Case Law Details

Case Name : Sital Prasad Swain Vs Disciplinary Committee (Authority For Advance Ruling)
Appeal Number : Appeal No. 07/ICSI/2017
Date of Judgement/Order : 04/08/2018
Related Assessment Year :
Courts : Advance Rulings (420)

Sital Prasad Swain Vs Disciplinary Committee (Appellate Authority)

It is pained to note that none of the parties filed the original minute books or the resolution passed which are the subject matter relevant to the filing of two forms i.e. Form-32 filed for the appointment of Shri Bishender Singh as an Additional / Promoter Director and secondly, the form regarding cession of Pramod Khosla and his wife as the Directors of the Company under Section 283(1) (g) of the Companies Act, 1956.

It was in these circumstances, after giving detailed hearing to both the parties and having gone through the record of this case, and the order passed by the Disciplinary Committee dated 22ndJuly, 2015 extract whereof we have discussed in this order in detail, we are of the considered view that in this case, it has been clearly held that the Appellant was negligent in filing Form-32 on both the occasions and failed to exercise diligence required on his part.

We have also gone through the Written Arguments, filed on behalf of both the parties. We are of the considered view that it is not a case where the professional i.e. the Appellant was expected to act as an investigator. What was required for him was to only see the contents of the resolution passed and relied upon in support of Form-32 himself and in case, it was shown to him in minute books, than he should have been very categorical as to who was in possession of minute books shown to him containing the resolutions in question. However, in this regard, no assistance has been provided to us.

As stated above, we are of the considered view that in the present case, the Disciplinary Committee after the remand of the matter has gone through the entire controversy in detail, given cogent reasons in holding that the Appellant was Guilty of Professional Misconduct under item (7) of Part-I of the Second Schedule of the Act in as much as he did not exercise due diligence while certifying the two Forms-32 on both the occasions and as such he was grossly negligent in the conduct of his professional duties. We accordingly dismiss the appeal while maintaining the order of sentence as awarded by the Disciplinary Committee in this case, which according to us is not excessive in any manner.

FULL TEXT OF ADVANCE RULING

1. Being aggrieved by the Order dated 28thApril, 2017 (Impugned Order) passed by the Disciplinary Committee of the Institute of Company Secretaries of India under Sub-Section (3) of Section 21B of the Company Secretaries Act, 1980 (hereinafter referred to as the “Act”) read with rule 19 (1) of the Company Secretaries (Procedure of Investigations of Professional and Other Misconduct of Cases) Rules, 2007 (hereinafter referred to as the “Rules”), Mr. Sital Prasad Swain has filed this appeal under Section 22E of the Act challenging the Impugned Order.

2. The original proceedings started with filing of the complaint dated 10th September, 2011 by Mr. Pramod Khosla (hereinafter referred to as complainant) wherein, it was alleged that professional misconduct has been committed by the Appellant while practicing as a Company Secretary for M/s. Khosla Steel Industries Private Ltd. (hereinafter referred to as Company). It was alleged that in the Board of Directors meeting held on 10th August, 2011, while Mr. Bishendra Singh was appointed only as an Additional Director of the Company with effect from 10th August, 2011 under section 260 of the Companies Act, 1956, and was to hold his office up to the conclusion of the next Annual General Meeting (AGM), in Form – 32, signed by Mr. Kishor Khosla (KK), a Director of the Company and verified by the Appellant, wherein, the appointment of Mr. Bishendra Singh was shown as a Director under the category of ‘Promoter’ and not as Additional Director.

It was further alleged that Mr. Kishore Khosla, resigned on 20th December, 2011 and his resignation was accepted by the Board of Directors (BOD) in the meeting held on the same day. The Complainant and his wife (who were also the Directors of the Company) were present in that Meeting. It has also been alleged that Form-32 showing the cessation of Mr. Pramod Khosla and his wife Ms. Sarita Khosla on the ground of their having vacated offices of Director under Section 283 (1) (g) of the Companies Act, 1956 was signed by Mr. Bishender Singh, though he was not a Director of the Company on that date, and was filed by the Appellant after verifying and certifying the said form. It has been alleged that in this Form the reason for removal mandatorily required to be attached in terms of Ministry of Corporate Affairs Circular No.01/2012 dated 10th February, 2012 were not attached. It has been stated that in meetings held on 27th February, 2012, the cessation of Mr. Pramod Khosla and Mrs. Sarita Khosla was wrongly approved on the ground that they had not attended the previous three meetings consecutively held on 11th November, 2011, 13th December, 2011 and 19th January, 2012, by ignoring the Board of Directors meeting held on 20th December, 2011 as they had attended the said meeting and could not have been treated as absent from three consecutive meetings as required by the Section 283 (1) (g) of the Companies Act, 1956 in the complaint. The Board of Directors meeting held on 20th December, 2011 in which the Complainant and his wife were present, had been ignored while certifying Form 32 by the Appellant. It has been alleged that at the Board of Directors meeting held on 20th December, 2011, the resignation of Shri Kishore Khosla, another Director of the Company was accepted, which fact, was informed to them by ROC.

It was further stated that the Annual General Meeting (AGM) of the Company was held on 30th August, 2011. Mr. Bishender Singh, whose appointment could only be as Additional Director, was not re-appointed as a Director of the Company at the AGM held on 30th August, 2011 and therefore, he ceased to be an Additional Director of the company on the conclusion of the AGM. Therefore, he could not have signed Form 32 showing the cessation of Shri Pramod Khosla and Ms. Sarita Khosla under section 283 (1) (g) of the Companies Act, 1956. With these averments, the complainant submitted that the Appellant while working as Company Secretary for the company did not exercise due diligence in verifying and certifying Form-32 on both the occasions.

3. On the aforesaid complaint, the Director (Discipline) formed a ‘Prima-Facie Opinion’ (PFO) that there had been laxity on the part of the Appellant while certifying Form-32 and observed that he was Prima Facie Guilty of Professional Misconduct under item (7) of Part-I of the Second Schedule of the Act having not exercised due diligence and being grossly negligent in the conduct of professional duties.

4. The matter was finally decided by the Disciplinary Committee holding Appellant guilty of committing misconduct under item (7) of Para-I of Second Schedule of the Company Secretaries Act, 1980, for not exercising due diligence in the conduct of his professional duties and awarded the punishment of (i) reprimand and (ii) a fine of Rs.5,000/- (Rupees Five Thousand Only).

5. The Appellant than filed an appeal against the said order before this Authority which at the relevant time was presided over by Justice P.K. Bhasin. The said appeal was registered vide Appeal No.11/ICSI/2015. The Authority at that time, after hearing the parties set aside the order of the Disciplinary Committee and remanded the matter by giving certain directions to the Disciplinary Committee to pass a fresh order.

6. It was in these circumstances, the matter came up before the Disciplinary Committee of the Institute again. The matter was taken up on 7th August, 2016 when the Disciplinary Committee called upon all the parties concerned before it and also gave liberty to them to file additional documents on 11thNovember, Mr. Nitin Khosla son of the Complainant appeared and made oral submissions on behalf of the Complainant. The Appellant did not appear as he had sought adjournment for the hearing.

7. The Disciplinary Committee directed Mr. Khosla to submit documents, not later than 21stNovember, 2016, namely, (i) Copy of Notice, (ii) Proof of service of the said notice, (iii) Attendance Register and (iv) Minutes of meeting of the AGM of M/s. Khosla Steel Industries Pvt. Ltd., held on 30th August 2011. The Disciplinary Committee further directed the Complainant to submit the aforesaid documents by 21st November, 2016 along with any additional document that would be directly relevant to the Complaint and fixed the hearing of the matter on Friday, the 2nd December 2016, at New Delhi.

8. Before the Disciplinary Committee, the Complainant submitted the following documents on 02-12-2016:-

(a) Notice of AGM dated 30/08/2011

(b) Attendance Sheet of AGM dated 30/08/2011

(c) Proof of service

(d) Minutes of meeting of AGM held on 30/08/2011.

9. After the hearing the parties including the Appellant, the Disciplinary Committee gave following findings:-

32. The allegations in the complaint are that the Appellant failed to exercise due diligence while certifying and filing two (2) Forms-32 relating to (i) the appointment of Shri Bishender Singh as a “Promoter Director” of Khosla Steel Industries Pvt. Ltd. and (ii) cessation of Shri Pramod Khosla and his wife Ms. Sarita Khosla as Directors of the Company under section 283 (1) (g) of the Companies Act, 1956.

33. In so far as the Form relating to the appointment of Shri Bishernder Singh as Promoter Director of the Company is concerned it has been alleged by the Complainant that the Board of Directors in its meeting held on 10.08.2011, had approved the appointment of Shri Bishernder Singh as an Additional Director of the Company, in terms of Section 260 of the Companies Act, 1956. The Additional Director appointed by the Board of Directors shall hold office only upto the date of next Annual General Meeting of the Company. In the Form – 32 certified by the Appellant for the appointment of Shri Bishender Singh he has not been shown as an Additional Director as approved by the Board of Directors but has been shown as Director under the category of “Promoter” Director.

35. The Promoter Director concept can be inferred from the Companies Act, 1956, and as well as by prevailing practice in the companies. The Promoter Director is a person who is instrumental in the formation of the company, incorporates the company, brings the capital and commences its business or who has taken the control of the company and whose name has been identified as Promoter Director and accepted by the Board of Directors. The second situation in the course of affairs generally emerges in listed or public companies where the change of management happens.

36. In the given case, there are two contradictory resolutions submitted by the parties before the Disciplinary Committee namely-

(a) Resolution passed in the meeting of Board of Directors purported to have been held on 10thAugust, 2011, for appointment of Shri Bishender Singh as Additional Director of M/s. Khosla Industries Pvt. Ltd. which is signed by 3 Directors, submitted by the complainant; and;

(b) Resolution passed in the Extra Ordinary General meeting purported to have been held on 10thAugust, 2011 for appointment of Shri Bishender Singh as Director (Executive Director and Promoter Category) of M/s. Khosla Industries Pvt. Ltd. which is signed by Ms. Neelam Khosla without mentioning the date and place, which was submitted by the Appellant.

37. It is prerequisite for a certified copy of a resolution that it shall be signed with date and place. It has been alleged by the complainant that Ms. Neelam Khosla could not have signed the purported EOGM Resolution dated 10.08.2011 as she was not a Director at that time. She has also not signed the Attendance Register for Board Meetings for last so many years since she had shifted to Delhi in 2004 and she procured her DIN in 2012 only.

38. In form 32 pertaining to the appointment of Shri Bishender Singh as Promoter Director certified by the Appellant, no certified copy of resolution is produced. Moreover, verification in Form 32 states that the signatory i.e. Shri Kishore Khosla is authorised by the Board of Directors vide Resolution No. 2 dated 10thAugust, 2011 which matches with the resolution submitted by the Complainant signed on 2nd September, 2011.

39. Further, with respect to Form 32 pertaining to the Appointment of Shri Bishender Singh it was the duty of the Appellant who is a Practising Company Secretary (PCS) to act with due diligence while certifying the form to ensure that the Director so appointed as per the form has been duly appointed by the Company as per the provisions of the Companies Act, 1956. The PCS is required to ensure that a copy of the resolution is annexed as an attachment to the Form for the record of the Regulatory Authorities while filing the form in support of his diligence, at least in crucial and specific cases where the matter is sub-judice also when there are disputes in the management.

40.The Practising Company Secretary, while certifying the form for appointment of a Director who was appointed in an Extra Ordinary General Meeting, is required to verify the following for his diligence and keep copies in his custody of the following:

(i) Copies of the notice of the Extra Ordinary General meeting.

(ii) Evidence not only of dispatch but of service of such notices within stipulated time.

(iii) Copy of the extract of minute/minute of the meeting.

(iv) Explanatory Statement.

(v) Copy of the Resolution for appointment/authority.

(vi) Agenda of Extra Ordinary General meeting. 

41. In the present case, the Appellant has submitted only an extract of the Resolution of the Extra Ordinary General Meeting held on 10thAugust, 2011 signed by Ms. Neelam Khosla but the Form 32 was certified by Shri Kishore Khosla.

42. The Appellant, by affixing his signature on the said Form 32, endorsed the authority of Shri Kishore Khosla to sign the form though, the copies of the resolution are not mandatory attachments but certain documents are required to be maintained by the Practising Company Secretary for his diligence and also for the records of the Regulatory Authorities.

43. Based on the above documents, it is evident that the appointment of Shri Bishender Singh as Promoter Director was not properly verified with proper documents viz Consent of Director in Board Meeting/Agreement/Specific documents of Extra Ordinary General Meeting with explicit statement of authorisation with duly certified Board Resolution and reliance of the Appellant on the certified copy of extract of the minutes of the Extra Ordinary General Meeting held on 10thAugust, 2011, which is not in order, shows that the Appellant has failed to exercise due diligence while certifying the Form 32 pertaining to appointment of Shri Bishender Singh.

44. In the common parlance a Promoter Director means a person who promotes a Company and is named as one of the First Directors in the articles of association of the Company. Shri Bishender Singh did not fulfil this requirement. Therefore, the Appellant has not exercised due diligence in certifying and filing this Form-32 relating to the appointment of Additional Director of the Company despite having been fully aware of the fact that the Board of Directors in its meeting held on 10.08.2011 had approved the appointment of Shri Bishender Singh only as an Additional Director. By changing the category of Shri Bishender Singh from Additional Director to Promoter Director the Appellant tampered with the public record to show that Shri Bishender Singh was not liable to retire at the next Annual General Meeting of the Company.

45. There is a dispute about the date of holding of AGM. According to the Complainant the AGM was held on 30.08.2011 but the agenda of the meeting did not include any item pertaining to the appointment of Shri Bishender Singh as Director. In the absence of such an item, Shri Bishender Singh ceased to be Director of the Company with effect from 10.08.2011. In support of his contention the Complainant has produced Notice of the Meeting, Proof of Service, the attendance sheet signed by the shareholders and copy of the Minutes of the AGM held on 30.08.2011.

46. The case of the Appellant, on the contrary, is that no AGM was held on 30.08.2011. According to him the AGM was held on 18.08.2012. In support of his contention it has been stated that the Annual Accounts of the Company were signed by the statutory auditors only on 14.05.2012 and, therefore, the AGM could not be held on a date prior to the date of signing of the Annual Accounts by the statutory Auditors. In response to this contention, the Complainant has stated that the Annual Accounts could not be adopted in the AGM on 30.08.2011 as the Statutory Auditors did not sign the Annual Accounts in connivance with the other side, though these accounts had been sent to him. The item relating to the consideration and adoption of the Annual Accounts had to be postponed.

47. The averments of the complainant are not borne out by the minutes of the 25thAGM of the company held on 30.08.2011. In the aforesaid minutes it is recorded as under;

“The Chairman expressed his hope that the member present have gone through the audited accounts for the FY 2010-11, auditor’s report and the Directors’ Report for the year which were sent to them along with notice calling the Annual General Meeting. Mr. Kishore Khosla stated that let the Notice calling the Annual General meeting, annual audited accounts for FY 2010-11, auditor’s report thereon and the Director’s Report for the year be treated as read.

The members discussed the reports, accounts and a detailed discussion followed. After that the Chairman moved the motion to adopt the audited Profit & Loss Accounts for the year ended 31.04.2011, the Balance Sheet as at 31.03.2011 along with its Schedule and notes to accounts, auditor’s report thereon and the Director’s report for the year. The motion and the following resolution was:

Proposed by Mrs. Veena Khosla

Seconded by Mrs. Sarita Khosla 

“RESOLVED THAT the audited profit and loss account for the year ended 31.10.2011 the Balance Sheet as 31.03.2011 along with its Schedules and notes to account, auditor’s report thereon and the Directors’ report for the year for the company, be, and/are, hereby received, adopted and approved”

48. The appraisal of the aforesaid facts brings out that AGM was held on 30.08.2011 and since the agenda for the meeting did not contain any item relating to the appointment of Shri Bishender Singh, he, in terms of the provisions of the Companies Act, 1956, ceased to be the Director of the Company from that date. It is clearly established that the Appellant failed to exercise diligence, expected of him, while certifying and filing Form 32 regarding the Appointment of Shri Bishender Singh as “Promoter Director”.

49. In so far as Form-32 relating to the removal of the Complainant and his wife from the directorship of M/s Khosla Steel Industries Pvt. Ltd., purportedly under section 283 (1) (g) of the Companies Act, 1956, is concerned the Disciplinary Committee noted that Section 283 (1)(g) of the Companies Act, 1956, read as under:

“Vacation of office by the Directors

283 (1): The office of the Directors shall become vacant if-

X x x x x

(g): He absents himself from three consecutives meetings of the Board of Directors, or from all meetings of the Board for a continuous without obtaining leave of absence from the Board.”

50. The Complainant has alleged that the Appellant did not exercise due diligence to ensure that the conditions laid down in Section 283 (1) (g) of the Companies Act, 1956, were satisfied, while verifying and certifying the Form-32 in this regard. It has been alleged by the Complainant that he and his wife attended the Board of Directors meeting held on 20.12.2011 in which the resignation of Shri Kishore Khosla, another Director of the Company, was accepted by the Board of Directors. The alleged removal of the Complainant and his wife from the directorship of the Company in the Board of Directors meeting held on 27.02.2012 was on the ground of absence from three consecutives Board meetings stated to have been held on 11.11.2011, 13.12.2012, 09.01.2012. He has alleged that the Appellant did not take into account the Board of Directors meeting held on 20.12.2011, and consequently the appellant is guilty of not exercising due diligence.

52. The Disciplinary Committee considered the arguments of the representatives of the Complainant and the appellant on 2nd December, 2016 and examined all the documents submitted by the Complainant vide letter dated 6th December, 2016 and by the appellant vide email dated 6th December, 2016. It has been observed that the dispatch proof has been submitted by the appellant with respect to the Board Meeting held on 27thFebruary, 2012 addressed to Jamshedpur. The frequency of Board meetings was so regular within the span of 3 months with regular and routine items of business. The fact that the Complainant is not available was also known to the appellant because of non-bailable warrants issued against the Complainant and his family. It appears from the documentary evidence that the appellant construed the violation intended under section 283(1)(g) in literal sense for removal of

53. The appellant, who is PCS, is not required to understand the intention. However, he is required to exercise due diligence by verifying the following documents:

(i) Notice of the Board meeting.

(ii) Agenda of the Board meeting.

(iii) Proof of Dispatch of Notice of the Board Meeting.

(iv) Minutes of the meeting duly signed by the Chairman.

(v) Documentary Evidence for requisite Quorum i.e. Attendance Sheet.

54. The removal of a Director of the Company is a serious matter particularly when the Appellant was aware of the existence of the management dispute. Therefore, it was incumbent upon him to be more vigilant and send a written communication to the Director for providing him an opportunity before verifying and certifying Form-32 for his removal as a principle of natural justice.

55. In the present case, the appellant verified the minutes and relied on the proof of dispatch of the notice sent through Speed Post on 22nd February, 2012 which was sent to Jamshedpur address. There is no proof of service of the notices on the Complainant and his wife. The fact that the management conducted the Board Meeting for the removal of Director by sending notice to a place where the Complainant was not available, appears to have been known to the Appellant while certifying the form as the appellant has admitted in his submission dated 2nd December, 2016, that he relied upon the Advocate’s Report stating that the Complainant is absconding with this family.

56. The diligence which is supposed to be shown by the Practising Company Secretary is not merely restricted to the verification of the documents but also it extends to the purpose of law for which it is envisaged to be exercised by him.

57. Section 283(1) (g) of the Companies Act, 1956 provides for Removal of Director who after due notice of Board meeting fails to attend the meeting either intentionally or because of pre-occupation or for any other reason but surely not for failure to receive the notice.

10. Consequently, the Disciplinary Committee of the Institute held that the Appellant was guilty of negligence as detailed by them under Para (58 to 61) of the Impugned Order and again hold the Appellant guilty and awarded the same punishment which was awarded earlier in Para (62) of the order which reads as under:-

After considering the pleadings, material on record detailed submissions of both the parties, hearing arguments at length and totality of all the facts and circumstances, the Disciplinary Committee reiterates its earlier decision passed vide order dated 22nd July, 2015 wherein the Appellant was held guilty of professional or other misconduct for not exercising due diligence and passed the following Order under Section 21(B) (3) of the Company Secretaries Act, 1980 read with proviso to Rule 19(1) of the Company Secretaries Procedure (Procedure of Investigations of Professional or Other misconduct and Conduct of Cases) Rules, 2007:

(i) Reprimand and; (ii) Fine Rs. 5000/-

11. It is against the aforesaid order; the Appellant approached us by filing the present appeal.

12. During the course of hearing, we were confronted with basic controversy regarding filing of Form-32, regarding resolutions dated 10th August, 2011 and 20th December, 2011. We, therefore, thought it appropriate to pass the following order on 19.01.2018, this order reads as under:-

“After hearing of both the parties, we feel that perusal of the original minute’s book pertaining to all dates of which there is reference regarding the resolutions which have been passed by the Company and perused by the Appellant in this case before certifying Form 32 are required to verify certain facts in the present matter. Therefore, we direct the parties of this matter more particularly in whose possession the same are kept, to bring the original minutes book before us on the next date of hearing of this Appeal. In case, if it is not in the possession of either party than they are directed to file an Affidavit, as to whether those documents are not in their profession.

2. In the meanwhile, both the parties are directed to file their respective written submissions highlighting the main issues pointing out the differences before the Authority before the next date of hearing.”

13. On 10thApril, 2018, we have passed the following order:-

“2. Further, in terms of the directions issued vide Order dated 19th January, 2018 passed earlier by this Authority, the Appellant as well as Respondent No.2 were directed to file an Affidavit specifying that under whose possession the original minutes book pertaining to all dates of which there is reference regarding the resolutions which have been passed by the Company and perused by the Appellant in this case before certifying Form 32. Therefore, in compliance, both the parties have filed an Affidavit along-with written submissions stating that the original minute books and the resolutions passed are not in their respective possession.

3. Therefore, in view of the above, the core issue involved in this case before us for consideration, which requires its proper response so as to decide the matter finally, is that when Form-32 were filed by the Appellant as a Company Secretary on both the dates, i.e., on 5th September, 2011 and 27thFebruary, 2012, whether he had seen the original minutes before certifying Form-32 on both the mentioned dates. If yes, who saw him these original minutes? In other words, under whose physical possession, the said original minutes were at that relevant time? Further, while certifying and filing Form-32 on both the dates, what documents were filed as an attachment with these Forms by the Appellant?

4. Based on the above, therefore, we hereby direct the Appellant to file an affidavit mentioning specifically the details as to the observations made by us under Para (3) of this Order, within two weeks from the date of receipt of this Order. An advance copy of the affidavit to be filed before this Authority shall also be provided by the Appellant to Respondent No.2 well before at least one week from the next date of hearing of this matter.

5. Further, in case the appellant has copies of the original minutes in his possession, we also grant the liberty to him to annex the copy of the same with other relevant documents on which he relied before certifying and filing Forms-32 along-with the requisite affidavit. “

14. It is pained to note that none of the parties filed the original minute books or the resolution passed which are the subject matter relevant to the filing of two forms i.e. Form-32 filed for the appointment of Shri Bishender Singh as an Additional / Promoter Director and secondly, the form regarding cession of Pramod Khosla and his wife as the Directors of the Company under Section 283(1) (g) of the Companies Act, 1956.

15. It was in these circumstances, after giving detailed hearing to both the parties and having gone through the record of this case, and the order passed by the Disciplinary Committee dated 22ndJuly, 2015 extract whereof we have discussed in this order in detail, we are of the considered view that in this case, it has been clearly held that the Appellant was negligent in filing Form-32 on both the occasions and failed to exercise diligence required on his part.

16. We have also gone through the Written Arguments, filed on behalf of both the parties. We are of the considered view that it is not a case where the professional i.e. the Appellant was expected to act as an investigator. What was required for him was to only see the contents of the resolution passed and relied upon in support of Form-32 himself and in case, it was shown to him in minute books, than he should have been very categorical as to who was in possession of minute books shown to him containing the resolutions in question. However, in this regard, no assistance has been provided to us.

17. As stated above, we are of the considered view that in the present case, the Disciplinary Committee after the remand of the matter has gone through the entire controversy in detail, given cogent reasons in holding that the Appellant was Guilty of Professional Misconduct under item (7) of Part-I of the Second Schedule of the Act in as much as he did not exercise due diligence while certifying the two Forms-32 on both the occasions and as such he was grossly negligent in the conduct of his professional duties. We accordingly dismiss the appeal while maintaining the order of sentence as awarded by the Disciplinary Committee in this case, which according to us is not excessive in any manner.

18. We, however, make it clear that since there is a dispute of management by the two sides of Khosla family and parties are already before various forums, observations made by us against the Appellant who is a professional will not be used against him in other litigations.

More Under CA, CS, CMA

Posted Under

Category : CA, CS, CMA (3855)
Type : Judiciary (12267)
Tags : company secretaries (181) ICSI (430)

Leave a Reply

Your email address will not be published. Required fields are marked *