The Registrar of Companies, Ernakulam, by Order ID PO/ADJ/07-2026/EK/02622 dated 03.08.2026, adjudicated penalty under Section 454 of the Companies Act, 2013 for violation of Section 450 in the matter of SECUREPRIME NIDHI LIMITED. The company had filed Form NDH-4, which was rejected by the Ministry on 23.11.2023. The company thereafter sought adjudication through Form GNL-1, admitting contravention of Rule 14(6) of the Companies (Prospectus and Allotment of Securities) Rules, 2014 due to incomplete details in the list of allottees in PAS-3 returns. As no specific penalty was prescribed, Section 450 was invoked. The company was directed to rectify the defect by filing relevant PAS-3 details through Form GNL-2. Following a show cause notice, e-hearing, and consideration of submissions, the ROC imposed a penalty of ₹10,000 each on the company and four officers in default. The company subsequently filed Form GNL-2 on 20.06.2026 with the list of allottees, stating that details of certain allottees could not be ascertained from its records. The order requires rectification and payment of penalty within 90 days and provides for appeal to the Regional Director, Bangalore.
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/02622 Dated: 03/08/2026
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 SECUREPRIME NIDHI LIMITED [herein after known as Company] bearing CIN U65929KL2020PLN061692, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at ROOM NO. 16, FIRST FLOOR PENTA ESTATE, H. NO. 35/1460C13 PALARIVATTOM ERNAKULAM ERNAKULAM KERALA INDIA 682025
Individual details:
In the matter relating to MULAMATTATHIL KUMARAN SABU__________
In the matter relating to JIHO MATHAI__________
In the matter relating to SHEENA VARGHESE________
In the matter relating to PAUL POTTACKAL__________
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 SECUREPRIME NIDHI LIMITED (hereinafter referred to as the company) has filed Form NDH-4 vide SRN T15130529 dated 20.04.2021 which was rejected by the Ministry vide order dated 23.11.2023.
2.The company has subsequently filed applications in e-Form GNL-1 vide SRN: N30386247 seeking adjudication of penalty for violation under Rule 14(6) of Companies (Prospectus and Allotment of Securities) Rules, 2014 stating that in the rejection order dated 23.11.2023 the Ministry has mentioned that the company has not mentioned the complete details in the list of allotees in PAS-3 returns filed by the company, 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 03.03.2026 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 26.03.2026 in terms of Section 454(4) of the Act, fixing the date of hearing on 06.04.2026. The hearing was re-scheduled to 22.04.2026 as per the request of the company. Sri. Midhunkumar, Company Secretary, attended the hearing and sought a lenient view in the matter.
After considering the submissions and 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.
Meanwhile the company filed GNL-2 vide SRN AC4100272 on 20.06.2026 enclosing the list of allottees and stating that they are unable to ascertain the said details of certain allottees, as the relevant information is not available in the Company’s records and could not be obtained.
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 | SECUREPRIME NIDHI LIMITED having CIN as U65929KL2020PL N061692 | 10000 | 0 | 200000 | |
| 2 | MULAMATTATHI L KUMARAN SABU having DIN as 08707787 | 10000 | 0 | 50000 | |
| 3 | JIHO MATHAI having DIN as 08707788 | 10000 | 0 | 50000 | |
| 4 | SHEENA VARGHESE having DIN as 08707789 |
10000 | 0 | 50000 | |
| 5 | PAUL POTTACKAL having DIN as 08841125 |
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
