The Registrar of Companies, Chennai passed an adjudication order dated January 7, 2026, imposing penalties under Section 454 read with Section 450 of the Companies Act, 2013, for violation of Rule 14(6) of the Companies (Prospectus and Allotment of Securities) Rules, 2014. The violation arose from failure to furnish complete details of allottees—such as PAN and email ID—in the return of allotment (Form PAS-3), which also led to rejection of Form NDH-4 by the Ministry earlier. The company contended that PAN and email ID were not mandatory for all allottees and that Rule 14(6) was inapplicable, besides arguing that rejection of NDH-4 itself amounted to punishment. These submissions were rejected. The Adjudicating Officer held that complete allottee details were mandatory and that rejection of NDH-4 did not preclude penalty. Consequently, penalties of ₹10,000 each were imposed on the company and its director, with directions to rectify the default and pay within 90 days, and appeal rights provided.
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
ROC Chennai
Registrar Of Companies, Block No.6,B Wing 2nd Floor, Shastri Bhawan 26, Haddows Road, Chennai, Tamil Nadu, India,
600034
Phone: 044-28276652/28276654, E-mail: roc.chennai@mca.gov.in
Order ID: PO/ADJ/12-2025/CN/01276 | Dated: 07/01/2026
ORDER FOR ADJUDICATION OF PENALTY UNDER SECTION 454 OF THE COMPANIES ACT, 2013 (‘THE ACT’) FOR VIOLATION OF SECTION 450 OF THE COMPANIES ACT, 2013.
A. Appointment of Adjudicating Officer:
Ministry of Corporate Affairs vide its Gazette notification number S.O. 831(E) dated 24/03/2015 appointed undersigned as Adjudicating Officer in exercise of the powers conferred by section 454 of the Companies Act, 2013 [herein after known as Act] read with Companies (Adjudication of Penalties) Rules, 2014 for adjudging penalties under the provisions of this Act.
B. Company details:
In the matter relating to MULAGUMOODU VICARIATE CATHOLIC NIDHI LIMITED ___________
Individual details:
In the matter relating to SAVARIMUTHU SEKHAR ______________
C. Provisions of the Act:
If a company or any officer of a company or any other person contravenes any of the provisions of this Act or the rules made thereunder, or any condition, limitation or restriction subject to which any approval, sanction, consent, confirmation, recognition, direction or exemption in relation to any matter has been accorded, given or granted, and for which no penalty or punishment is provided elsewhere in this Act, the company and every officer of the company who is in default or such other person shall be 1[liable to a penalty of ten thousand rupees, and in case of continuing contravention, with a further penalty of one thousand rupees for each day after the first during which the contravention continues, subject to a maximum of two lakh rupees in case of a company and fifty thousand rupees in case of an officer who is in default or any other person]
D. Facts about the case:
1. Default committed by the officers in default/noticee – Ministry vide order dated 04.07.2024 has rejected the form NDH-4 (Form for filing application for declaration as Nidhi and for updating of Status by Nidhi) filed by the company M/s. Mulagumoodu Vicariate Catholic Nidhi Limited (vide SRN: R77836211 dated 26.12.2020) wherein it was mentioned that the company has not mentioned the complete details in the list of allotees as required in Rule 14(6) of the Companies (Prospectus and Allotment of Securities) Rules, 2014 which read as follows:
14 (6) A return of allotment of securities under section 42 shall be filed with the Registrar within fifteen days of allotment in Form PAS-3 and with the fee as provided in the Companies (Registration offices and Fees) Rules, 2014 along with a complete list of all the allottees containing-
(i) the full name, address, permanent Account Number and E-mail ID of such security holder;
(ii) the class of security held;
(iii) the date of allotment of security ;
(iv) the number of securities herd, nominal value and amount paid on such securities; and particulars of consideration received if tire securities were issued for consideration other than cash.
Pursuant to the said order, it observed the subject company has violated the Rule 14(6) of Companies (Prospectus and Allotment of Securities) Rules, 2014. Hence, the company and its director is liable under Section 450 of the Companies Act, 2013
2. The Adjudicating Authority had issued notice for e-Adjudication on 06.10.2025. The Company vide letter dated 21.10.2025, submitted that they had given all the details of the allotees except PAN number and e-mail ID for some allotees and that there is no requirement for persons to become members of Nidhi to have a PAN number or e-mail ID and further submitted that non-filing of PAN number and e-mail ID for those allotees who did not have PAN number/e-mail ID is not a violation as per Rule 14(6) of Companies (Prospectus and Allotment of Securities) Rule, 2014. The Company further submitted that The Companies (Prospectus and Allotment of Securities) Rule, 2014 provides for submissions of Form PAS-3, with different particulars for Public offer(Rule 12(2)) and different set of particulars in the Return of Allotment in Form PAS-3 for Private Placement (Rule 14(6)) and that a Company allotting shares under one method cannot be expected to comply with both the allotment methods and since they filed PAS-3 under Rule 12(2), Rule 14(6) is not applicable and hence no penalty can be levied. The Company further submitted that the penalty under Section 450 is applicable only if no penalty/punishment is provided under any other punishment of the Act and that a punishment has already been provided to them by rejection of Form NDH-4 and hence, no penalty is leviable under section 450 on the Company or any officers of the Company.
E. Order:
1. The Ministry vide order dated 04.07.2024 had rejected the Form NDH-4 filed by the Company M/s. Mulagumoodu Vicariate Catholic Nidhi Limited Stating that the Company has not mentioned the complete details in the list of allotees furnished with Form PAS-3 filed with in MCA portal vide SRN R39882246 as required in Rule 14(6) of Companies (Prospectus and Allotment of Securities) Rule, 2014. Considering the aforesaid, the Company ought to have mentioned the complete details in the list of allotees as mandated under Rule 14(6) of the Companies (Prospectus and Allotment of Securities) Rules, 2014. Since the Company failed to comply with the said requirement, it has thereby violated Rule 14(6) of Companies (Prospectus and Allotment of Securities) Rules, 2014. Accordingly, the Company and its officers in default are liable for action under Section 450 of the Companies Act, 2013.
2. The details of penalty imposed on the company, officers in default and others are shown in the table below:
| (A) | Name of person on whom penalty imposed (B) | Rectification of Default required
(C) |
Penalty Amount
(D) |
Additional Penalty (E) (*Per day of continuing default i.e. date of rectification of default less order issue date) | Maximum limit for Penalty (F) |
| 1 | MULAGUMOODU VICARIATE CATHOLIC NIDHI LIMITED having CIN as U65991TN1995P LC030938 | 10000 | 0 | 200000 | |
| 2 | SAVARIMUTHU SEKHAR having DIN as 07559450 |
10000 | 0 | 50000 |
3. The notified officers in default/noticee shall rectify the default mentioned above and pay the penalty, so applicable within 90 days of receipt of the order.
4. The notified officers in default/noticee shall pay the penalty amount via ‘e-Adjudication’ facility which can be accessed through the respective login IDs on the website of Ministry of Corporate Affairs and upload the copy of paid challan / SRN of e-filing (if applicable) on the ‘e-Adjudication’ portal itself. It is also directed that the penalty so imposed upon the officers in default shall be paid from their personal sources/income.
5. Appeal against this order may be filed in writing with the Regional Director, RD Chennai within a period of sixty days from the date of receipt of this order, in Form ADJ setting for the grounds of appeal and shall be accompanied by a certified copy of this order [Section 454 (5) & 454 (6) of the Act, read with Companies (Adjudication of Penalties) Rules, 2014].
6. For penal consequences of non-payment of penalty within the prescribed time limit, please refer Section 454(8) of the Companies Act, 2013.
B SRIKUMAR,
Registrar of Companies
ROC Chennai
