sec.151 & sec. 241 of The Indian Companies Act 2013 and class action lawsuits ~ Shareholder Awareness Program

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sec.151 & sec. 241 of The Indian Companies Act 2013 and class action lawsuits

section 151, section 241 and class action suit from The Indian Companies Act 2013

Article published as on Friday, 1st MAY, 2020 at 1:00 a.m.   


Sec.151 of The Indian Companies Act 2013

The section itself is very small but the terms and conditions and other details are given in the:

Rule (7) of the companies (appointment and qualification of directors) rules, 2014.

(“151. Appointment of director elected by small shareholders.— A listed company may have one director elected by such small shareholders in such manner and with such terms and conditions as may be prescribed.

Explanation.—For the purposes of this section ―small shareholders means a shareholder holding shares of nominal value of not more than twenty thousand rupees or such other sum as may be prescribed.” ~ Source: MCA website)

An interesting thing to know is that every terms and conditions related to Small Shareholder Director are given in rule (7).

As changes to Rules can be done by the ruling party overnight (stated under sec.469 of The Indian Companies Act 2013), whereas changes to sections of the Act is a comparatively lengthy process which requires acceptance from both the houses and sign from the president.

This allows the ruling party to make overnight changes in the rules.


Coming back to the Rule (7), It States process for appointment of small shareholder director (SSD).

It states that a listed company MAY appoint  small shareholder director upon notice of 1000 such shareholders or 10% of small shareholders nomination whichever is less, notice to be sent at least 14 days prior to AGM with name, folio no, address, sign and no. of shares holding by small shareholders


Director may or may not be a shareholder.

It states that small shareholder are those who hold nominal value of less than INR 20,000.

Small shareholder director is a not a rotational director.
Maximum tenure for such director is 3 years. And s/he can’t be reappointed.

Director should also not be appointed for a period of 3 years after completing his tenure in the company or its associates in any capacities directly or indirectly
(This means a cool off period of 3 years shall be maintained)

A person may become director in maximum 2 companies, provided that 2nd company is not a rival company of the first company.

Note: if s/he fulfils the criteria of 149(6), then he will be counted as an independent director if s/he gives declaration for being considered as an independent director in the first board meeting after his appointment.

Proposal is out forward to the board 

Board approves it, 
If not, we can take action against the board under sec 241 of companies act 2013.
(Oppression of minority shareholders, mismanagement by board of director)

After approval a normal resolution is passed (50% majority required) voting to be done only by small shareholders, (no promoter, HNI's and institutions)
It has to be done through a postal ballot or by e-voting as a special business and not at AGM.

Sec.160 provides for the right for any person to stand as a director in a democratic way for this a security deposit of 1 lac rupees is needed.
(Previously it was INR 500 as per 1956 law.)

This is done to avoid abuse of right by the person with bad motive. 

As in our case by small shareholders we are nominating the director so we are not required to keep a deposit of rupees 1 lac with the company

In the case of unify capital and alembic ltd, they gave security cheque of 1 lac rupees just to be on a safer side.
(In reality use of these provisions and sections are limited, so there are limited case studies to understand practically.)



Sec.241 of The Indian Companies Act.
 This comes under chapter XVI – prevention of oppression and mismanagement (sec.241 to sec.246)

This sec.241 is a merged section from the old sec.397 and sec.398 from the 1956 act.

This section has to be studied along with other sections up to sec.245 which is class action suits.

Any member eligible under sec.244.
Can file application under this section whenever a person feels that the operations are prejudicial to company, public or the member or oppressive to any of its member.

Who can file?

Member of the company and following are conditions 
100 members needed.
1/10th if total members needed.
1/10 of total share capital needed, whichever is lower.

In these days for every major listed company we would need only 100 members to come together to file application.

Now what judgement can court provide as relief to the applicants?

Under sec.242 (2)

Court can regulate the affairs of the company.

(This means the court can provide a direction to the company.

This means over ruling the decision of the board of rejecting the proposal for small shareholder director and thus giving a fair opportunity to us for electing our representative.)

Sec.243 discusses clause (e) and (f) with respect to sec.242 (2), which is not relevant for us right now, so we move onto:

Sec.245 - class action suits

It can be filled by members and depositors provided they are eligible to do so, against the wrongdoings of the company.

Here both members and depositors can come together to file the case, this is why it is called class action suit, as all class comes together to file the case

Why is it filed?

To restrain:

·        From committing any act that is ultra vires from the Memorandum Of Association and Article Of Association.

·        Committing any breach of the Memorandum Of Association and Article Of Association.

·        From committing any act which is contrary to the Act (The Indian Companies Act 2013.)

·        From committing any action which is contrary to the resolution of the member.

·        Company from Action on any resolution if passed by misstatement to members or depositors.



In addition the application can be made for the action against:

·        Company or director for any fraudulent or unlawful act.

·        Auditor for the improper or misleading statement.

·        Expert/advisor for any incorrect or misleading statement.




Who can file?


100 members/depositors needed.

1/10th if total members/depositors needed.

1/10 of total share capital/value of deposits needed, whichever is lower.

As depositors are included in this again getting 100 members or depositors would be the least number required in most public listed firms.

Points to be considered while applying under tribunal:

·        Whether application are made under good faith.

·        Any evidence for the involvement of the person.


·        Possibility of the ratification by the company.

If any application filed before the tribunal is found to be frivolous or vexatious, then the tribunal shall reject the application and make applicant pay the opposite party costs not exceeding one lakh rupees.

These were some important basic laws shareholder should be educated and made aware of to protect their rights and fight against the wrongdoings of companies.

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