ROC Penalises Company and Director for Failure to Disclose Allottees’ Occupation in Form PAS-3

The Registrar of Companies (ROC), Chennai, has imposed a penalty amounting to Rs. 20,000 on the company, Sri Narayani Benefit Fund Nidhi Limited, and its director under Section 454 of the Companies Act 2013, vide an order of adjudication dated March 03, 2026.

The concerned ministry had rejected a Form NDH-4 furnished by the disputed company through an order dated July 26, 2024. The rejection was made because the company had not mentioned the occupation of all the allottees in the list attached to Form PAS-3 (SRN: G59548958 dated 01.11.2017) in the MCA system. This is an explicit contravention of Section 12(2) of the Companies (Prospectus and Allotment of Securities) Rules, 2014.

According to the provisions of the said section, a company is compelled to mention allottees’ names; address; occupation, if any; and numbers of securities allotted in the list of allottees attached to the Form PAS-3. The list must also be certified by the signatory of Form PAS-3 as complete and correct according to the company’s records.

Since the company had violated the aforementioned provisions of Rule 12(2) of the Companies (Prospectus and Allotment of Securities) Rules, 2014. Hence, it is liable for penal action under Section 450 of the Companies Act, 2013, along with its officers.

In conclusion, the ROC Chennai imposed a penalty of Rs. 20,000 on Sri Narayani Benefit Fund Nidhi Limited and its director, Govindaraj Murugesan (Rs. 10,000 each). The company and director in default are required to rectify the default and pay the imposed penalty amount within the time period of 90 days from receipt of the order.