ROC Cuttack Imposes Penalty on Satguru Metals Limited for Delayed PAS-6 Filing Under Section 450 of Companies Act, 2013
Background and Overview
The Registrar of Companies, Cuttack, exercising adjudicatory powers under Section 454 of the Companies Act, 2013, issued a formal penalty order dated 1st July 2026 against Satguru Metals Limited and its directors. The violation pertained to non-compliance with sub-rule 8 of Rule 9A of the Companies (Prospectus and Allotment of Securities) Rules, 2014, which mandates timely submission of the Reconciliation of Share Capital Audit Report in e-Form PAS-6. The penalty was invoked under Section 450 of the Companies Act, 2013, which governs contraventions for which no specific punishment is prescribed elsewhere in the Act.
This adjudication order carries significant implications for unlisted public companies that issue shares in dematerialised form and are obligated to file PAS-6 on a half-yearly basis. The case underlines that belated rectification of a default does not extinguish the liability for the period during which the non-compliance persisted.
Details of the Company and Officers Involved
The adjudication proceedings were initiated against the following parties:
Company: Satguru Metals Limited
- CIN: U27102OR2007PLC009524
- Registered Office: Opp. Crazy Cool, Main Road Daily Market, Rourkela, Orissa – 769001
Officers in Default:
- Kripal Singh Dang (DIN: 01623170)
- Inderpal Singh Chhabra (DIN: 03147440)
- Ujjwal Singh (DIN: 08968179)
The adjudication was conducted by the ROC-cum-Official Liquidator, Ministry of Corporate Affairs, Corporate Bhawan, Plot No. 9(P), Sector-1, CDA, Cuttack, Orissa – 753014, vide Order ID: PO/ADJ/06-2026/CT/02399.
Appointment of Adjudicating Officer
Pursuant to a Gazette Notification bearing number S.O. 698(E) dated 10th February 2026, the Ministry of Corporate Affairs formally designated the undersigned officer as the Adjudicating Officer under Section 454 of the Companies Act, 2013, read with the Companies (Adjudication of Penalties) Rules, 2014. The adjudicating officer was vested with the authority to assess and impose monetary penalties for contraventions of the Act and its subordinate rules.
Statutory Framework: Relevant Legal Provisions
Section 450 – Companies Act, 2013
Section 450 of the Companies Act, 2013 provides a residuary penal provision applicable when a company, its officer, or any other person contravenes any provision of the Act or the rules framed thereunder, and no specific penalty or punishment has been prescribed for such contravention elsewhere in the legislation.
The penalty structure under Section 450 is as follows:
- Initial penalty: ₹10,000 for the contravening company or officer
- Continuing default: An additional penalty of ₹1,000 per day for every day the contravention continues after the first day
- Maximum cap:
- ₹2,00,000 in the case of a company
- ₹50,000 in the case of an officer in default or any other person