ROC Delhi Imposes ₹32,000 Penalty for Breach of 120-Day Board Meeting Gap Requirement Under Section 173(1) of the Companies Act, 2013
Overview of the Adjudication
The Registrar of Companies, Delhi, exercising adjudicatory powers conferred under Section 454 of the Companies Act, 2013, issued a penalty order against CDPQ India Private Limited and its two officers in default for non-compliance with Section 173(1) of the Act. The violation pertained to the failure to hold a Board meeting within the mandated 120-day interval from the preceding meeting. The company had voluntarily approached the Registrar through a suo motu adjudication application, acknowledged the default, and confirmed that the lapse had since been corrected.
Adjudicating Authority and Jurisdiction
The Ministry of Corporate Affairs, through Gazette Notification No. S.O. 831(E) dated 24/03/2015, designated the Registrar of Companies, Delhi as the Adjudicating Officer under Section 454 of the Companies Act, 2013, read with the Companies (Adjudication of Penalties) Rules, 2014. This appointment empowers the Registrar to adjudge and impose penalties for contraventions of the provisions of the Act and rules framed thereunder.
The adjudication order bearing Order ID: PO/ADJ/04-2026/DL/02036, was passed on 21st April 2026 from the office located at 4th Floor, IFCI Tower, 61, Nehru Place, New Delhi – 110019.
Details of the Company and Officers Involved
| Particulars | Details |
|---|---|
| Company Name | CDPQ India Private Limited |
| CIN | U67190DL2016FTC290408 |
| Registered Office | 2nd Floor, Unit No. 204, Worldmark 3, IGI Airport, New Delhi – 110037 |
| Officer 1 | Elyse Bedwani (DIN: 09541205) |
| Officer 2 | Pallavi Bhargava (DIN: 10390931) |
CDPQ India Private Limited is a company incorporated and registered under the provisions of the Companies Act, 2013/1956 with the Registrar of Companies, Delhi.
Relevant Legal Provisions
Section 173(1) – Companies Act, 2013
Section 173(1) of the Companies Act, 2013 mandates that every company must hold a minimum of four Board meetings in every calendar year, with the condition that the interval between two consecutive Board meetings shall not exceed 120 days. This provision ensures regular oversight and governance by the Board of Directors.
Section 450 – Companies Act, 2013
The penalty framework invoked in the present matter is governed by Section 450 of the Companies Act, 2013, which provides as follows: