The Registrar of Companies, Ernakulam, issued Order ID PO/ADJ/07-2026/EK/02545 dated 24.07.2026 under Section 454 of the Companies Act, 2013 for adjudication of penalty against Fairfin Secure Nidhi Limited for violation of Section 450 arising from non-compliance with Rule 14(6) of the Companies (Prospectus and Allotment of Securities) Rules, 2014. The company stated in its application that, while processing Form NDH-4, the Ministry found that complete details of allottees had not been furnished in the Form PAS-3 filings since incorporation, and the company admitted the default. As no specific penalty is prescribed for the contravention, Section 450 was invoked. The company was directed to rectify the defect by filing the relevant Form PAS-3 details through Form GNL-2, but had not complied with this direction. Following the issue of a show cause notice and an e-hearing, the Registrar imposed a penalty of ₹10,000 each on the company and five officers in default. The order directs payment of the penalties within 90 days and provides for an appeal to the Regional Director, Bangalore, within 60 days.
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
ROC Ernakulam
Registrar Of Companies, Corporate Bhawan, BMC Road, Thrikkakara, Ernakulam, Kerala, India, 682021
Phone: 0484-2421626/2421310
Fax: 0484-2422327
E-mail: roc.ernakulam@mca.gov.in
Order ID: PO/ADJ/07-2026/EK/02545 | Dated: 24/07/2026
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. 698(E) dated 10/02/2026 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 FAIRFIN SECURE NIDHI LIMITED [herein after known as Company] bearing CIN U65999KL2020PLN065590, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at DOOR NO.II/III(3), TMC-51/933(3), FIRST FLOOR ANNE’S TOWER,KANJANI ROAD,AYYANTHOLE P O ,CHUNGAM NA THRISSUR THRISSUR KERALA INDIA 680003
Individual details:
In the matter relating to JAYAKUMAR PUTHIRATH __________
In the matter relating to KUNIPPARA RAMAKRISHNAN DIVYA __________
In the matter relating to TOTTINGAL MOHANAKRISHNAN __________
In the matter relating to . MEENAKSHI __________
In the matter relating to . RAMAKRISHNAN __________
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 – Rule 14(6) – Companies (Prospectus and Allotment of Securities) Rules, 2014
1. The company FAIRFIN SECURE NIDHI LIMITED (hereinafter referred to as the company) has filed Form NDH-4 vide SRN AB2566775 dated 03.02.2025 which was rejected by the Ministry vide order dated 15.12.2025.
2. The company has subsequently filed application in e-Form GNL-1 vide SRN: AC2194253 seeking adjudication of penalty for violation of Rule 14(6) of Companies (Prospectus and Allotment of Securities) Rules, 2014 stating that while processing Form NDH-4 filed by the company, the Ministry has made finding that the company has not mentioned complete details in the list of allottees provided alongwith Form PAS-3 since incorporation, thereby contravening the above Rules. The company has also admitted the default. Further, since no specific penalty or punishment has been prescribed for the aforesaid default, the provisions of Section 450 of the Companies Act, 2013 (general penalty) are attracted which provides for adjudication. Accordingly, adjudication proceedings are initiated against the company and its officers in default during the relevant period.
3. Further, in exercise of powers under Section 454(3)(b) of the Companies Act, 2013, the company is also directed to rectify the defect by filing the relevant details of Form PAS-3, through Form GNL-2, in order to bring the records on par.
2. Opportunity for hearing was given
E. Order:
1. A Show Cause Notice dated 21.04.2026 was issued to the company and its officers in default under Section 454 of the Companies Act, 2013, calling upon them to explain why penalty should not be imposed under Section 450 of the Act for the default committed.
Subsequently, a notice for e-hearing was issued on 12.05.2026 in terms of Section 454(4) of the Act, fixing the date of hearing on 18.05.2026. Sri. Edison Mathew, Company Secretary, attended the hearing and sought a lenient view in the matter.
After considering the material available on record and in exercise of the powers conferred under Section 454(3) of the Companies Act, 2013 read with Rule 3 of the Companies (Adjudication of Penalties) Rules, 2014, penalty as prescribed under Section 450 of the Act is hereby imposed on the company and its officers in default.
However, the company has not complied with the directions with respect to filling the missing PAS-3 details in GNL-2.
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 | FAIRFIN SECURE NIDHI LIMITED having CIN as U65999KL2020PL N065590 | 10000 | 0 | 200000 | |
| 2 | JAYAKUMAR PUTHIRATH . having DIN as 08091038 | 10000 | 0 | 50000 | |
| 3 | KUNIPPARA RAMAKRISHNAN DIVYA having DIN as 08950832 | 10000 | 0 | 50000 | |
| 4 | TOTTINGAL MOHANAKRISHN AN having DIN as 08950853 | 10000 | 0 | 50000 | |
| 5 | MEENAKSHI having DIN as 09791122 | 10000 | 0 | 50000 | |
| 6 | RAMAKRISHNAN having DIN as 10103803 | 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 Bangalore 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.
Anu Vivek,
Registrar of Companies
ROC Ernakulam
