The Registrar of Companies, Jaipur, adjudicated penalties against Navjeet India Limited and its officers for violating Section 77 of the Companies Act, 2013. The company had taken a vehicle loan of ₹10,00,000 from HDFC Bank on 05.05.2018 but failed to file e-Form CHG-1 with the Registrar for creation of charge and did not file e-Form CHG-4 for its satisfaction, violating Sections 77 and 82 read with the Companies (Registration of Charges) Rules. Although a No Objection Certificate (NOC) was issued by the bank in August 2023, the company did not rectify the defaults, nor request an e-hearing. While the company cited its status as a startup/small company, the adjudicating officer considered this in mitigation but still imposed penalties. Each officer in default was penalized ₹25,000 (subject to a maximum of ₹50,000), with instructions to pay via e-Adjudication within 90 days and the right to appeal within 60 days.
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
ROC Jaipur
ROC-cum-Official Liquidator, Ministry Of Corporate Affairs, C/6-7, 1st Floor, Residency Area, Civil Lines, Jaipur, Rajasthan,
India, 302001
Phone: 0141-2981913/2981914/2981915
Fax: 0141-2981916
E-mail: roc.jaipur@mca.gov.in
Order ID: PO/ADJ/11-2025/JP/00961 Dated: 28/11/2025
ORDER FOR ADJUDICATION OF PENALTY UNDER SECTION 454 OF THE COMPANIES ACT, 2013 (‘THE ACT’) FOR VIOLATION OF SECTION 86 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 NAVJEET INDIA LIMITED [herein after known as Company] bearing CIN
U18101RJ2016PLC049370, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at 36, KAMLAWADI, GULAB BAGH ROAD NA UDAIPUR UDAIPUR RAJASTHAN INDIA 313001
Individual details:
In the matter relating to BHARAT KUMAR NIHALANI [herein after known as individual] ——–
In the matter relating to NAVEEN KUMAR NEBHNANI [herein after known as individual] ——–
In the matter relating to NIRANJAN KUMAR NEBHNANI [herein after known as individual] ——–
C. Provisions of the Act:
If any company is in default in complying with any of the provisions of this Chapter, the company shall be liable to a penalty of five lakh rupees and every officer of the company who is in default shall be liable to a penalty of fifty thousand rupees
D. Facts about the case:
1. Default committed by the officers in default/noticee – (I). This office has received a suo-moto adjudication application under section 454 of the Companies Act, 2013 in e-Form GNL-1 vide SRN AB6049824 dated 14.08.2025 for the offence committed under section 77 of the Companies Act, 2013 read with Rule 3 of the Companies (Registration of Charges) Rules, 2014 stating that the company had taken a vehicle loan amounting to Rs. 10,00,000/- from the HDFC Bank on 05.05.2018 and failed to file e-Form CHG-1 with the Registrar and violated section 77 of the Companies Act, 2013 read with Rule 3 of the Companies (Registration of Charges) Rules, 2014.
II. The company has also stated in its application that the company has also failed to file e-Form CHG-4 with the Registrar for the satisfaction of the above vehicle loan and violated the provisions of section 82 of the Companies Act, 2013 read with Rule 8 of the Companies (Registration of Charges) Rules, 2014.
III. The HDFC Bank has issued No Objection Certificate (NOC) dated 07.08.2023 for the full payment of the above vehicle loan amount.
2. The noticees have not sought an opportunity of e-hearing as requested/ mentioned in their replies to the e-SCN/Notice.
E. Order:
1. (I). This office has received a suo-moto adjudication application under section 454 of the Companies Act, 2013 in e-Form GNL-1 vide SRN AB6049824 dated 14.08.2025 for the offence committed under section 77 of the Companies Act, 2013 read with Rule 3 of the Companies (Registration of Charges) Rules, 2014 stating that the company had taken a vehicle loan amounting to Rs. 10,00,000/- from the HDFC Bank on 05.05.2018 and failed to file e-Form CHG-1 with the Registrar and violated section 77 of the Companies Act, 2013 read with Rule 3 of the Companies (Registration of Charges) Rules, 2014.
II. The company has also stated in its application that the company has also failed to file e-Form CHG-4 with the Registrar for the satisfaction of the above vehicle loan and violated the provisions of section 82 of the Companies Act, 2013 read with Rule 8 of the Companies (Registration of Charges) Rules, 2014.
III. The HDFC Bank has issued No Objection Certificate (NOC) dated 07.08.2023 for the full payment of the above vehicle loan amount.
IV. The company in its reply has stated that it is a Startup Company and gets covered under the purview of Small
Company at time of non-compliance. The facts made by the company has been examined and are taken into consideration while levying the penalties in accordance with section 446B of the Companies Act, 2013.
V. The matter has been examined and observed that the company has failed to file e-Form CHG-1 with the Registrar for the creation of charge in respect of loan provided by the HDFC Bank amounting to Rs. 10,00,000/- and violated section 77 of the Companies Act, 2013 read with Rule 3 of the Companies (Registration of Charges) Rules, 2014 subject to the penalty in accordance with section 446B of the Companies Act, 2013. The matter has also been examined with regard to company’s submission of violation of section 82 of the Companies Act, 2013 and observed that as there was no creation of charge, hence, the question of satisfaction of the same was not considered. Hence, through this Adjudication Order, the violation of section 77 of the Companies Act, 2013 read with Rule 3 of the Companies (Registration of Charges) Rules, 2014 has been adjudicated.
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 | BHARAT KUMAR NIHALANI having DIN as 07258249 |
25000 | 0 | 50000 | |
| 2 | NAVEEN KUMAR NEBHNANI having DIN as 07337100 | 25000 | 0 | 50000 | |
| 3 | NIRANJAN KUMAR NEBHNANI having DIN as 07424006 |
25000 | 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 Ahmedabad 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.
Atma Sah,
Registrar of Companies
ROC Jaipur
