The Registrar of Companies (ROC), Kanpur, issued an Adjudication Order (dated 13/10/2025) under the Companies Act, 2013, imposing a penalty on SEN HON LEE TECHNOLOGIES PRIVATE LIMITED and six of its directors for non-compliance with statutory requirements concerning the maintenance of corporate records. The violation specifically relates to Section 118(10) read with the penal provision Section 118(11), stemming from multiple failures to adhere to Secretarial Standard-1 (SS-1) regarding meetings of the Board of Directors. An inquiry identified five distinct lapses in record-keeping, noting that the company had not complied with these crucial standards since its incorporation. The breaches included the failure to ensure consecutive numbering of pages in the Minutes Books (SS-1, 7.1.4) and the lack of recording of the date of entry of the Minutes (SS-1, 7.5.2). Furthermore, the company was found non-compliant regarding its attendance registers, which lacked serial numbering for both pages and meetings (SS-1, 4.1.1 and 4.1.2). Finally, the company failed to include the mandatory statement on compliance with applicable Secretarial Standards in the Directors’ Report for the financial year ending March 31, 2020 (SS-1, 9).
The formal adjudication process was initiated with the issuance of a Show Cause Notice on June 24, 2025. The order explicitly documents that the company and the six officers in default—Wu Xiaoping, Nakul Kumar Bhati, Zhiyong Zhou, Sachin Bhartiya, Huang Weifei, and Gautam Singh—failed to submit any response to the notice or request an opportunity for a formal hearing within the prescribed time limit. Consequently, the Adjudicating Officer proceeded with the imposition of penalties under Section 118(11) of the Act. The maximum penalty of ₹25,000 was levied against the company, and the maximum individual penalty of ₹5,000 was imposed upon each of the six named directors. The cumulative penalty for these repeated and long-standing administrative defaults totaled ₹55,000.
The ROC order mandates the company and all penalized directors to immediately rectify the enumerated defaults to achieve full compliance with Secretarial Standard-1 and the associated provisions of the Companies Act. The total penalty amount must be paid within 90 days of the order’s receipt via the Ministry of Corporate Affairs’ ‘e-Adjudication’ facility, with the directors being strictly required to pay their portion from personal funds. The order also outlines the right to appeal the decision by filing Form ADJ with the Regional Director, RD Noida, within sixty days from the date of receipt, while simultaneously cautioning the noticees about the penal consequences detailed in Section 454(8) for non-payment within the specified period.
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
ROC Kanpur
Registrar of Companies, 37/17, Westcottt Buidling, The Mall, Kanpur, Uttar Pradesh, India, 208001
Phone: 0512-2310443,2310227,2310323
E-mail: roc.kanpur@mca.gov.in
Order ID: PO/ADJ/10-2025/KN/00763 Dated: 13/10/2025
ORDER FOR ADJUDICATION OF PENALTY UNDER SECTION 454 OF THE COMPANIES ACT, 2013 (‘THE ACT’) FOR VIOLATION OF SECTION 118(11) 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 SEN HON LEE TECHNOLOGIES PRIVATE LIMITED [herein after known as Company] bearing CIN U25209UP2019PTC117599, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at PLOT NO 10, KASNA ECOTECH -1 EXTENSION -1 NA GREATER NOIDA GAUTAM BUDDHA NAGAR UTTAR PRADESH INDIA 201308
Individual details:
In the matter relating to WU XIAOPING [herein after known as individual] having DIN 08602212 and having its address at
In the matter relating to NAKUL KUMAR BHATI [herein after known as individual] having DIN 09473679 and having its address at
In the matter relating to ZHIYONG ZHOU [herein after known as individual] having DIN 08415698 and having its address at
In the matter relating to SACHIN BHARTIYA [herein after known as individual] having DIN 08415718 and having its address at
In the matter relating to HUANG WEIFEI [herein after known as individual] having DIN 08517634 and having its address at
In the matter relating to GAUTAM SINGH [herein after known as individual] having DIN 08575001 and having its address at
C. Provisions of the Act:
(11) If any default is made in complying with the provisions of this section in respect of any meeting, the company shall be liable to a penalty of twenty-five thousand rupees and every officer of the company who is in default shall be liable to a penalty of five thousand rupees.
D. Facts about the case:
1. Default committed by the officers in default/noticee – The Directorate vide its letter no. Inq./Guard/2021/10971 dated 17.12.2021 and Ministry?s letter no. F.No. CL-II-08/131/2021-DGCoA-MCA dated 13.12.2021 directed to conduct the inquiry u/s. 206(4) of the Companies Act, 2013, against the said company. On examining the minutes and attendance register of board meetings for the financial year 2019-20, 2020-21 and 2021-22 it was found that (i) As per point no.7.1.4 of Secretarial Standard-1, the pages of the Minutes Books shall be consecutively numbered. The Company has not complied with the same since incorporation. (ii) As per point no. 7.5.2 of Secretarial Standard-1, the date of entry of the Minutes in the Minutes Book shall be recorded by the Company Secretary/ Chairman. (iii) As per point no. 4.1.1 of Secretarial Standard-1, the pages of the respective attendance registers shall be serially numbered (which were not done). (iv) As per point no. 4.1.2 of Secretarial Standard-1, the attendance register shall contain serial number of the Meeting (which was not done). (v) As per point no.9 of Secretarial Standard-1, the Report of the Board of Directors shall include a statement on compliances of applicable Secretarial Standards. However, the Company has not disclosed the same in the director?s report for the financial year ended 31.03.2020. Accordingly, the said violation was reported by the Inquiry officer in report dated 08.06.2022. The O/o DGCoA vide its letter No. CL-II-04/190/2022-O/o DGCoA dated 12.08.2024 has accorded the sanction to take penal action. Thus, it is evident that the company and its Directors have failed to comply with the provisions of Secretarial Standard-1 read with Section 118(10) of the Companies Act, 2013. And are thus liable for penal provisions U/s 118(11) of the Companies Act, 2013.
2. Neither any response has been received from the company and its officers-in-default nor any request of hearing received in this regard.
E. Order:
1. This office issued Show Cause Notice on 24.06.2025 to the company and its officer-in-default as the Company has failed to maintain proper minute book in terms of Section 118 of the Companies Act, 2013 read with Secretarial Standard-1 due to the following:
i)Point no.7.1.4 of Secretarial Standard-1, the pages of the Minutes Books shall be consecutively numbered. The Company has not complied with the same since incorporation.
ii)Point no. 7.5.2 of Secretarial Standard-1, the date of entry of the Minutes in the Minutes Book shall be recorded by the Company Secretary/ Chairman.
iii)Point no. 4.1.1 of Secretarial Standard-1, the pages of the respective attendance registers shall be serially numbered (which were not done).
iv)Point no. 4.1.2 of Secretarial Standard-1, the attendance register shall contain serial number of the Meeting (which was not done).
v)Point no. 9 of Secretarial Standard-1, the Report of the Board of Directors shall include a statement on compliance of applicable Secretarial Standards. However, the Company has not disclosed the same in the directors report for the financial year ended 31.03.2020.
More than 15 days have expired from issue of Show Cause Notice, no response has been received till date. The company and its officer-in default have also not requested for hearing. In the said circumstances, penalty as applicable as mentioned below is being imposed upon the company as well as its officer-in default as per Section 118 (11) 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 | SEN HON LEE TECHNOLOGIES PRIVATE LIMITED having CIN as U25209UP2019P TC117599 | 25000 | 0 | 25000 | |
| 2 | WU XIAOPING having DIN as
08602212 |
5000 | 0 | 5000 | |
| 3 | NAKUL KUMAR BHATI having DIN as 09473679 | 5000 | 0 | 5000 | |
| 4 | ZHIYONG ZHOU having DIN as
08415698 |
5000 | 0 | 5000 | |
| 5 | SACHIN BHARTIYA having DIN as 08415718 |
5000 | 0 | 5000 | |
| 6 | HUANG WEIFEI having DIN as 08517634 | 5000 | 0 | 5000 | |
| 7 | GAUTAM SINGH having DIN as 08575001 | 5000 | 0 | 5000 |
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 Noida 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.
Sanjay Bose,
Registrar of Companies
ROC Kanpur
