and  388 will not apply to your company.

 

29.        Note that if your company's paid‑up share capital is less than Rs. 50 lakhs but is equal to or more than Rs. 10 lakhs, your company is required to obtain a Compliance Certificate from a secretary in whole‑time practice to be filed with the Registrar of Companies mentioning therein inter alia that the registers have been kept and maintained as stated in Annexure A of the Certificate, the forms have been duly filed with the Registrar of Companies as stated in Annexure B of the Certificate and the appointment of manager has been made in compliance with the provisions of section 269 read with Schedule XIII of the Act and approval of the Central Government has been obtained in respect of the said appointment not being in terms of Schedule XIII as per paragraphs 1, 2 and 15 of the Form of Compliance Certificate appended to the Companies (Compliance Certificate) Rules, 2001 [Section 383‑A(1) proviso ].

 

Topic 82

 

DO YOU WISH TO APPOINT A COMPANY SECRETARY?

 

1.          Only persons who are Company Secretaries within the meaning of Section 2(1)(c) of the Companies Secretaries Act, 1980, and individuals possessing the prescribed qualifications can be appointed as secretary of a company. [Section 2(45)].

 

2.          In the case of companies having paid‑up share capital of not less than rupees fifty lakhs, it is obligatory to appoint a whole‑time secretary. [Section 383A].

 

3.          Please keep in mind that if your company fails to comply with the requirement, the company and every officer of the company who is in default will be punishable with fine upto Rs. 500/‑ for every day during which the default continues. [Section 383A(1A)]

 

4.          However, when there are more than two directors on the Board, then one of them if otherwise qualified within the meaning of Companies (Appointment and Qualifications of Secretary) Rules, 1988, may act as secretary and not otherwise.

 

5.          The qualifications prescribed for appointment as secretary by the Compa­nies (Appointment and Qualifications of Secretary) Rules, 1988 are:­

 

(a)         In the case of companies having a paid‑up share capital of Rs. 50 lakhs or more:

 

(i)          Membership of the Institute of Company Secretaries of India;

 

(b)         In the case of any other company:

 

(i)          membership of the Institute of Company Secretaries of India constituted under the Company Secretaries Act, 1980 (56 of 1980);

 

(ii)         pass in the Intermediate ‑examination conducted either by the Institute of Company Secretaries of India constituted under the Company Secretaries Act, 1980, (No. 56 of 1980) or by the earlier Institute of Company Secretaries of India incorporated on 4th October, 1968 under the Companies Act, 1956 (1 of 1956) and licensed under Section 25 of that Act;

 

(iii)         post graduate degree in commerce or corporate secretaryship granted by any University in India;

 

(iv)        degree in law granted by any university;

 

(v)         membership of the Institute of Chartered Accountants of India constituted under the Chartered Accountants Act, 1949 (38 of 1949);

 

(vi)        membership of the Institute of Cost and Works Accountants of India constituted under the Cost and Works Accountants Act, 1959 (23 of 1959);

 

(vii)        post graduate degree or diploma in management sciences, granted by any University, or the Institutes of Management, Ahmedabad, Calcutta, Bangalore or Lucknow;

 

(viii)       post diploma in company secretaryship granted by the Institute of Commercial Practice under Delhi Administration or Diploma in Corporate Laws.and Management granted by the Indian Law Institute, New Delhi;

 

(ix)        post graduate diploma in company law and secretarial practice granted by the University of Udaipur; or

 

(x)         membership of the Association of Secretaries and Managers, Calcutta, registered under the West Bengal Registration of Societies Act, 1961 (XXVI of 1961).

 

6.          In the case of a company having a Company Secretary with any of the qualifications mentioned in item 5(b) above it is necessary to appoint a Company Secretary with qualifications mentioned in item 5(a) above within one year of the increase in paid‑up share capital to rupees fifty lakhs and above.

 

7.          Irrespective of the size of paid‑up capital, and existing company secretary, notwithstanding his qualifications, who had continued to enjoy protection upto 30‑10‑1980, under the old Companies (Secretary's Qualification) Rules, 1975, shall continue to enjoy such protection.

 

8.          Convene a Board Meeting after giving noticel to all the directors of the company as per Section 286 and pass a resolution appointing the secretary and approving the terms and conditions of his appointment.

 

9.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/-.[Section 286(2)]

 

10.        Ensure that the interests of directors are disclosed in accordance with the provisions of sections 297 and 299.

 

11.        Please keep in mind that every director who fails to disclose his interests as aforesaid will be punishable with fine upto Rs. 50,000/-. [Section 299(4)]

 

12.        In the case of a public company or its subsidiary or holding company, no director who is interested or concerned in any way, whether directly or indirectly, in the contract of appointment should take part in discussion or voting, nor his presence should be counted for quorum for the said purpose. [Section 300]

 

13.        Please keep in mind that every director who knowingly contravenes the provisions of this section will be punishable with fine upto Rs. 50,000/‑. [Section 300(4)]

            

14.        File Form No. 32 in duplicate with the concerned Registrar of Companies within thirty days of the appointment [Section 303] after paying the requisite fee  prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury challan. [Rule 22]

 

15.        Please also keep in mind that if default is made in complying with the aforesaid requirements, the company and every officer of the company who is in default will be punishable with fine upto Rs. 500/‑ for ever day during which the default continues. [Section 303(3)]

 

16.        The person appointed has to notify about his appointment to other companies in which he is a director, managing director, manager or secretary within twenty days of his appointment. [Section 305]

 

17.        Make necessary entries in the Register of Particulars of Directors etc. [Section 303(1)]

 

18.        Further keep in mind that if the required entries as aforesaid are not made, the company and every officer of the company who is in default will be punishable with fine upto Rs. 500/- for every day during which the default continues. [Section 303(3)].

 

19.        If the case falls within the purview of Section 314, complete the formali­ties as mentioned in Topic 69.       

 

20.        If the person appointed as secretary fails to disclose to other companies in which he is a director, managing director, manager or secretary within twenty days of his appointment he will be punishable with fine of upto Rs. 5000/- [Section 305(1)]

 

Topic 83

 

DO YOU WISH TO REMOVE THE COMPANY SECRETARY?

 

1.          Convene a Board Meeting after giving notice to all the directors of the company as per Section 286 and take the decision of removing the existing secretary only if the secretary is not named in the Articles of Association for, in that case, the Article will have to be altered accordingly vide Topic 26.

 

2.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/‑. [Section 286(2)]

 

3.          Intimate the secretary regarding the decision of the Board and ask him to give representation to the Board within fifteen days of the date of intimation.

 

4.          Again hold a Board Meeting after giving notice to all the directors of the company as per Section 286 and consider the representation, if any, made by the secretary and cancel the agreement entered into by the company with the secretary.

 

5.          In the same Board Meeting appoint a secretary in place of the removed secretary.

 

6.          File Form No. 32 in duplicate with the concerned Registrar of Compani to intimate about the removal of the existing secretary and appointment of new secretary, within thirty days of such removal as well as appointment [Section 303(2)] after paying the requisite fee as prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury challan. [Rule 22]

 

7.          Please also keep in mind that if default is made in complying with the aforesaid requirements, the company and every officer of the company who is in default will be punishable with fine upto Rs. 500/- for every day during which the default continues. [Section 303(3) ]

 

8.          Inform the members and the public, if desired by the Board, through a newspaper advertisement about the removal of the existing secretary and the appointment of the new secretary.

 

9.          Intimate the secretary so appointed in the Board Meeting.

 

10.        In case your company's shares are listed on a recognised Stock Exchange then forward to the Stock Exchange three copies of the newspaper advertisement promptly. [Clause 31(e) of the Standard Listing Agreement].

 

Topic 84

 

DO YOU WISH TO APPOINT A SECRETARY IN WHOLE‑TIME PRACTICE?

 

1.          Note that appointing a Secretary in whole‑time practice is compulsory for a company whose shares are listed on a recognised Stock Exchange, as per the provisions of Section 161 [Proviso to sub‑section (1) of section 161] for having the annual return signed by a Secretary in whole‑time‑practice before it is filed with the Registrar.

 

2.         

A.          Also note that appointing a Secretary in whole‑time practice is also  compulsory for a company whose paid‑up share capital is less than Rs. 50 lakhs but is Rs. 10 lakhs or more, because such a company is required to file with the Registrar of Companies' a Certificate of Compliance as to whether the company has complied with all the provisions of the Act ob­tained from Secretary in whole‑time practice. [Section 383‑A(1), proviso read with Rule 3 of the Companies  (Compliance Certificate) Rules, 2001].

 

B.          Ensure that the certificate is filed with the Registrar in the Form appended to the Companies (Compliance Certificate) Rules, 2001], or as near thereto as circumstances admit, in respect of each financial year within thirty days from the date on which the annual general meeting was held along with requisite filing fee as per Schedule X.

 

C.          Where the annual general meeting has not been held, file with the Registrar such certificate within thirty days from the latest day on or before which that meeting should have been held in accordance with the provisions of the Act.

 

D.          Every secretary in whole‑time practice for the purpose of issue of certificate shall have right to access at all times to the registers, books, papers, documents and records of the company whether kept in pursuance of the Act or any other Act or otherwise and whether kept at the registered office of the company or elsewhere and shall be entitled to require from the officers or agents of the company, such information and explanations as the secretary in whole‑time practice may think necessary for the purpose of such certificate.

 

E.          Every certificate shall be laid by the company in its annual general meeting.

 

F.          A copy of such certificate should be attached to the Board's Report referred to in section 217 [Section 383‑A(1), Proviso]

 

3.          Please keep in mind that if your company fails to comply with the afore­ said requirement, the company and every officer of the company who is in de­fault will be punishable with fine upto Rs. 500/- for every day during which the default continues. [Section 383‑A(1A)]

 

4.          Note further that an option is available with you to appoint a Secretary in whole‑time‑practice for filing a declaration of compliance with the Registrar of Companies while forming a company, under Section 33(2) of the Act, for certification of compliance with the requirements of Schedule XIII in return to be filed with the Registrar in the matter of appointment of managerial personnel without Government approval, and for filing a duly verified declaration relating to commencement of business under Section 149 of the Act. [Clause (d) of Subsection (1), Clause (c) of Sub‑section (2), sub‑clause (ii) of Clause (b) of Subsection (2A) of Section 149].

 

5.          Ensure before appointing the Secretary in whole‑time‑practice, that the individual concerned satisfies the definition of Secretary in whole‑time‑practice in clause (45A) of Section 2, i.e., he is a member of the Institute of Company Secretaries of India and is not in full time employment anywhere.

 

6.          Note that the individual proposed to be appointed holds a certificate of practice from the Institute of Company Secretaries of India and that the said certificate is of current validity.

 

7.          Convene a Board Meeting after giving notice to all the directors of the company as per Section 286 pass a Board Resolution appointing the individual as Secretary in whole‑time‑practice either generally for performing the duties and functions of a Secretary under the Act (if yours is not a company which is otherwise compulsorily required to appoint a whole‑time Secretary under Section 383‑A) or for discharging the functions in respect of a specific assignment, such assignment being mentioned in the body of the Resolution.

 

8.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/‑. [Section 286(2)]

 

9.          While drafting the Resolution, you may limit the tenure of appointment or limit the appointment to specific assignment or both.

 

10.        See that the remuneration to be paid to the Secretary in whole‑time prac­tice should also be mentioned in the Resolution.

 

11.        You may, if you so desire, pass the aforesaid Resolution after appointing the Secretary in whole‑time‑practice or after assigning the job to him, the Resolution being in the nature of a ratification.

 

12.        As an alternative, if the Managing Director or any other officer is so empowered, the appointment can be made by a letter addressed to the individual appointed as Secretary in whole‑time practice.

 

13.        Such appointment is as valid as an appointment made by a Resolution pro­spective or retrospective.

 

14.        Where you decide to appoint a Secretary in whole‑time practice to perform the duties and functions of Secretary of the company, please maintain the Register under Section 303.

 

15.        In the aforesaid case file Form No. 32 in duplicate with the Registrar of CompanieS within 30 days of the appointment, [Section 303(2)] after paying the requisite fee prescribed under Schedule X of the Act, either in cash, or treasury challan. [Rule 22].

 

16.        Please also keep in mind that if default is made in complying with the aforesaid requirements, the company and every officer of the company who is in default will be punishable with fine upto Rs. 500/‑ for every day during which the default continues. [Section 303(3)].

 

17.        Please see that the person appointed notifies about his appointment to other companies in which he is a Director, Managing Director, Manager or Secretary within 20 days of his appointment [Section 305]

 

18.        Further keep in mind that if he fails to do so, he will be punishable with fine upto Rs. 5000/‑. [Section 305(1)]

 

19.        If you choose to appoint a Director of the company (not being in wholetime employment anywhere), please ensure that the requirements of Section 314 are complied with vide Topic 69.

 

20.        Keep in mind that the services of a company secretary in whole‑time practice are also needed under sub‑rule (1) and (2) of Rule 10 of the Private Limited Company  and Unlisted Public Limited Company (Buy‑back of Securities) Rules, 1999.

 

Topic 85

 

DO YOU WISH TO DEFEND YOUR FAILURE TO APPOINT A QUALIFIED COMPANY SECRETARY?

 

1.          Note that appointing a whole‑time Secretary is complusory for a company having paid‑up share capital of not less than rupees fifty lakhs. [Section 383 A(1)].

 

2.          Further note that appointing a whole‑time secretary is although not compulsory for a company whose paid‑up share capital is less than rupees fifty lakhs but a company whose paid‑up share capital is rupees ten lakhs or more must file with the Registrar of Companies a Compliance Certificate obtained from a secretary in whole‑time practice in the Form appended to the Companies (Compliance Certificate) Rules, 2001 in respect of each financial year of your company within 30 days from the date of holding the annual general meeting as to whether the company has complied with all provisions of the Act or not and a copy of such certificate should be attached to the Board's Report referred to in section 217. [Section 383‑A(1) Proviso].

 

3.          Note also that the company and every officer of the company who fails to appoint a whole‑time Secretary or a secretary in whole‑time practice as aforesaid becomes punishable with fine of upto Rs. 500/‑ for every day of default. [Section 383A(1A)].

 

4.          Note also that you are liable to be prosecuted for mere failure to appoint a whole‑time Secretary where you are required to do so and the penalty is fine of Rs. 500/- for every day during which the failure continues. [Section 383‑A (1A)].

 

5.          In the aforesaid prosecution proceedings, the following defences are open to you:­

 

(a)         You had made reasonable efforts to appoint a whole‑time Secretary but without success. Whether the efforts made by you are reasonable or not will be a question of fact. Thus, you cannot defend your case by showing that you had advertised for a Company Secretary on a salary of Rs. 1000/‑ and no one applied in response to that advertisement. The Secretary is, in law and in fact, the Chief Administrative Officer of the Company, a salary which even the lowest worker in the company gets cannot be offered to a Company Secretary.

 

(b)         The financial position of your company is such that it is beyond your capacity to engage a whole‑time Secretary. A good case would be made out when you can show that a part of your paid up capital has also been eroded by accumulating losses and taking that erosion into account, your net paid up capital is now less than rupees fifty lakhs being paid up share capital requiring appointment of a whole‑time Secretary. [Section 383A(1A), Proviso].

 

6.          Keep in mind that to take the aforesaid defences at the time of trial of the criminal proceedings if any initiated by the Registrar of Companies and not thereafter by invoking the inherent power of the High Court. [Sandur Investment Company Ltd. v. ROC (2001) 34 SCL 586 (Kar)].

 

 

D. Officer in Default

 

(Topic 86 to Topic 89)

 

Topic 86

 

DO YOU WISH TO CHARGE A PERSON WITH RESPONSIBILITY FOR COMPLIANCE OF SECTIONS OF THE ACT WHERE THE EXPRESSION, "OFFICER IN DEFAULT" DOES NOT OCCUR?

 

1.          Note that in the absence of an enabling provision in this behalf, you cannot charge a person with responsibility for compliance of any provision of the Act to shift the guilt from one person to another.

 

2.          Note that the provisions of the Act which enable you to charge a person for responsibility for compliance are contained in the proviso to Sub‑section (5) of Section 209, proviso to Sub‑section (5) of Section 210, proviso to Subsection (7) of Section 211  and proviso to Sub‑section (9) of Section 212.

 

3.          Note that since authority and responsibility go together, Section 292 of the Act which contains certain enabling provisions to delegate the authority which vests in the Directors can be invoked by the company to charge specified Directors constituting a committee, the Managing Director, the Manager or any other principal officer of the company or any of its branch with the responsibility which attaches to the exercise of the authority delegated to them.

 

4.          Convene a Board Meeting after giving notice to all the directors of the company as per Section 286 and pass a Board Resolution in which the specific officer should be named along with the specific section of the Act whose compliance is intended to be ensured by charging such person with the responsibility.

 

5.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/‑. [Section 286(2)]

 

6.          Before charging such person with responsibility, obtain his written consent in Form No. 1 AB.

 

7.          Apart from complying with the requirements‑of sub‑sections (2), (3) and (4) of Section 292, while delegating the authority in terms of the proviso to Subsection (1) of that section, it will be necessary to spell out the Resolution of delegating the responsibility for compliance as well.

 

8.          File a return in Form No. 1AA within thirty days of passing the Board Resolution with the concerned Registrar of Companies, after paying the requisite fee as prescribed under Schedule X of the Companies Act, 1956, either in cash, demand draft or treasury challan. [Rule 4BB(1) read with Rule 22]

 

9.          See that the above mentioned return is accompanied by the consent given to the Board of Directors by the person so charged with the responsibility in Form No. 1AB. [Rule 4BB(2)].

 

10.        See also that the above mentioned return is accompanied by a certified true copy of the Board Resolution so passed for the purpose.

 

11.        Where the consent given by the person, charged with responsibility, to the Board of Directors, is revoked or withdrawn, your company should file within thirty days of such revocation or withdrawal, with the concerned Registrar of Companies a return in Form No. 1AC after paying the requisite fees prescribed under Schedule X of the Companies Act, 1956, either in cash, or treasury challan. [Rule 4BB(3) read with Rule 22(3)]

 

12.        Note that since no specific penalty is imposed for not filing the aforesaid returns within the prescribed time in section 5 itself, the general provision of penalty provided in section 629A will be applicable ‑which is fine of upto Rs. 5,000/‑ and also a continuing fine of upto Rs. 500/-. for every day after the first during which the contravention continues.

 

Topic 87

 

DO YOU WISH TO CHARGE A PERSON OTHER THAN A DIRECTOR WITH RESPONSIBILITY FOR COMPLIANCE OF SECTIONS OF THE ACT WHERE THE EXPRESSION, "OFFICER IN DEFAULT" DOES OCCUR?

 

1.          Please refer Clause (f) of Section 5 of the Companies Act, 1956.

 

2.          Before charging a person with responsibility for compliance, please iden­tify the specific section for which compliance is required.

 

3.          Ensure that the section so identified uses the expression "officer of the company who is in default".

 

4.          Where such expression does not occur, it would not be open to you to charge a person with responsibility for compliance unless the section itself contains an enabling provision in this behalf.

 

5.          Obtain written consent of the person proposed to be charged with responsibility for compliance in Form No. 1AB unless the person charged is present in the meeting of the Board in which the Resolution charging him with the responsibility is passed and his presence has been duly recorded.

 

6.          Convene a Board Meeting after giving notice to all the directors of the company as per Section 286 and pass the necessary Board Resolution charging the person with the responsibility for compliance.

 

7.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/-. [Section 286(2)]

 

8.          Do not forget to mention the specific provision of the Act whose compli­ance is sought to be attached to the person charged.

 

9.          Do not forget that the Managing Director or whole‑time Director or Manager or Secretary or a person in accordance with whose instructions the Board of Directors are accustomed to act cannot be charged with the responsibility for compliance under clause (f) of section 5.

 

10.        The person charged as aforesaid must be other than a person falling under any of the categories mentioned in clauses (a) to (e) of Section 5. It is, however, open to the Board to charge a director under clause (f).

 

11.        File with concerned Registrar of Companies the return in Form No. 1AA within thirty days of passing of the Board Resolution under clause (f) of Section 5, after paying the requisite fee as prescribed under Schedule X of the Companies Act, 1956, either in cash, or treasury challan. [Rule 4BB(1) read with Rule 22].

 

12.        See that the above‑mentioned return is accompanied by the consent ob­tained from the person as mentioned in item 5 in Form No. 1AB.

 

13.        See also that the above‑mentioned return is accompanied by a certified true copy of the Board Resolution so passed for the purpose.

 

14.        Where the consent given by the person, charged with responsibility, to the Board of Directors, is revoked or withdrawn, your company should file within thirty days of such revocation or withdrawal, with the concerned Registrar of Companies a return in Form No. 1AC after paying the requisite fees prescribed under Schedule X of the Companies Act, 1956, either in cash, or treasury challan. [Rule 4BB(3) read with Rule 22].

 

15.        Note that since no specific penalty is imposed for not filing the aforesaid returns within the prescribed time, in section 5 itself the general provision of penalty provided in section 629A will be applicable which is fine of upto Rs. 5000/‑ and also a continuing fine of upto Rs. 500/‑ for every day after the first during which the contravention continues.

 

Topic 88

 

DO YOU WISH TO CHARGE A DIRECTOR WITH COMTLIANCE OF PROVISIONS OF THE ACT WHERE THE EXPRESSION, "OFFICER IN DEFAULT" DOES OCCUR?

 

1.          Note that a Director can be charged with the responsibility for compliance either under clause (f) or under clause (g) of Section 5.

 

2.          Note, however, that when a Director is charged under clause (f), he is charged in the capacity of "any person" and not as director.

 

3.          Where a director is charged in the capacity of "any person", the company may have a Managing or Whole‑time Director or Manager or Secretary and yet he will be charged under clause (f) of Section 5.

 

4.          Note further that when a Director is charged with responsibility for compliance under clause (g) of section 5 he is charged in the capacity of a Director and he can be so charged only if the company does not have either a Managing or a whole‑time Director or a Manager.

 

5.          Note, again, that it is not a compulsory requirement of clause (e) of Section 5 that a Director of the company must necessarily be charged with the responsibility for compliance if it is a Board managed company.

 

6.          The only consequence of not charging a Director;th such responsibility under clause (g) of section 5 is that all the directors of company will jointly and severally be responsible for compliance.

 

7.          Convene a Board Meeting after giving noticel to all the directors of the company as per Section 286 and pass a Resolution of the Board specifiying the Director concerned and also spelling out the specific provision of the Act whose compliance is sought to be attached to the Director charged. [Section 5(g)].

 

8.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/‑. [Section 286(2)]

 

9.          File a return in Form No. 1AA with the concerned Registrar of Companies within thirty days of the passing of the Resolution of the Board aforesaid, after paying requisite fee as prescribed under Schedule X of the Companies Act, 1956, either in cash, or treasury challan. [Rule 4BB read with Rule 22].

 

Topic 89

 

DO YOU WISH TO KEEP OUT SOME OFFICERS FROM BEING CHARGED WITH OFFENCE?

 

1.          Note that all the officers or persons referred to in various clauses of Section 5 are not to be treated as being simultaneously responsible for compliance with any provision of the Act.

 

2.          All of these officers are not to be taken together as officers in default when it comes to the question of identifying the officer in default for purpose of prosecution.

 

3.          Keep in mind that the Act uses the expression "every officer who is in de­fault" and not the expression "all officers in default by definition".

 

4.          Note that a Managing Director having whole or substantial powers of management can be charged with responsibility for compliance whenever there is violation of any section of the Act which uses the expression "every officer who is in default".

 

5.          It is difficult for that Managing Director to escape responsibility unless he can show that, as regards specific provision, another person has been duly charged with the responsibility for compliance.

 

6.          Note further that although a whole‑time Director is like a Managing Director having substantial powers of management, yet depending upon the particular area of Management over which he exercises substantial powers that his responsibility is to be fixed.

 

7.          A Whole‑time Director (Marketing) cannot be said to be responsible for violation of any section of the Act dealing with financial discipline.

 

8.          Where, however, no particular area of management is assigned to a Whole‑time Director, it will be difficult for the Whole‑time Director to escape responsibility, he being treated on the same footing as a Managing Director.

 

9.          Note that where a company has more than one Managing Director, all of them will be jointly and severally liable unless areas of responsibility have been clearly demarcated by the company and an intimation to this effect is available with the Registrar. Such an intimation may be available with the Registrar of Companies in terms of specific resolution passed under Section 292 of the Act.

 

10.        Note further that the Secretary of the company is invariably an officer in default, he being a principal officer responsible for compliance with the regulatory provisions of the statute.

 

11.        Note again that where a person has been charged with the responsibility for compliance under clause (f) of Section 5, others can escape responsibility but, the Secretary of the company will remain an officer in default along with the person charged.

 

12.        Note again that in the case of a company which is managed by the Board of Directors and which does not have any of the managerial persons mentioned in clauses (a) to (c) in Section 5, all the Directors can escape responsibility by charging one of the Directors with the sole responsibility of compliance with all the provisions of the Act where the expression "officer who is in default" does occur. Of course if such a company has a Secretary, the Secretary will be liable along with such a Director.

 

13.        It has been clarified by the Department of Company Affairs in the light of Rajasthan High Courts' judgement on Ravinder Narayan and others v. Registrar of Companies, Rajasthan, Jaipur, that where the penal provisions provide for punishment of officers in default prosecution be filed against the Managing Director(s), Whole‑time Director(s) and Manager, apart from the Secretary, if any, and the company and only in those cases where, there is no such managerial personnel that is Managing/Whole‑time Directors/Manager, prosecution be filed against all ordinary directors, apart from the Secretary, if any, and the company. [Circular No. 6/94, F. No. 3‑41‑93‑CL‑V, dated 24‑6‑1994].

 

 

E. Auditors

 

(Topic 90 to Topic 105)

 

Topic 90

 

DO YOU WISH TO APPOINT OR RE‑APPOINT AN AUDITOR?

 

A.          Appointment of the first auditor:

 

1.          Convene a Board Meeting after giving notice to all the directors of the company as per Section 286 within one month of the incorporation of the company and pass a resolution appointing the first auditor of the company to hold office till the conclusion of the first Annual General Meeting and fixing his remuneration. [Section 224(5)]

 

2.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/‑. [Section 286(2)]

 

3.          Ensure that the person appointed as the first auditor of the company does not hold any security of that company after a period of one year from the date of commencement of the Companies (Amendment) Act, 2000. [Section 226(3)(e)]

 

4.          Keep in mind that for the purposes of the above security means an instrument which carries voting rights. [Section 226(3)(e) Explanation]

 

5.          If the Board fails to do so within one month after the incorporation of the company hold a General Meeting by issuing noticest in writing at least twenty‑one days before the date of general meeting with relevant explanatory statement after fixing up the date, time, place and agenda by convening a Board Meeting and pass Ordinary Resolution by simple majority appointing the first auditor. [Section 224(5), Proviso (b) read with sections 171(1), 173(2) and section 189(1)]

 

6.          If a General Meeting is held for this purpose then forward promptly to the Stock Exchange with which the shares of your company are listed, three copies of the notice and a copy of the proceedings of the General Meeting. [Clause 31(c) and (d) of the Standard Listing Agreement].

 

7.          Intimate the auditor immediately about his appointment.

 

B.          Appointment of the retiring auditor :

 

1.          In case of any appointment to be made in respect of any financial year, get a written certificate from the auditor to the effect that the appointment, if made, will, be in accordance with the limits specified in Section 224(1B). [Section 224(1), Proviso].

 

2.          Note that the provisions of sub‑section (1B) of section 224 will not apply on and after the commencement of the Companies (Amendment) Act, 2000 to a private company. [Section 224(1B) fourth proviso]

 

3.          Convene an Annual General Meeting after issuing notices in writing at least twenty‑one days before the meeting along with relevant explanatory statement and pass an Ordinary Resolution by simple majority in the Annual General Meeting appointing the retiring auditor and fixing his remuneration, the notice of the said meeting should contain the said agenda. [Section 171(1) read with section 173(2) and section.166 ].

 

4.          Forward three copies of the notice and a copy of the proceedings of the Annual General Meeting to the Stock Exchange with which the shares of your company are listed. [Clause 31(c) and (d) of the Standard Listing Agreement].

 

5.          In the case of a company in which not less than twenty‑five per cent of the subscribed share capital is held whether singly or in combination by (a) a public financial institution or a Government Company or Central Government or any State Government, or (b) any financial or other institution established by any Provincial or State Act in which a Statd Government holds not less than fifty‑one per cent of the subscribed capital, or (c) a Nationalised Bank or an Insurance Company carrying on general insurance business, the appointment or reappointment of an auditor at each Annual General Meeting shall be made by passing a Special Resolutionf by three‑fourths majority. [Section 224A].

 

6.          Remember that the provisions of the aforesaid three clauses (a) (b) (c) are not mutually exclusive and would apply to all cases of shareholding in any combination by any of the institutions mentioned therein [General Circular No. 14 of 2001 dated 16‑7‑2001 of the Department of Company Affairs]

 

7.          Intimate the auditor of his appointment within seven days. [Section 224(1)].

 

8.          The Auditor has to inform the concerned Registrar of Companies' in Form No. 23B about his accepting or refusing the appointment within one month of the receipt of intimation of his appointment. [Section 224(1A)].

 

9.          No fee is required to be paid for filing the above‑mentioned form.

 

10.        File the Special Resolution with the Explanatory Statement in Form No. 23 with the concerned Registrar of Companies within thirty days of its passing after paying the requisite fee as prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury challan. [Rule 22].

 

11.        Please keep in mind that if default is made in complying with the aforesaid requirements, the company and every officer of the company who is in default will be punishable with fine upto Rs. 2000 for every day during which the default continues. [Section 192(5)]

 

C.          Appointment of an auditor other than the retiring one

 

Complete the formalities as per Topic 93.

 

D.         Appointment of a branch auditor other than that of the company's auditor:

 

1.          Convene a Board Meeting after giving notice to all the directors of the company as per Section 286 to fix up the date, time, place and agenda of a General Meeting to pass an Ordinary Resolution to the effect that the accounts of a particular branch of the company be audited by a particular auditor other than the company's auditor.

 

2.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/-. [Section 286(2)].

 

3.          Before appointing the said branch auditor, ensure that the person appointed as such does not hold any security of the company of which he is going to be the branch auditor after a period of one year from the date of commencement of the Companies (Amendment) Act, 2000. [Section 226(3)(e) read with section 228(1)] ,

 

4.          Keep in mind that for the purposes of above securit T, means an instrument which carries voting rights [Section 226(3)(e), Explanation]

 

5.          Issue notices in writing at least twenty‑one days before the General Meeting and hold the General Meeting and pass the Ordinary Resolution by simple majority and appoint the branch auditor or authorise the Board to appoint him in consultation with the company's auditor. [Section 228(3)(a)]

 

6.          Forward to the Stock Exchange with which the shares of your company are listed, promptly three copies of the notices and a copy of the proceedings of the General Meeting. [ Clause 31 (c) and (d) of the Standard Listing Agreement]

 

7.          In the case mentioned in item 3 consult the company's auditor for ap­pointing the branch auditor and then appoint him in a Board Meeting.

 

General Note :

 

1.          In all the above cases, an auditor should be a person who fulfils the quali­fications mentioned in Section 226.

 

2.          In case of a foreign branch, its auditor may also be an accountant duly qualified to act as an auditor of the accounts of the branch office in accordance with law of the foreign country concerned. [Section 226 and Section 228(1)].

 

3.          The auditor has to report on certain additional matters, as contained in the Manufacturing and Other Companies (Auditor's Report) Order, 1988.

 

4.          Note that for non‑compliance of the provisions of sections 225 to 231 the company and every officer of the company who is in default will be punishable with fine of upto Rs. 5000/-, [Section 232]

 

Topic 91

 

DO YOU WISH TO REVISE THE REMUNERATION OF A STATUTORY AUDITOR?

 

1.          Convene a Board Meeting after giving notice to all the directors of the company as per Section 286 to take the decision of increasing the remuneration of the statutory auditor and to fix the date, time, place and agenda of the General Meeting. [Section 224(8)(b)].

 

2.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/‑. [Section 286(2)]

 

3.          Issue notice in writing at least twenty‑one days before the date of the General Meeting proposing the Ordinary Resolution with suitable Explanatory Statement for increase of the remuneration of the statutory auditor. [Section 171(1) read with Section 173(2)]

 

4.          Hold the General Meeting and pass the Ordinary Resolution by simple majority. [Section 189(1)]

 

5.          Intimate the statutory auditor regarding such increase of remuneration.

 

6.          Forward promptly to the Stock Exchange with which the shares of your company are listed, three copies of the notices and a copy of the proceedings of the General Meeting. [Clause 31(c) and (d) of the Standard Listing Agreement].

 

Topic 92

 

DO YOU WISH TO APPOINT OR RE‑APPOINT AN AUDITOR OF A GOVERNMENT COMPANY?

 

1.          Auditor of a Government company is appointed or re‑appointed by the Comptroller and Auditor‑General of India. [Section 619(2)].

 

2.          Obtain a certificate from the auditor to be so appointed to the effect that such appointment, if made, will be within the specified number as mentioned in the Explanation I of Section 224(1C). [Section 224 (1B)].

 

3.          Keep in mind that the aforesaid certificate need not be obtained from the auditor to be so appointed if the Government Company is a private company, on and after the commencement of the company (Amendment) Act, 2000. [Section 224(lB) fourth proviso]

 

4.          Obtain the name of the person determined by the Comptroller and Audi­tor‑General of India, as the auditor of the Government Company.

            

5.          Convene a Board Meeting after giving notice to all the directors of the company as per Section 286 to fix the date, time, place and agenda of the Annual General Meeting to appoint the auditor by passing a Special Resolution. [Section 224A(1)]

 

6.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/-. [Section 286(2)]

 

7.          Issue notices in writing at least twenty‑one days before the date of the meeting and hold the Annual General Meeting and pass the Special Resolution by three‑fourths majority. [Section 171(1) read with section 189(2)]

 

8.          if the shares of the Government company are listed on a recognised Stock Exchange, forward promptly to the Stock Exchange three copies of the notice and a copy of the proceedings of the General Meeting. [Clause 31(c) and (it) of the Standard Listing Agreement.

 

9.          File a copy of the Special Resolution along with the Explanatory Statement with the concerned Registrar of Companies within thirty days of its passing in Form No. 23 after paying requisite fee [Section 192(1) & (4)(a)] prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury Charlene [Rule 22].

 

10.        Please also keep in mind that if default is made in complying with the aforesaid requirements, the company and every officer of the company who is in default will be punishable with fine upto Rs. 200/- for every day during which the default continues. [Section 192(5)]

 

11.        Within seven'days of the appointment, give intimation to the auditor so appointed by the Comptroller and Auditor‑General of India. [Section 619 read with section 224(1)].

 

12.        See that the auditor, within thirty days of such receipt of intimation, gives notice to the concerned Registrar of Companies in Form No. 23B stating whether he has accepted or refused the appointment. [Section 224(1A)].

 

13.        No filing fee is required to be paid for giving the above‑mentioned notice.

 

14.        Further keep in mind that, the remuneration of the auditor appointed under section 619 by the Comptroller, and Auditor‑General of India will be fixed by the company in General Meeting or in such manner as the company in General Meeting may determine. [Section 224(8)(aa)]

 

Topic 93

 

DO YOU WISH TO CHANGE THE AUDITOR OF YOUR COMPANY?

 

1.          Receive special notice from member of your company, indicating intention to move a resolution for changing the existing auditor of the company and for appointing another auditor in his place in the ensuing Annual General Meeting. [Section 225(1) read with section 190].

 

2.          See that this special notice is received by the company not less than fourteen days before the Annual General Meeting, exclusive of the day on which the notice is served or deemed to be served and the day of the meeting. [Section 190(1)].

 

3.          Also see that this special notice complies with the requirements of Section 188 of the Act. Pedley v. Inland Waterways Association Ltd., (1977) 1 All ER 209 (ChD).

 

4.          Send forthwith a copy of the aforesaid notice to the existing auditor of  your company. [Section 225(2)].

 

5.          Get a written certificate from the proposed auditor to the effect that the appointment, if made, will be in accordance with the limits specified in Section 224(1B). [Section 224(1), Proviso].

 

6.          Keep in mind that the aforesaid certificate need not be obtained from the proposed auditor if your company is a private company on and after the commencement of the Companies (Amendment) Act, 2000. [Section 224(1B) fourth Proviso].

 

7.          Issue noticest in writing at least twenty‑one days before the date of the Annual General Meeting stating about the special notice and proposing the Ordi­nary Resolution for change along with relevant Explanatory Statement. [Section 171(1) read with section 190].

 

8.          State in the notice the fact about representations, if any, made by the auditor concerned and enclose the copy of the representation.

 

9.          If the representations could not be sent along with the notice for being received late, send the same later on. [Section 171(1) read with sections 173(2) and 225(3)].

 

10.        In case it is not possible to state about the special notice in the notice of the Annual General Meeting, then inform the members either by advertisement in a newspaper having an appropriate circulation or in any other mode allowed by the Articles of Association of the company not less than seven days before the meeting. [Section 190(2)].

 

11.        Forward three copies of the notice to the Stock Exchange with which the shares of your company are listed [Clause 31(c) and (e) of the Standard Listing Agreement].

 

12.        Hold the General Meeting and pass the Ordinary Resolutionj by simple majority. [Section 189(1)].

 

13.        The resolution required is Ordinary Resolution except as provided in Sec­tion 224A.

 

14.        If the representations were not sent to members earlier for the reason that they were received too late or because of default of the company, read out the same in the meeting if the auditor concerned so requires.

 

15.        The auditor concerned has also the right to be heard at the meeting. But in certain circumstances, the Company Law Board can exempt the company from sending or reading out the representations on the application either of the company or of any of the persons who claims to be aggreived. [Section 225(3), Proviso].

 

16.        Forward a copy of the proceedings of the General Meeting to the Stock Exchange with which the shares of your company are listed [Clause 31(d) of the Standard Listing Agreement].

 

17.        Promptly notify to the Stock Exchange with which the shares of your company are listed of the change of auditors [Clause 30(c) of the Standard Listing Agreement].

            

18.        Send intimations thereof to the newly appointed auditor within seven days. [Section 224(1)].

 

19.        The new auditor has to inform the concerned Registrar of Companies in Form No. 23B about his accepting or not accepting the appointment within a month from the receipt by him of intimation of his appointment.

 

20.        No fee is required to be paid for filing the above mentioned form. [Section 224(1A)].

 

21.        Note that for non‑compliance of the provisions of section 225, the company and every officer of the company who is in default will be punishable by way of fine of upto Rs. 5000/‑. [Section 232].

 

Topic 94

 

DO YOU WISH TO REMOVE THE AUDITOR OF YOUR COMPANY BEFORE THE EXPIRY OF HIS TERM OF OFFICE?

 

1.          Convene a Board Meeting after giving notice to all the directors of the company as per Section 286 to approve the draft of the application to be sent to the Central Government for sanctioning the removal of the auditor. [Section 224(7)].

 

2.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/‑. [Section 286(2)]

 

3.          Make an applicationf to the Regional Director of the concerned region seeking approval of the removal of the auditor before the expiry of his term, as the aforesaid power has been delegated to the Regional Director.

 

4.          There is no prescribed form of the aforesaid application,f and therefore should be made in the letter head of the company.

 

5.          The application must be addressed to the concerned Regional Director, Kanpur or Calcutta or Mumbai or Chennai, as the case may be, depending on its jurisdiction on the particular region in which the company's registered office is situated, and must state the reasons in detail for the removal of the auditor and it must be accompanied by the following documents:

 

(i)          A certified true copy of your company's Memorandum and Articles of Association.

 

(ii)         A treasury challan or demand draft evidencing the payment of the requisite fee prescribed under the Companies (Fees on Applications) Rules, 1999.

 

(iii)         Reasons for removal of the auditor before the expiry of the term.

 

6.          If the application fee is paid by way of treasury challan, then pay the req­uisite fee of minimum Rs. 500/‑ and maximum Rs. 2000/‑, as the case may be, and as prescribed by the Companies (Fees on Applications) Rules, 1999,3 by way of treasury challan prepared in triplicate and paid in cash into any of the specified branches of the Punjab National Bank for credit.

 

7.          The description of the Head of account of the treasury challan should be as prescribed under Rule 22(2) of the Companies (Central Government's) General Rules and Forms, 1956 and as amended vide GSR 251(E), dated 21‑6‑1996 (w.e.f 21‑6‑1996). For account head and code please see Rule 22(2) in Appendix 1.

 

8.          Two copies of the treasury challan will be given back to the depositor by the said branch of the bank and the original copy should be filed along with the application made to the concerned Regional Director.

 

9.          If the application fee is paid by way of demand draft, then draw the demand draft in favour of "Pay and Accounts Officer, Department of Company Affairs, Mumbai/ Calcutta/Chennai as the case may be and payable at city where the concerned Regional Director is situated and the said demand draft should be attached to the application made to the concerned Regional Director. For payment of application fee by way of demand draft to the Regional Director, Northern Region, Kanpur, draw the demand draft in favour of "Regional Director, N.R., Department of Company Affairs, Kanpur", and payable at Kanpur.

 

10.        Deliver a copy of the application to the concerned Registrar of Compa­nies, for information.

 

11.        On receipt of approval, convene a Board Meeting after giving notice to all the directors of the company as per Section 286 to fix the date, time, place and agenda of the General Meeting where the auditor will be removed, and also another auditor will be appointed in his place.

 

12.        Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/‑. [Section 286(2)]

 

13.        Issue noticest in writing at least twenty‑one days before the date of the General Meeting along with the relevant explanatory statement and hold the General Meeting and remove the auditor by passing an Ordinary Resolutionj by simple majority, and appoint new auditor in his place. [Section 171(1) read with section 173(2) and section 189(1)].

 

14.        If the shares of your company are listed on a recognised Stock Exchange, then do the following:­

 

(i)          Forward to the Stock Exchange three copies of the notice of the meeting issued to the shareholders;

 

(ii)         Forward to the Stock Exchange a copy of the proceedings of the General Meeting;

 

(iii)         Notify promptly to the Stock Exchange the removal of the auditor.

[Clauses 31(c) & (d) and 30(c) of the Standard Listing Agreement].

 

15.        Deliver to the concerned Registrar of Companies a copy of the approval, letter obtained by the company from the Regional Director.

 

16.        Note that as per the Citizen's Charter of the Department of Company Affairs, Schedule II, Serial No. 3, the application made to the Regional Director will be processed within 45 days. [No. 5/25/99‑CL‑V, Press Note No. 9/99, dated 9‑8‑1999].

 

Topic 95

 

DO YOU WISH TO APPOINT AN AUDITOR ALREADY HAVING MORE THAN TWENTY AUDITS?

 

1.          Please note that the requirement of section 224, after its amendment by the Companies (Amendment) Act, 1988, is not to appoint a person as auditor who is in full‑time employment elsewhere and who is already holding appointment as auditor of the specified number of companies. [Section 224(1‑B)].

 

2.          In case, the person is in part‑time employment, the restrictions on the number of audits do not apply to him.

 

3.          Again, if the person is in full‑time practice and is not in full‑time employ­ment elsewhere, these restrictions on the number of audits do not apply to him.

 

4.          If the person proposed to be appointed is practising in his individual capacity, he can be appointed as auditor of any number of companies and his appointment need not be confined to twenty companies of which not more than ten shall be companies having a paid‑up share capital of Rs. 25 lakhs or more. [Section 224(1‑C) Explanation]

 

5.          Please note that the provisions of sub‑section (1‑B) of section 224 will not be applicable to a private company on and after the commencement of the Companies (Amendment) Act, 2000. [Section 224(1B) fourth proviso]

 

6.          Further note that if your company is a private company which is a subsidiary of a public company, it will be treated as a public company. [Section 3(1)(iv)(c)]

 

Topic 96

 

DO YOU WISH TO APPOINT OR RE‑APPOINT A COST AUDITOR? [SECTION 233B]

 

1.          Upon receipt of the order of the Central Government under Section 233B(1) determine the name of the Cost Auditor at a Board Meeting convened after giving notice to all the directors of the company as per Section 286 and pass a resolution sanctioning the proposal for making the application to the Central Government to appoint a cost auditor.

 

2.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine.of upto Rs. 1000/‑. [Section 286(2)]

 

3.          Obtain a written certificate from the cost auditor to the effect that the appointment, if made, will be in accordance with the provisions of Section 224(lB). [Section 233B(2), Proviso].

 

4.          Note that the aforesaid certificate need not be obtained from the cost auditor if your company is a private company, on and after the commencement of the Companies (Second Amendment) Act, 1999. [Section 224(1B)fourth proviso]

 

5.          Note that the cost auditor so appointed should not hold any security of your company after a period of one year from the date of commencement of the Companies (Amendment) Act, 2000. [Section 226(3)(e)]

 

6.          Obtain the approval of the Central Government for appointing the Cost Auditor as determined in item 1 above, by making an application to it in Form No. 23C [Section 233B(2)]

 

7.          Get the application signed by any director, managing or whole‑time di­rector, manager or the secretary of your company.

 

8.          Send along with the application a receipted treasury challan or demand draft evidencing the payment of requisite fees, prescribed under the Companies (Fees on Applications) Rules, 1999.

 

9.          If the application fee is paid by way of treasury challan, then pay the requisite fee of minimum Rs. 500/‑ and maximum Rs. 2000/‑, as the case may be, and as prescribed by the Companies (Fees on Applications) Rules, 1999, by way of treasury challan prepared in triplicate and paid in cash into any of the specified branches of the Punjab National BanO for credit.

 

10.        The description of the Head of account of the treasury challan should be as prescribed under Rule 22(2) of the Companies (Central Govemment's) General Rules and Forms, 1956 and as amended vide GSR 251(E), dated 21‑6‑1996 (w. ef 21‑6‑1996). For account head and code please see Rule 22(2) in Appendix 1.

 

11.        Two copies of the treasury challan will be given back to the depositor and the original copy of the treasury challan. should be attached to the application made to the Central Government mentioned in item 6.

 

12.        If the application fee is paid by way of demand draft, then draw the demand draft in favour of "Pay and Accounts Officer, Department of Company Affairs, New Delhi", and payable at any bank located in New Delhi, and the said demand draft should be attached to the application made to the Central Government mentioned in item 6.

 

13.        Deliver to the concerned Registrar of Companies' a copy of the applica­tion together with a copy of all the documents attached to it.

 

14.        Hold another Board Meeting after giving notice to all the directors of the company as per Section 286 to pass a Resolution and to appoint the Cost Auditor.

 

15.        Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/-. [Section 286(2)]

 

16.        Give intimation to the Auditor about the appointment.

 

17.        Deliver a certified true copy of the Central Government's approval to the concerned Registrar of Companies.

 

18.        See that the cost auditor so appointed/re‑appointed is not the statutory auditor of the company as appointed under Section 224(3) and he should also not be a person falling under sub‑sections (3) and (4) of Section 226. [Section 233B(5)]

 

19.        This appointment of Cost Auditor applies only where the Central Government has prescribed maintenance of cost records under Section 209(1)(d) and directed under Section 233B that the audit of the cost accounts be conducted. [Section 233B(1)].

 

20.        Note that if a company fails to appoint a Cost Auditor that company will be punishable with fine of upto Rs. 50,000/- and every officer of that company who is in default will be punishable with imprisonment for term of three years or with fine of upto Rs. 50,000/- or with both. [Section 233B(11)]

 

21.        Further note that as per the Citizen's Charter of the Department of Company Affairs, Schedule I, Serial No. 20, the application made to the Central Government will be processed within 30 days. [No. 5/25/99‑CL‑V, Press Note No. 9/99, dated 9‑8‑1999.]

 

Topic 97

 

DO YOU WISH TO HAVE THE AUDITOR APPOINTED BY THE CENTRAL GOVERNMENT?

 

1.          If in your Annual General Meeting neither the retiring auditor nor any other auditor is re‑appointed or appointed, the Central Government may appoint a person to fill the vacancy. [Section 224(3)]

 

2.          Give notice to the Regional Director, Kanpur or Calcutta or Mumbai or Chennai, as the case may be, depending on its jurisdiction on the particular region in which the company's registered office is situated within seven days from the date of the Annual General Meeting stating that no auditor has been appointed or re‑appointed in that meeting. [Section 224(4)]

 

3.          Prepare the aforesaid notice on plain paper, preferably on the letter head of your company as there is no prescribed form of the said notice.

 

4.          State in the notice the reasons for which no auditor could be appointed or re‑appointed.

 

5.          Attach the following documents along with the notice:­

 

(i)          A certified true copy of the proceedings of the General Meeting;

 

(ii)         A certified true copy of the Memorandum and Articles of Association of your company;

 

(iii)         A certified true copy of the Annual Report.

 

(iv)        A treasury challan or demand draft evidencing the payment of the requisite fee of minimum Rs. 500/‑ and maximum Rs. 2000/- as the case may be and as rescribed by the Companies (Fees on Applications) Rules, 1999.

 

6.          Deliver simultaneously to the concerned Registrar of Companies' a copy of the notice along with a copy of each of the documents annexed to it.

 

7.          On receipt of the Regional Director' order, the person whom the Central Government has directed to be appointed as the auditor of the Company will be the auditor of your company and will hold office till the conclusion of the next Annual General Meeting.

 

8.          Such an auditor will be paid remuneration as fixed by the Central Gov­ernment.

 

9.          Give intimation within seven days from the date of receipt of the Central Government's order to the person appointed as auditor of your company by the Central Government [Section 224(1)]

 

10.        See that auditor informs the concerned Registrar of CornpanieS by giving a notice in Form No. 23B within thirty days from the receipt by him of intimation of his appointment.

 

11.        No filing fee is required to be paid for giving the above‑mentioned notice.

 

12.        Since the Auditor is appointed by the Regional Director, it is presumed that the certificate under Section 24(1B) must already have been given by him, otherwise such a certificate should be obtained from the said auditor before his appointment.

 

13.        Keep in mind that if your company is a private company the, provisions of sub‑section (1B) of section 224 will not be applicable to your company on and after the commencement of the Companies (Section Amendment) Act, 1999. [Section 224 (1B) fourth proviso]

 

14.        Note that if a company fails to give notice within seven days to the Central Government, the company and every officer of the company who is in default will be punishable with fine of upto Rs. 5000/‑. [Section 224(4)].

 

Topic 98

 

DO YOU WISH TO APPOINT THE AUDITOR OF A COMPANY WHOSE 51 PER CENT OR MORE OF THE PAID‑UP SHARE CAPITAL IS HELD BY ONE OR MORE OF THE COMBINATIONS STATED UNDER SECTION 619B?

 

1.          Auditor of such a company is appointed or re‑appointed by the Comptroller and Auditor‑General of India. [Section 619(2) read with Section 619B].

 

2.          Obtain a certificate from the auditor to be so appointed to the effect that such appointment, if made, will be within the specified number as mentioned in the Explanation I of Section 224(1C). [Section 224(1B)]

 

3.          Keep in mind that the aforesaid certificate need not be obtained from the auditor to be so appointed on and after the commencement of the companies (Amendment) Act, 2000, if the company is a private company. [Section 224(1B) fourth proviso]

 

4.          Obtain the name of the person determined by the 'Comptroller and Audi­tor‑General of India as the auditor of the company.

 

5.          Convene a Board Meeting after giving notice to all the directors of the company as per Section 286 to fix the date, time, place and agenda of the Annual General Meeting to appoint the auditor by passing a Special Resolution. [Section 224A(1)]

 

6.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/-. [Section 286(2)]

 

7.          Issue notices in writing at least twenty‑one days before the date of the meeting along with relevant explanatory statement. [Section 171(1) read with section 173(2)]

 

8.          Hold the Annual General Meeting and pass the Special Resolution by  three‑fourths majority. [Section 189(2)]

 

9.          If the shares of the Government company are listed on a recognised Stock Exchange, forward promptly to the Stock Exchange three copies of the notice and a copy of the proceedings of the General Meeting. [Clause 31(c) and (d) of the Standard Listing Agreement]

 

10.        File a copy of the Special Resolution along with the Explanatory Statement with the concerned Registrar of Companiess within thirty days of its passing in Form No. 23 after paying requisite fee [192(1) & (4)(a)] prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury challan. [Rule 22].

 

11.        Please also keep in mind that if default is made in complying with the aforesaid requirements, the company and every officer of the company who is in ,default will be punishable with fine upto Rs. 200/‑ for every day during which the default continues. [Section 192(5)]

 

12.        Within seven days of the appointment, give intimation to the auditor so appointed by the Comptroller and Auditor‑General of India. [Section 619 read with Section 224(1) and (8)(aa)].

 

13.        See that the auditor within thirty days of such receipt of intimation, gives notice to the concerned Registrar of Companies in Form No. 23B stating whether he has accepted or refused the appointment. [Section 224(1A)].

 

14.        No filing fee is required to be paid for giving the above‑mentioned notice.

 

Topic 99

 

DO YOU WISH TO APPOINT AN INTERNAL AUDITOR UNDER SECTION 227(4A)?.

 

1.          Verify the following before taking the decision of appointing an internal auditor:­

 

(i)          Whether your company is engaged in one or more of the following activities mentioned in clause 1(2) of the Manufacturing and Other Companies (Auditor's Report) Order, 1988, namely:

 

(a)         manufacturing, mining or processing;

 

(b)         supplying and rendering services;

 

(c)         trading; and

 

(d)         the business of financing, investment, chit fund, nidhi or mutual benefit societies.

 

(ii)         Whether your company being engaged in any of the abovementioned activities comes within the scope of the definitions given in clause (2)(a) to (h) of the same order.

 

2.          Convene a Board Meeting after giving notice to all the directors of the company as per Section 286 and appoint the internal auditor and fix his remu­neration by passing a resolution.

 

3.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine of Rs. 1000/‑. [Section 286(2)]

 

4.          Intimate the internal auditor so appointed.

 

5.          Note that if a company fails to appoint an internal auditor under section 227(4‑A) read with the Manufacturing and Other Companies (Auditor's Report) Order, 1988 then the company and every officer of the company who is in default will be punishable with fine of upto Rs. 5000/‑. [Section 232]

 

Topic 100

 

DO YOU HAVE A CASE WHERE A SPECIAL AUDITOR IS APPOINTED UNDER SECTION 233A?

 

1.          See whether you have received an order of the Central Government directing a special audit of the company's accounts for such period or periods as may be specified in the order.

 

2.          The Central Government may also by a separate or the same order appoint a Chartered Accountant or the company's Statutory Auditor as the Special Auditor. [Section 233A(1) & (2)]

 

3.          See that the special auditor holds office for such period or periods as may be specified in the Central Government's order and has same powers and duties in relation to the special audit as an auditor of the company under Section 227. [Section 233A(3)]

 

4.          Convene a Board Meeting after giving notice to all the directors of the company as per Section 286 and pass a resolution to pay as determined by the Central Government the expenses of and incidental to any such special audit conducted by the special auditor appointed under the order of the Central Government. [Section 233A(7)]

 

5.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/‑. [Section 286(2)]

 

6.          Intimate the statutory auditor regarding his appointment as a special auditor if the Central Government by order under section 233A(1) appoints him as the special auditor.

 

7.          Please also keep in mind that the Central Government may by order direct any person specified in its order to furnish to the special auditor within such time as may be specified therein such information or additional information as may be required by the special auditor in connection with the special audit and if such person fails to comply with such order, he will be punishable with fine upto Rs. 5,000/-.[Section 233A(5)]

 

8.          On receipt of the report from the special auditor, the Central Government shall send to the company after four months of such receipt either a copy of or relevant extracts from the report with its comments thereon and require the company either to circulate it to the members or have it read at the immediately next General Meeting. [Section 233A(6)].

 

9.          On receipt of such comments, circulate it among all the members of the company after getting it printed.

 

10.        See that such comments are also read at the next General Meeting.

 

11.        Note that if default is made in the payment of the expenses of and incidental to any special audit as determined by the Central Government, such payment will be recoverable from the company as an arrear of land revenue. [Section 233A(7)]

 

Topic 101

 

DO YOU WISH TO APPOINT AN AUDITOR IN CASUAL VACANCY UNDER SECTION 224(6)(a) ?

 

1.          Verify whether the vacancy in the office of the auditor is caused by the resignation of the auditor, or not.

 

2.          If not, then hold a Board Meeting after giving notice to all the directors of the company as per Section 286 and pass a resolution appointing an auditor to fill the casual vacancy and fix his remuneration. [Section 224(8)(a)]

 

3.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/‑.[Section 286(2)]

 

4.          Obtain a written certificate from the auditor to the effect that the appointment, if made, will be in accordance with the limits specified in Section 224(1B).

            

5.          Note that the aforesaid written certificate is not required to be obtained from the auditor if your company is a public company. [Section 224(1B) fourth proviso]

 

6.          See that the auditor so appointed in casual vacancy holds office until the conclusion of the company’s next Annual General Meeting. [Section 224(6)(b)]

 

7.          Intimate the auditor so appointed in casual vacancy immediately.

 

8.          See that till the Board fills up the casual vacancy, the remaining auditor or auditors of the company, if any, continues or continue to act. [Section 224(6)(a)]

 

9.          If the shares of your company are listed on a recognised Stock Exchange promptly notify the exchange about the change in the auditor. [Clause 30(c) of the Standard Listing Agreement]

 

10.        Further note that the auditor so appointed does not suffer from any of the disqualifications mentioned in section 226(3).

 

Topic 102

 

DO YOU WISH TO APPOINT AN AUDITOR IN A VACANCY CAUSED BY THE RESIGNATION OF AN EXISTING AUDITOR?

 

1.          Convene a Board Meeting after giving notice to all the directors of the company as per Section 286 and fix the date, time, place and agenda for holding a General Meeting to pass an Ordinary Resolution to appoint an auditor in a vacancy caused by resignation of the existing auditor. [Section 224(6)(a), Proviso].

 

2.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/‑. [Section 286(2)]

 

3.          Obtain a written certificate from the auditor to the effect that the appoint­ment, if made, will be in accordance with the limits specified in Section 224(1B).

 

4.          Note that the aforesaid written certificate is not required to be obtained from the auditor if your company is a public company. [Section 224(1B) fourth proviso]

 

5.         

(i)          Issue notices in writing at least twenty‑one days before the date of the General Meeting with suitable Explanatory Statement. [Section 171(1) read with section 173(2)].

 

(ii)         Hold the General Meeting and pass the Ordinary Resolution by simple majority. [section 189(1)].

 

6.          See that the auditor so appointed holds office until the conclusion of the next Annual General Meeting of the company.

 

7.          Intimate the auditor so appointed, in casual vacancy immediately.

 

8.          See that till the auditor is so appointed in the General Meeting remaining auditor or auditors of the company, if any, acts or act during the continuation of such vacancy.

 

9.          Promptly forward to the Stock Exchange with which the shares of your company are listed, three copies of the notices and a copy of the proceedings of the General Meeting. [Clause 31(c) and (d) of the Standard Listing Agreement]

 

10.        Further note that the auditor so appointed does not suffer from any of the disqualifications mentioned in section 226(3).

 

Topic 103

 

DO YOU WISH TO HAVE THE AUDITOR OF YOUR COMPANY THE REQUISITE QUALIFICATIONS AND NOT TO SUFFER FROM ANY DISQUALIFICATIONS? [SECTION 226 OF THE ACT]

 

1.          If your company wants to appoint an auditor in his individual capacity then see that the said auditor is a chartered accountant in practice. [Section 226(1)]

 

2.          If your company wants to appoint a firm then see that all the partners of that firm are practising in India and are chartered accountants. [Section 226(1), Proviso]

 

3.          Where a firm is appointed as the auditor of your company then see that the said firm is appointed by its name to be the auditor of your company and in such case any partner of that firrd may act in the name of the firm. [Section 226(1), Proviso]

 

4.          While appointing an auditor of your company whether in individual capacity or in the name of the firm ensure that the said auditor is qualified to be so appointed and does not suffer from the following disqualifications:

 

(i)          the auditor is not a body corporate; [Section 226(3)(a)]

 

(ii)         the auditor is not an officer or employee of your company; [Section 226(3)(b)]

 

(iii)         the auditor is not a person who is a partner or who is in the employment of an officer or employee of your company; [Section 226(3)(c)]

 

(iv)        the auditor is not a person who is indebted to your company for an amount exceeding Rs. 1,000/‑or who has given any guarantee or provided any security in connection with the indebtedness of any third person to your company for an amount exceeding Rs. 1,000/‑; [Section 226(3)(d)]

 

(v)         the auditor is not a person holding any security of the company after a period of one year from the date of commencement of the Companies (Second Amendment) Act, 2000. [Section 226(3)(e)]

 

5.          Remember that for the above purpose security means an instrument which carries voting rights. [Section 226(3)(e) Explanation]

 

6.          Keep in mind that while appointing an auditor of your company whether in individual capacity or in the name of the firm ensure that the said auditor. is also qualified to be appointed and does not exceed the limits of specified member of companies mentioned in section 224(1B) read with Explanations I and II to sub‑section (1C) of section 224.

 

7.          Note that if your company is a private company the aforesaid disqualifica­tion will not be applicable to your company. [Section 224(1B) Fourth Proviso]

 

8.          Further note that if your company is a private company which is also a subsidiary of a public company by virtue of sub‑clause (c) of clause (vi) of subsection (1) of section 3.

 

9.          Keep in mind your company should not appoint an auditor who is disqualified as above for appointment as an auditor in any body corporate which is your company's subsidiary company or which is your company's holding company or which is the subsidiary company of your company's holding company or in any other body corporate which is a company. [Section 226(4)]

 

10.        Note that if after the appointment of the auditor of your company the said auditor is subject to any of these disqualifications he will be deemed to have vacated office as your company's auditor. [Section 226(5)]

 

11.        Further note that if default is made in coplying with the aforesaid requirements, the company and every officer of the company who is in default will be punishable with fine of upto Rs. 5000/-. [Section 232].

 

 

Topic 104

 

DO YOU WISH TO VERIFY WHETHER THE AUDITOR OF YOUR COMPANY HAS BEEN GIVEN ADEQUATE POWERS AND HAS BEEN DISCHARGING NECESSARY DUTIES PROVIDED UNDER THE ACT? [SECTION 227 OF THE ACT]

 

1.          Give every auditor of your company the right of access at all times to the books of account and vouchers of your company whether kept at your company's head office or elsewhere. [Section 227(1)]

 

2.          Allow the auditor of your company to get from the officers of your company such information or explanation as that auditor may think necessary for the performance of his duties as auditor. [Section 227(1)]

 

3.          Allow the auditor of your company to inquire whether loans and advances made by your company on the basis of security have been properly secured and whether the terms on which they have been made are not prejudicial to the interests of your company or its members. [Section 227(1A)(a)]

 

4.          Allow the auditor of your company also to inquire whether transactions of your company which are represented merely by book entries are not prejudicial to the interests of your company. [Section 227(1A)(b)]

 

5.          If your company is not an investment company or a banking company then allow the uditor of your company also to inquire whether so much of the assets of your company as consist of securities, debentures and other securities have been sold at a price less than that at which they were purchased by your company. [Section 227(1A)(c)]

 

6.          Further allow the auditor of your company to inquire whether loans and advances made by your company have been shown as deposits. [Section 227(1A)(d)]

 

7.          Also allow the auditor of your company to inquire about personal ex­penses that have been charged to revenue account. [Section 227(1A)(e)]

 

8.          Where it is stated in the books and papers of your company that any securities have been allotted for cash then allow the auditor of your company to inquire whether cash has actually been received in respect of such allotment and if no cash has actually been so received, whether the position as stated in the account books and the balance‑sheet is correct, regular and not misleading. [Section 227(1A)(f)]

 

9.          See that the auditor of your company makes a report to the members of your company on the account examined by him and on every balance‑sheet and profit and loss account and on every other document declared by the Act to be part of or annexed to the balance‑sheet or profit and loss account which was laid before your company in its annual general meeting during the auditors tenure of office. [Section 227(2)]

 

10.        Ensure that the aforesaid report given by the auditor of your company states whether in your company's auditor's opinion and to the best of his information and according to the explanations given to him, the said accounts give the information required by the Act in the manner so required and give a true and fair view [Section 227(2)] with regard to the following:

 

(i)          the state of your company's affairs as at the end of its financial year in the case of the balance‑sheet; [Section 227(2)(i)]

 

(ii)         the profit or loss for your company's financial year in the case of the profit and loss accounts. [Section 227(2)(ii)]

 

11.        Ensure that the auditor's report also states the reasons for answering in the negative or with a qualification with regard to the aforesaid two matters if they are answered in the negative or with a qualification. [Section 227(4)]

 

12.        Further ensure that the auditor's report states whether the auditor of your company has obtained all the information and explanations which to the best of his knowledge and belief were necessary for the purposes of his audit. [Section 227(3)(a)]

 

13.        Also ensure that the auditor's report of your company states whether in the opinion of your company's auditor proper books of account as required by law have been kept by the company so far as appears from the auditor's exarnination of those books and proper returns adequate for the purposes if his audit have been received from branches not visited by the auditor. [Section 227(3)(b)]

 

14.        Also ensure that the auditor's report of your company states whether the report on the accounts of any branch office audited by another auditor has been forwarded to your company's auditor as required under section 184(3)(c) and how he has dealt with the same in preparing the auditor's report. [Section 227(3)(bb)]

 

15.        Also ensure that the auditor's report of your company states whether your company's balance‑sheet and profit and loss account dealt with by the said report are in agreement with the books of account and returns. [Section 227(3)(c)].

 

16.        Further ensure that the auditor's report of your company states in thick type or in italics the observations or comments of the auditor which have any adverse effect on the functioning of the company. [Section 227(3)(d)]

 

17.        Further ensure that the auditor's report of your company states whether any director of your company is, disqualified from being appointed as director under clause (g) of sub‑section (1) of section 274. [Section 227(3)(e)]

 

18.        Further ensure that the auditor's report of your company states whether the profit and loss account and balance‑sheet of your company comply with the Accounting Standards referred to in sub‑section (3C) of section 211. [Section 227(3)(d)]

 

19.        See that the auditor's report of your company also gives the answers to the reasons as to why any matters given under items 12,13,14 and 15 have been an$wered in the negative or with a qualification if it is so given. [Section 227(4)]

 

20.        Ensure that the auditor follows the Standard. Auditing Practice (SAP) 16 for going concern for all audits relating to accounting periods beginning on or after April, 1999.

 

21.        Note that the accounts of your company will not be deemed as not having been properly drawn up and the auditor's report of your company also should not state so merely on the ground that your company has not disclosed certain matters which are not required to be disclosed by your company by virtue of any provision of the Act or any other Act and that those provisions are already specified in your company's balance‑sheet and profit and loss account. [Section 227(5)]

 

22.        Note that if your company fails to comply with the provisions of section 227 then the company and every officer of the company who is in default will be punishable with fine of upto Rs. 5000/‑. [Section 232] .

 

23.        Further ensure that your Company's auditor follows the guidance note on auditor's duties in relation to the year 2000 (Y2K) published in The Chartered Accountant issue of January, 1999.

 

24.        Keep in mind that if an auditor does not add a paragraph in his report about the requirement as mentioned in item 16 above the Department of Company Affairs will be constrained to take penal action against such an auditor as well as refer the matter to the Institute of Chartered Accountants of India for initiating disciplinary proceedings against him. [Press Note No. 7/99 (F.No. 2/9/99‑V), dated 23‑ 7‑1999].

 

Topic 105

 

DO YOU WISH TO VERIFY THE ENTITLEMENTS OF THE AUDITORS OF YOUR COMPANY?

 

1.          Ensure that all notices of any general meeting of your company and any other communications relating to any general meeting of your company are sent to the auditors' of your company. [Section 231]

 

2.          Also ensure that the auditors of your company attend all the general meetings of the company. [Section 231]

 

3.          Further ensure that the auditors of your company are allowed to be heard at any general meeting of the company which they attend on any part of the business which concerns them as auditors. [Section 231]

 

4.          Further ensure that the auditors' report of your company is read before the company in the annual general meeting by the secretary of the company. [Section 230]

 

5.          Keep the auditors report of your company open for inspection by any member of your company. [Section 230]

 

6.          Keep in mind that if your company defaults in complying with the provisions of sections 230 and 231 as aforesaid, the company and every officer of the company who is in default will be punishable with fine of upto Rs. 5000/‑. [Section 232]

 

 

F. Sole Selling Agents

 

(Topic 106 and Topic 107)

 

Topic 106

 

DO YOU WISH TO APPOINT/RE‑APPOINT SOLE SELLING/ BUYING AGENTS?

 

A.          In the case of companies having a paid‑up share capital of less than Rs.50 lakhs:

 

1.          Convene a Board Meeting after giving notice to all the directors of the company as per Section 286 and pass a resolution appointing the sole selling agent fixing the terms and conditions of appointment.

 

2.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/‑. [Section 286(2)]

 

3.          In the same board meeting also fix the date, time, place and agenda of the General Meeting to pass an Ordinary Resolution. [Section 294(2)]

 

4.          Disclose complete interests of directors, if any. In the case of a public company or its subsidiary or a holding company, no director who is interested or concerned in any way, whether directly or indirectly, in the contract of appointment should take part in discussion or voting nor his presence should be counted in the quorum for that purpose. [Section 300]

 

5.          Please also keep in mind that every director who knowingly contravenes the provisions of section 300 will be punishable with fine upto Rs. 50,000/‑.

 

6.          See that the terms and conditions of appointment or re‑appointment do not contain the term exceeding five years at a time. [Section 294(1)]

 

7.          Issue notices in writing at least twenty‑one days before the date of the General Meeting proposing the Ordinary Resolution with suitable Explanatory Statement. [Section 294(2) read with sections 171(1) and 173(2)]

 

8.          Hold the General Meeting and pass the Ordinary Resolution by simple majority to approve the appointment of a sole selling agent. [Section 189(1)]

 

9.          If the General Meeting does not approve the same, the appointment will cease to be valid from the date of the General Meeting. [Section 294(2A)]

 

10.        Alternatively, without going through the procedure as mentioned in items 1, 2, 3, 4 and 5 hold a General Meeting straight away after fixing up the date, time, place and agenda in a Board Meeting and pass an Ordinary Resolution by simple majority therein to approve the appointment of the sole selling agent.

 

11.        Forward three copies of the notices and a copy of the proceedings of the General Meeting to the Stock Exchange with which the shares of your company are listed. [Clause 31(c) and (d) of the Standard Listing Agreement]

 

12.        Where an individual, firm or body corporate has substantial interest in the company, such individual, firm or body corporate cannot be appointed sole selling agent or buying agent except with the previous approval of the Central Government. [Section 294AA(2)]

 

13.        Note that in case the aforesaid provision is not attracted to the appointment of sole selling agent or buying agent of your company at the time of entering of agreement with him, it will not be obligatory on your company to comply with the aforesaid requirement for the continuance of the said appointment for the re‑maining duration of his current tenure but not during any extension thereof even if the provisions of section 294AA(2) become applicable after the appointment due to the sole selling agent or buying agent acquiring substantial interest. [Circular No. 1/1/78‑CL‑ V, dated 7‑3‑1978]

 

14.        In such cases apply in Form I or Form II of the Companies (Appointment of Sole Agents) Rules, 1975, to the Central Government. [Section 294AA (2) read with Explanation (b) to it]

 

15.        In the above case also deliver a copy of the application together with a copy of each of the documents attached to it to the concerned Registrar of Com­panies.

 

16.        Attach a treasury challan or demand draft evidencing the payment of the requisite fees as per the Companies (Fees on Application) Rules, 1999.

 

17.        If the application fee is paid by way of treasury challan, then pay the requisite fee of minimum Rs. 500/‑ and maximum Rs. 2000/‑ as the case may be, and as prescribed by the Companies (Fees on application) Rules, 1999, by way of treasury challan prepared in triplicate and paid in cash into any of the specified branches of the Punjab National Bank for credit.

 

18.        The description of the Head of account of the treasury challan should be as prescribed under Rule 22(2) of the Companies (Central Government's) General Rules and Forms, 1956 and as amended vide GSR 251(E), dated 21‑6‑1996 (w.ef 21‑6‑1996). [Rule 22(2) of the Companies (Central Governments) General Rules and Forms, 1956 read with Rule 3 of the Companies (Appointment of Sole Agents) Rules, 1975]. For account head and code please see Rule 22(2) in Appendix 1.

 

19.        Two copies of the treasury challan will be given back to the depositor by the said branch of the bank and the original copy should be attached to the application made to the Central Government.

 

20.        If the application fee is paid by way of demand draft, then draw the demand draft in favour of "Pay and Accounts Officer, Department of Company Affairs, New Delhi", and payable at any bank located in New Delhi and said demand draft should be attached to the aforesaid application to the Central Government.

 

21.        File the Ordinary Resolution of the General Meeting under item 7 with Explanatory Statement with the concerned Registrar of Companies in Form No. 23 within thirty days of its passing along with a certified true copy of the terms and conditions of appointment [Section 192(4)(ee)(ii)(g)] after paying the requisite fee prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury challan. [Rule 22]

 

22.        Please keep in mind that if default is made in complying with the aforesaid requirements, the company and every officer of the company who is in default will be punishable with fine upto Rs. 200/‑ for every day during which the default continues. [Section 192(5)]

 

23.        If the case falls within the purview of Section 314, complete, the for­malities as mentioned in Topic 108.

 

24.        Take note of the provisions of Section 294 and Section 294AA(1) as regards disqualifications, disabilities etc. of a person to be appointed as sole selling agent.

 

25.        Note that if during the continuance of the current tenure of the sole selling agent or buying agent of your company there is increase in the paid‑up capital of your company to make it Rs. 50 lakhs or more, it will not be obligatory on the part of the company to comply with the provisions of section 294AA(3) during the remaining duration if the sole selling agent's or buying agent's current tenure. [Circular No. 11/77, dated 3‑11‑1977]

 

26.        Further note that if your company's paid‑up share capital is less than Rs. 50 lakhs but is equal to or more than Rs. 10 lakhs, your company is required to obtain a compliance certificate from a secretary in whole‑time practice to be filed with the Registrar of Companies mentioning therein inter alia that the company has appointed the sole selling agent in compliance with the provisions of the Act as per paragraph 16 of the Form of Compliance Certificate appended to the Companies (Compliance Certificate) Rules, 2001.[Section 383‑A(1) proviso]

 

B.          In the case of companies having a paid‑up share capital of Rs. 50 lakhs or more:

 

1.          Convene a Board Meeting after giving noticel to all the directors of the company as per Section 286 and determine the name of the sole selling or buying agent to be appointed and fix up the date, time, place and agenda for calling a General Meeting and to pass a special resolution subject to approval of the Central Government in this regard. [Section 294AA(3)]

 

2.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/‑.[Section 286(2)]

 

3.          Issue notices in writing with suitable Explanatory Statement at least twenty one days before the date of the General Meeting and hold the General Meeting and pass the Special Resolution by three fourths majority. [Section 171(1) and 173(2) read with section 189(2)]

 

4.          Forward three copies of the notices and a copy of the proceedings of the General Meeting to the Stock Exchange with which the Shares of your company are listed. [Clause 31(c) and (d) of the Standard Listing Agreement]

 

5.          File the copy of the Special Resolution with Explanatory Statement with the concerned Registrar of Companies in Form No. 23 within thirty days of its passing along with certified true copy of the terms and conditions of appointment [Section 192(4)(ee)(ii) and (g)] after paying the requisite fee as prescribed under Schedule X to the Companies Act, 1956, either in cash, demand draft or treasury challan (Rule 22]

 

6.          Please keep in mind that if default is made in complying with the aforesaid requirements, the company and every officer of the company who is in default will be punishable with fine upto Rs. 200/‑ for every day during which the default continues. [Section 192(5)]

 

7.          Apply for the approval of the Central Government for appointing the sole selling or buying agent as determined in item 1 above in Form I or Form II of the Companies (Appointment of Sole Agents) Rules, 1975. [Section 294AA (3)]

 

8.          Attach a treasury challan or demand draft evidencing the payment of the requisite fees as per the Companies (Fees on Application) Rules, 1999.

 

9.          If the application fee is paid by way of treasury challan, then pay the requisite fee of minimum Rs. 500/‑ and maximum Rs. 2000/‑ as the case may be, and as prescribed by the Companies (Fees on Application) Rules, 1999, by way of treasury challan prepared in triplicate and paid in cash into any of the specified branches of the Punjab National Bank for credit.

 

10.        The description of the Head of account of the treasury challan should be as prescribed under Rule 22(2) of the Companies (Central Govemment's) General Rules and Forms, 1956 and as amended vide GSR 251(E), dated 21‑6‑1996 (w.e.f. 21‑6‑1996). [Rule 22(2) of the Companies (Central Government's) General Rules and Forms 1956 read with Rule 3 of the Companies (Appointment of Sole Agents) Rules, 1975]. For account head and code please see Rule 22(2) in Appendix 1.

 

11.        Two copies of the treasury challan will be given back to the depositor by the said branch of the bank and the original copy should be attached to the application to the Central Government.

 

12.        If the application fee is paid by way of demand draft, then draw the demand draft in favour of "Pay and Accounts Officer, Department of Company Affairs, New Delhi", and payable at any bank located in New Delhi, and the said demand draft should be attached to the application made to the Central Government.

 

13.        Take note of the provisions of Section 294 and Section 294AA(1) as regards disqualifications, disabilities etc. of a person to be appointed as sole selling agent.

 

14.        See that the appointment is made for a period not exceeding five years at a time [Section 294(1)]

 

15.        Also ensure that the proposal to appoint sole selling agent is not in respect of an industry in which no sole selling agent can be appointed. 17

 

16.        Note that the appointment of distribution would also fall within the ambit of section 294 depending on the distributors contractual relationship between the parties and the terms and conditions of the appointment, and if the true nature of the appointment, and if the true nature of the functions performed by them shows that although a person is described as a distributor, he performs in fact the functions of a sole selling agent notwithstanding his description given in the deed of contract. [6th Annual Report on the Workings and Administration of the Companies Act, 1956 ‑Year ended March 31, 1962]

 

17.        Further note that as per the Citizen's Charter of the Department of company Affairs, Schedule I, Serial No. 12 the application made to the Central Government will be processed within 30 days. [No. 5/25/99 CL‑V, Press Note No. 9/99, dated 9‑8‑1999]

 

18.        Also note that the provisions of sub‑sections (2) and (3) of section 294AA do not apply to a Government Company. [Notification GSR 578(E), dated 16‑7-1985]

 

Topic 107

 

DO YOU WISH TO PAY COMPENSATION TO SOLE SELLING AGENTS FOR LOSS OF OFFICE? [SECTION 294A]

 

1.          Verify the following before paying compensation to your sole selling agent:­

 

(i)          Whether the appointment of the sole selling agent has become invalid as it is disapproved by the General Meeting as required by Section 294(2A);

 

(ii)         Whether the sole selling agent has resigned his present office and has been appointed as such in the reconstructed company or body corporate resulting from amalgamation;

 

(iii)         Whether the sole selling agent submitted his resignation for any other reason;

 

(iv)        Whether he is guilty of fraud or breach of trust or gross negligence as a sole selling agent;

 

(v)         Whether he has instigated or has taken part directly or indirectly in bringing about the termination of his office as a sole selling agent. [Section 294A (1)].

 

2.          If the sole selling agent has ceased to hold office due to any of the reasons mentioned above, your company need not pay compensation to the sole selling agent due to loss of office.

 

3.          Keep in mind that if the appointment of the sole selling agent made by the Board of Directors of your company is not placed before the immediate next general meeting of your company under section 294(2) the said appointment being invalid will also disentitled the sole selling agent from claiming any compensation.

 

4.          In any other case, fix the compensation to be paid to the sole selling agent in the following manner:- ­

 

(i)          Calculate the average remuneration actually earned by the sole selling agent during his tenure of office immediately preceding the date of his termination or cesser of office;

 

(ii)         Apply this average remuneration to unexpired residue of his term of office;

 

(iii)         See that the total amount of remuneration so calculated does not exceed the remuneration which he would have earned if he was in the office during his whole term or for three years, whichever is shorter.

 

5.          Convene a Board Meeting after giving notice to all the directors of the company as per Section 286 and pass a Board Resolution approving the pay­ment of compensation to the sole selling agents for loss of office as fixed per item 4 above.

 

6.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/‑.[Section 286(2)]

 

7.          Send a certified copy of the Board Resolution along with a letter stating that the office of the sole selling agent has been terminated to the concerned Registrar of Companies for information.

 

8.          Make the payment to the sole selling agent and obtain an official receipt from him for such payment .

 

 

G. Others

 

(Topic 108 to Topic 111)

 

1. Appointment of a firm or body corporate to an office or place of profit

 

Topic 108

 

DO YOU WISH TO APPOINT A FIRM OR BODY CORPORATE TO AN OFFICE OR PLACE OF PROFIT?

 

1.          If the firm or body corporate holds the office or place of profit carrying a total monthly remuneration of Rs. 10,000/‑ or more, then the following procedure should be undertaken:

 

(i)          Take a declaration in writing on behalf of the firm or body corporate stating that it is connected with a director in any of the ways mentioned in section 314(1) and (1B). [Section 314(2A)];

 

(ii)         Convene a Board Meeting after giving noticel to all the directors of the Company as per Section 286 and fix the date, time, place and agenda of the General Meeting to pass a Special Resolution;

 

(iii)         Issue notices in writing at least twenty‑one days before the date of the General Meeting proposing the Special Resolution with suitable Explanatory Statement. [Section 171(1) read with section 173(2)];

 

(iv)        Hold the General Meeting and pass the Special Resolutionf by threefourths majority. [Section 189(2)];

 

(v)         File the Special Resolution in Form No. 23 with the concerned Registrar of Companies within thirty days of the passing thereof [Section 192(4)(a)], after paying the requisite fee as prescribed under Schedule X to the Companies Act, 1956, either in cash, or treasury challan. [Rule 22]

 

(vi)        Forward three copies of notices of the General Meeting to the Stock Exchange if your company is listed on it. [Clause 31(c) of the Standard Listing Agreement]

 

2.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be pun­ishable with fine of upto Rs. 1000/-. [Section 286(2)]

 

3.          Please also keep in mind that if default is made in complying with the fil­ing of the Special Resolution with the Registrar of Companies within thirty days of its passing, the company and every officer of the company who is in default will be punishable with fine upto Rs. 200/- for every day during which the de­fault continues. [Section 192(5)]

 

4.          If the firm or body corporate holds the office or place of profit carrying a total monthly remuneration of Rs. 20,000/‑, or more then undertake the following procedure:

 

(i)          Approve it by passing a Special Resolutionj by three‑fourths majority by holding a General Meeting after giving notice at least twenty one days before the date of the meeting prior to the holding of such office and do all other things as mentioned under item 1 above.

 

(ii)         Apply to the Central Government in Form No. 24B along with a copy of the Special Resolution passed by the company and a treasury challan or demand draft evidencing payment of the requisite fee as per the Companies (Fees on Applications) Rules, 1999, along with the following:

 

(a)         Certified true copy of audited annual accounts together with directors and auditor's reports for the last three financial years.

 

(b)         Certified true copy of the Special Resolution passed in the general meeting together with the explanatory statement in regard thereto.

 

(c)         Certified true copy of the resolution passed by the board of directors, if any, relating to the proposed appointment.

 

5.          If the application fee is paid by way of treasury challan, then pay the requisite fee of minimum Rs. 500/‑ and maximum Rs. 2000/‑, as the case may be, and as prescribed by the Companies (Fees on Applications) Rules, 1999, by way of treasuv challan prepared in triplicate and paid in cash into any of the specified branches of the Punjab National Bank for credit.

 

6.          The description of the Head of account of the treasury challan should be as prescribed under Rule 22(2) of the Companies (Central Government's) General Rules and Forms, 1956 and as amended vide GSR 251(E), dated 21‑6‑1996 (w.e.f. 21‑6‑1996). For account bead and code please see Rule 22(2) in Appendix 1.

 

7.          Two copies of the treasury challan will be given back to the depositor by the said branch of the bank and the original copy should be attached to application made to the Central Government.

 

8.          If the application fee is paid by way of demand draft, then draw the demand draft in favour of "Pay and Accounts Officer, Department of Company Affairs, New Delhi", and payable at any bank located in New Delhi and the said demand draft should be attached to the application to the Central Government.

 

9.          See that the firm or body corporate so appointed holds such office or place of profit for a period not exceeding five years at a time except in such cases as are exempted under Section 204.

 

10.        In case of initial appointment, applyf to the Central Government for ap­proving the appointment for a period of ten years. [Section 204(1), Proviso]

 

11.        There is no prescribed form for the above applicatiorif mentioned in item 8 above. Make the application in the form of a letter in the letter head of the company to the Central Government along with the following documents:

 

(i)          A signed copy of the agreement between the firm or body corporate and your company;

 

(ii)         A certified true copy of the latest audited Balance‑sheet;

 

(iii)         A certified true copy of the Board's resolution;

 

(iv)        A treasury challan or demand draft evidencing the payment of the requisite fees as prescribed under the Companies (Fees on Applications) Rules, 1999.

 

12.        If the application fee is paid by way of treasury challan, then pay the requisite fee of minimum Rs. 500/‑ and maximum Rs. 2000/‑, as the case may be, and as prescribed by the Companies (Fees on Applications) Rules, 1999 by way of treasury challan prepared in triplicate and paid in cash into any of the specified branches of the Punjab National Bank for credit.

 

13.        The description of the Head of account of the treasury challan should be as prescribed under Rule 22(2) of the Companies (Central Government's) General Rules and Forms, 1956 and as amended vide GSR 251(E), dated 21‑6‑1996 (w.ef 21‑6‑1996). For account head and code please see Rule 22(2) in Appendix 1.

 

14.        Two copies of the treasury challan will be given back to the depositor.by the said branch of the bank and the original copy should be attached to the application made to the Central Government.

 

15.        If the application fee is paid by way of demand draft, then draw the demand draft in favour of "Pay and Accounts Officer, Department of Company Affairs, New Delhi", and payable at any bank located in New Delhi, and the said demand draft should be attached to the application.

 

16.        Note that appointment of any firm or body corporate to an office or place of profit under a company by a contract or arrangement terrninable at will and/or without the approval of Central Government is in contravention of section 204(1) and prosecution for the same will be under section 529A. [Circular No. 19 of 1975, dated 12‑9‑1975]

 

17.        Further note that as per the Citizen's Charter of the Department of Company Affairs, Schedule I, Serial No. 10, the application to the Central Government will be processed within 30 days. [No. 5/25/99‑CL‑V, Press Note No. 9/99, dated 9‑8‑1999]

 

18.        Also note that if your company's paid‑up share capital is less than Rs. 50 lakhs but is equal to or more than Rs. 10 lakhs, your company is required to obtain a Compliance Certificate from a secretary in whole‑time practice to be filed with the Registrar of Companies mentioning therein inter alia that the company has obtained necessary approvals from the Board of Directors, members and previous approval of the Central Government pursuant to section 314 as per paragraph 11 of the Form of Compliance Certificate appended to the Companies (Compliance Certificate) Rules, 2001.[Section 383‑A(1) proviso].

 

 

2. Waiver of refund of money paid under section 314

 

Topic 109

 

DO YOU WISH TO WAIVE REFUND OF MONEY MADE BY THE TERSON APPOINTED NOT IN ACCORDANCE WITH SECTION 314?

 

1.          You have to obtain the permission of the Central Government to waive refund of money by the person to whom the company has paid Rs. 10,000/‑, Rs. 20,000/‑ or more per month for holding any office or place of profit. [Section 314(2‑B) and (2D) read with Rule 10C].

 

2.          Convene a Board Meeting after giving notice to all the directors of the company as per Section 286 and take the decision of such waiver by passing a Resolution.

 

3.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/‑.[Section 286(2)]

 

4.          Make an applicationE to the Central Government on a plain paper preferably on the letter head of the company stating the reasons of such waiver as there is no prescribed form for making this application.

 

5.          The application will be addressed to "The Secretary to the Government of India, Department of Company Affairs, Ministry of Law, Justice and Company Affairs, Shastri Bhavan, 5th Floor, 'A' Wing, Dr. Rajendra Prasad Road, New Delhi‑ 110 001".

 

6.          Enclose the following documents along with the application:-­

 

(i)          A certified true copy of the latest balance‑sheet and profit and loss account of the company;

 

(ii)         A certified true copy of the Board's resolution;

 

(iii)         A treasury challan or demand draft evidencing the payment of the requisite fee­as prescribed under the Companies (Fees on Applications) Rules, 1999.

 

7.          If the application fee is paid by way of treasury challan, then pay the req­uisite fee of minimum Rs. 500/‑ and maximum Rs. 2000/‑, as the case may be, and as prescribed by the Companies (Fees on Applications) Rules, 1999, by way of treasury challan prepared in triplicate and paid in cash into any of the specified branches' of the Punjab National Bank for credit.

 

8.          The description of the Head of account of the treasury challan should be as prescribed under Rule 22(2) of the Companies (Central Government's) General Rules and Forms, 1956 and as amended vide GSR 251(E), dated 21‑6‑1996 (w.e.f. 21‑6‑1996). For account head and code please see Rule 22(2) in Appendix 1. Two copies of the challan will be given back to the depositor by the said branch of the said bank and the original copy should be attached to the application.

 

9.          If the application fee is paid by way of demand draft, then draw the demand draft in favour of Pay and Accounts Officer, Department of Company Affairs, New Delhi, and payable at any bank located in New Delhi, and the said demand draft should be attached to the application.

 

10.        Deliver a copy of the application together with a copy of each of the documents enclosed to the concerned Registrar of Companies, simultaneously.

 

11.        Note that as per the Citizen's Charter of the Department of the Company Affairs, Schedule I Serial No. 10, the application to the Central Government will be processed within 30 days. [No. 5/25/99‑CL‑V, Press Note No. 9/99, dated 9‑8-1999]

 

            

             3. Appointment of Constituted Attorney

 

Topic 110

 

DO YOU WISH TO APPOINT A CONSTITUTED ATTORNEY?

 

1.          Get a draft prepared for power of attorney incorporating the powers you wish to invest in him.

 

2.          Convene a Board Meeting after giving notice to all the directors of the company as per Section 286 and approve the same authorising one or more of your directors to execute the same and to affix the company's common seal thereon as per the terms of your Articles of Association.

 

3.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/‑.[Section 286(2)]

 

4.          Execute the same on duly stamped paper as required under the Indian Stamp Act or the State Act, as applied to the concerned State or Union Territory, and get it registered with the appropriate registration authorities or have it notarised by a Notary Public after affixing proper notarial stamps.

 

5.          Also note that where substantial managerial powers in any area of management is conferred, the constituted attorney will be in the position of a deemed managing or whole‑time director.

 

6.          Keep in mind that for the appointment of such a person Ordinary Resolution of the General Meeting or the Central Government's approval will be required under Section 269, as the case may be.

 

 

 

4. Appointment of Inspector to Investigate

 

Topic 111

 

DO YOU WISH TO HAVE AN INSPECTOR APPOINTED TO INVESTIGATE THE AFFAIRS OF YOUR COMPANY?

 

A.          Application by members [Section 235(2)].

 

1.          Make your application to the Company Law Board, Principal Bench, New Delhi, or to the Additional Principal Bench, Chennai, as the case may, by way of a petition to be prepared in Form No. 1 in Annexure II to the Company Law Board Regulations, 1991 and annex thereto the following:

 

(i)          Documentary and/or other evidence in support of the statements made in the petition, as are reasonably open to the petitioner.

 

(ii)         Documentary evidence in proof of the eligibility and status of the petitioner with the voting power held by each of them.

 

(iii)         Affidavit verifying the aforesaid petition.

 

(iv)        Demand draft evidencing payment of the fee of Rs. 2,500/-.

 

(v)         Certified true copy of the Memorandum and Articles of Association of the company.

 

(vi)        Certified true copy of the latest audited balance‑sheet and profit and loss account with the Directors' and Auditors' Reports.

 

(vii)        Memorandum of Appearance in Form No. 5 of the Company Law Board Regulations, 1991 with a certified true copy of the Board Resolution or the executed Vakalatnama, as the case may be.

 

(viii)       Original acknowledgement of the concerned Registrar of Companies.

 

(ix)        Original acknowledgement of the Central Government.

 

2.          The affidavit should be prepared on a non‑judicial stamp paper of the requisite value prevalent in the State and should be either notarised by the Notary Public or sworn before the Oath Commissioner.

 

3.          The said affidavit should be drawn up in first person and shall give the full name, age, occupation and complete residential address of the deponent and shall be signed by the deponent. [Regulation 14(5) of the Company Law Board Regulations, 1991]

 

4.          If in the said affidavit the deponent is not personally known to the person before whom the affidavit is sworn, he should be identified by a person who is known to the person before whom the affidavit is sworn. [Regulation 14(6) of the Company Law Board Regulations, 1991]

 

5.          The said affidavit should clearly and separately indicate statements which are true to the knowledge of the deponent, information received by the deponent, belief of the deponent and information based on legal advice. [Regulation 14(7) of the Company Law Board Regulations 1991]

 

6.          Where any statement is stated to be true to the information received by the deponent, the affidavit shall also include the name and complete residential address of the person from whom the information has been received by the deponent and declare that the deponent believes that infori‑nation to be true. [Regulation 14(8) of the Company Law Board Regulations, 1991]

 

7.          Please ensure that the aforesaid petition is written, type‑written, cyclostyled or printed, neatly and legibly on one side of the substantial paper of foolscap size in double space and separate sheets shall be stiched together and every page consecutively numbered. [Regulation 11 of the Company Law Board Regulations, 1991]

 

8.          Numbers and dates specified therein should be expressed in figures as well as in words. The petition should be divided into separate paragraphs which should be numbered serially and shall state thereon the matter and the name of the company to which it relates. [Regulation 12 of the Company Law Board Regulations, 1991]

 

9.          Please also ensure that the aforesaid petition is presented by the petitioner in original and four extra copies thereof in person or through authorised representative to the office of the Bench or to be sent by registered post with acknowledgement due addressed to the Secretary or Bench Officer of the Bench concemed as the case may be. [Regulation 14(1) of the Company Law Board Regulations, 1991]

 

10.        Affix Court fee stamps of the requisite value' on the original petition be­fore submission.

 

11.        Please furnish a copy of the complete set of the petition to the concerned Registrar of Companies before filing it with the Company Law Board [Regulation 14(3) of the Company Law Board Regulations, 1991]

 

12.        Please furnish a copy of the complete set of the petition to the 'Regional Director of the concerned region, before filing it with the Company Law Board. [Regulation 14(3) second proviso of the Company Law Board Regulations, 1991]

 

13.        Pay the filing fee of Rs. 2,500/- as per Rule 3 read with Rules 4 and 5 of the Company Law Board (Fees on Applications & Petitions) Rules, 1991, by way of demand draft drawn in favour of "Pay and Accounts Officer, Department of Company Affairs, New Delhi" and payable at New Delhi.

 

14.        Ensure that the petition is made by not less than two hundred members or from members holding not less than one‑tenth of the total voting power therein, where the company is having a share capital [Section 235(2)(a)]

 

15.        Where the company does not have a share capital, then the petition should be made by not less than one‑fifth of the persons on the company's register of members. [Section 235(2)(b)]

 

16.        Also ensure that the petition explains the facts and circumstances under which the affairs of the company need to be investigated by an inspector or inspectors.

 

B.          Application by a contributory, creditor or any person interested (Through Registrar of Companies)

 

1.          Make a representation to the concerned Registrar of Companies with particulars and materials that the business of the company is being carried on in fraud of its creditors or of persons dealing with the company or otherwise for a fraudulent or unlawful purpose.

 

2.          If the Registrar of Companies is satisfied, he may submit a report to the Central Government to give an order for investigation of the affairs of the company. [Section 235(1) read with Section 234(7)]

 

C.          Application by Company [Section 237(a)(i)]

 

1.          Convene a Board Meeting after giving notice to all the directors of the company as per Section 286 and take the decision of having an investigation of your company by an Inspector appointed by the Central Government and also fix the date, time, place and agenda of the General Meeting to pass a Special Resolution. [Section 237(a)(i)]

 

2.          Please keep in mind that every officer of the company whose duty is to give notice of the Board Meeting as aforesaid and who fails to do so will be punishable with fine of upto Rs. 1000/-. [Section 286(2)]

 

3.          Issue notices at least twenty‑one days before the date of the General Meeting proposing the Special Resolution with suitable explanatory statement. [Section 171(1) read with section 173(2)]

 

4.          Hold the General Meeting and pass the Special Resolution by three fourths majority declaring that the affairs of the company ought to be investigated by an Inspector appointed by the Central Government. [Section 189(2)]

 

5.          Forward to the Stock Exchange with which the shares of your company are listed, three copies of the notice and a copy of the proceedings of the General Meeting. [Clause 31(c) and (d) of the Standard Listing Agreement]

 

6.          Make an applicationE to the Central Government enclosing certified true copies of the following:­

 

(i)          Special resolution passed by the company declaring that the affairs of the company ought to be investigated by an inspector appointed by the Central Government;

 

(ii)         Notice of the general meeting in which the aforesaid special resolution was passed and the explanatory statement;

 

(iii)         Memorandum and Articles of Association of the company;

 

(iv)        Latest audited balance‑sheet and profit and loss account and the Directors' and Auditors' Reports.

 

7.          Enclose a treasury challin or demand draft evidencing payment of the requisite fees as prescribed under the Companies (Fees on Applications) Rules, 1999.

 

8.          If the application fee is paid by way of treasury challan, then pay the requisite fee of minimum Rs. 500/‑ and maximum Rs. 2000/‑, as the case may be, and as prescribed by the Companies (Fees on Applications) Rules, 1999, by way of treasury challan prepared in triplicate and paid in cash into any of the specified branches of the Pun ab National Bank for credit.

 

9.          The description of the Head of account of the treasury challan should be as prescribed under Rule 22(2) of the Companies (Central Government's) General Rules and Forms, 1956 and as amended vide GSR 251(E), dated 21‑6‑1996 (w.ef 21‑6‑1996). For accobnt head and code please see Rule 22(2) in Appendix 1.

 

10.        Two copies of the treasury challan will be given back to the depositor by the said banch of the bank and the original copy should be attached to the application made to the Central Government.

 

11.        If the application fee is paid by way of demand draft, then draw the demand draft in favour of "Pay and Accounts Officer, Department of Company Affairs", New Delhi, and payable at any bank located in New Delhi, and the said demand draft should be attached to the application made to the Central Government.

 

12.        File the Special Resolution with the Explanatory Statement in Form No. 23 within thirty days of its passing with the concerned Registrar of Companies [Section 192(1) & (4)(a)] after paying the requisite fee prescribed under Schedule X to the Companies Act, 1956, either in cash, demand draft or treasury challan. [Rule 22]

 

13.        Please keep in mind that if default is made in complying with the aforesaid requirements, the company and every officer of the company who is in default will be punishable with fine upto Rs. 200/‑. For every day during which the default continues. [Section 192(5)]

 

14.        Deliver a copy of the application together with a copy of each of the documents enclosed to the concerned Registrar of Companies, simultaneously.

 

15.        Note that as per the Citizen's Charter of the Department of Company Affairs, Schedule I, Serial No. 6, the application will be processed within 60 days. [No. 5/25/99‑CL‑V, Press Note no. 9/99, dated 9‑8‑1999]

 

D.         Application by any member after obtaining the High Court's order [Section 237(a)(ii)]

 

1.          The Central Government, Department of Company Affairs, will automatically appoint one or more competent persons as inspectors to investigate the affairs of a company and to report thereon in such manner as the Central Government may direct where the concerned High Court in whose jurisdiction the registered office of the company falls, by order declares that the affairs of the company ought to be investigated by an inspector appointed by the Central Government.

 

2.          For obtaining the aforesaid order from the concerned High Court, an application by way of a petition is to be made to the said Court along with a true copy of the Memorandum and Articles of Association. [Rule 11(9) of the Companies (Court) Rules, 1959 read with its Annexure II and Rule 22].

 

E.          Application to the Company Law Board for appointment of Inspec­tors by the Central Government under section 237(b).

 

1.          Make your application to the Company Law Board, Principal Bench, New Delhi, or to the Additional Principal Bench, Chennai, as the case may be, by way of a petition to be prepared in Form No. 1 in Annexure II to the Company Law Board Regulations, 1991 and annex thereto the following:

 

(i)          Documentary and/or other evidence in support of the statements made in the petition, as are reasonably open to the petitioner;

 

(ii)         Documentary evidence in proof of the eligibility and status of the petitioner with the voting power held by each of them;

 

(iii)         Affidavit verifying the aforesaid petition;

 

(iv)        Demand draft evidencing payment of the fee of Rs. 2,500/‑ 15;

 

(v)         Certified true copy of the Memorandum and Articles of Association of the company;

 

(vi)        Certified true copy of the latest audited balance‑sheet and profit and loss account with the Directors' and Auditors' Reports;

 

(vii)        Memorandum of Appearance in Form No. 5 of the Company Law Board Regulations, 1991 with a certified true copy of the Board Resolution or the executed Vakalatnama, as the case may be;

 

(viii)       Original acknowledgement of the concerned Registrar of Companies;

 

(ix)        Original acknowledgement of the Central Government.

 

2.          The affidavit, should be prepared on a non‑judicial stamp paper of the requisite value prevalent in the State and should be either notarised by the Notary Public or sworn before the Oath Commissioner.

 

3.          The said affidavit should be drawn up in first person and shall give the full name,             age, occupation and complete residential address of the deponent and shall be signed by the deponent. [Regulation 14(5) of the Company Law Board Regulations, 1991]

 

4.          If in the said affidavit the deponent is not personally known to the person before whom the affidavit is sworn, he should be identified by a person who is known to the person before whom the affidavit is sworn. [Regulation 14(6) of the Company Law Board Regulations, 1991]

 

5.          The said affidavit should clearly and separately indicate statements which are true to the knowledge of the deponent, information received by the deponent, belief of the deponent and information based on legal advice. [Regulation 14(7) of the Company Law Board Regulations, 1991]

 

6.          Where any statement is stated to be true to the information received by the deponent, the affidavit shall also include the name and complete residential address of the person from whom the information has been received by the deponent and declare that the deponent believes that information to be true. [Regulation 14(8) of the Company Law Board Regulations, 1991]

 

7.          Please ensure that the aforesaid petition is written, type‑written, cyclostyled or printed, neatly and legibly on one side of the substantial paper of foolscap size in double space and separate sheets shall be stiched together and every page consecutively numbered. [Regulation 11 of the Company Law Board Regulations, 1991]

 

8.          Numbers and dates specified therein should be expressed in figures as well as in words. The petition should be divided into separate paragraphs which should be numbered serially and shall state thereon, the matter and the name of the company to which it relates. [Regulation 12 of the Company Law Board Regulations, 1991]

 

9.          Please also ensure that the aforesaid petition is presented by the petitioner in original and four extra copies thereof in person or through authorised representative to the office of the Bench or to be sent by registered post with acknowledgement due addressed to the Secretary or Bench Officer of the Bench concemed, as the case may be. [Regulation 14(1) of the Company Law Board Regulations, 1991]

 

10.        Affix Court fee stamps of the requisite value 16 on the original petition be­fore submission.

 

11.        Please furnish a copy of the complete set of the petition to the concerned Registrar of Companies before filing it with the Company Law Board. [Regulation 14(3) of the Company Law Board Regulations, 1991]

 

12.        Please also furnish a copy of the complete set of the petition to the Re­gional Director of the concerned region, before filing it with the Company Law Board. [Regulation 14(3), second proviso of the Company Law Board Regulations, 1991]

 

13.        Pay the filing fee of Rs. 2,500/‑ as per Rules 3 read with Rules 4 and 5 of the Company Law Board (Fees on Applications & Petitions) Rules, 1991, by way of demand draft drawn in favour of Pay and Accounts Officer, Department of Company Affairs, New Delhi and payable at New Delhi.

 

14.        Also ensure that the petition explains the facts and circumstances sug­gesting the following:­

 

(i)          that the business of the company is being conducted with intent to defraud its creditors, members or any other persons, or otherwise for a fraudulent or unlawful purpose, or in a manner oppressive of any of its members, or that the company was formed for any fraudulent or unlawful purpose. [Section 237(b)(i)];

 

(ii)         that persons concerned in the formation of the company or the management of its affairs have in connection therewith been guilty of fraud, misfeasance or other misconduct towards the company or towards any of its members; [Section 237(b)(ii)]; or

 

(iii)         that the members of the company have not been given all the information with respect to its affairs which they might reasonably expect, including information relating to the calculation of the commission payable to a managing or other director or the manager, of the company. [Section 237(b)(iii)].