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Microlesson · 5-min read

Prospectus Issued by Foreign Company [Sec 387 & 389]

# Prospectus of Foreign Company — Sections 387 to 389

## Important Distinction

Sections 387 to 391 apply to a company incorporated outside India that issues a prospectus or makes an offer to Indian investors — whether or not it has a place of business in India.

In contrast, Sections 380 to 386 apply only to foreign companies (companies that DO have a place of business in India).

## Section 387 — Dating of Prospectus and Particulars to be Contained

No person shall issue, circulate or distribute in India any prospectus offering for subscription securities of a company incorporated outside India (whether or not it has a place of business in India) unless the prospectus:

### Is Dated and Contains:

#Required Particular
1Instrument constituting/defining the constitution (charter, statutes, MOA/AOA) — and where copies can be inspected
2Date and country of incorporation
3Whether the company has established a place of business in India and, if so, the address of its principal office in India
4Statement of matters specified in Section 26 (general prospectus content)

### Restriction on Old Prospectuses

No prospectus shall be issued more than 2 years after the date on which the company is entitled to commence business.

## Application Forms for Securities

A foreign company shall not issue an application form for securities unless the form is accompanied by a prospectus complying with Sec 387.

### Exception

The restriction does not apply to issue of an application form to a person for entering into an underwriting agreement.

Worked example

### Example 1

Q. A Mauritius company, incorporated 5 years ago and entitled to commence business since incorporation, wishes to issue a fresh prospectus in India. Is this permissible?

A. No. Under Sec 387, no prospectus can be issued more than 2 years after the date on which the company became entitled to commence business.

### Example 2

Q. A Singapore company sends an application form for shares to an Indian merchant banker for entering into an underwriting agreement, without a prospectus. Valid?

A. Yes. This falls within the express exception — application forms issued for entering into an underwriting agreement do not require a prospectus.

⚠️ Common exam mistakes

  • Believing Sec 387 applies only to foreign companies under Sec 2(42) — it applies to ANY company incorporated outside India that solicits Indian investors.
  • Forgetting the 2-year freshness limit on prospectus issuance.
  • Missing the underwriting agreement exception to the application form rule.
  • Omitting the address of the principal Indian office (when one exists) from the prospectus particulars.
Bare-Act text Sections 387 to 389 · Companies Act, 2013 · click to expand
Section 387: No person shall issue, circulate or distribute in India any prospectus offering for subscription in securities of a company incorporated or to be incorporated outside India, whether the company has or has not established, or when formed will or will not establish, a place of business in India, unless the prospectus is dated and signed, and — (a) contains particulars with respect to the following matters, namely: — (i) the instrument constituting or defining the constitution of the company; (ii) the enactments or provisions by or under which the incorporation of the company was effected; (iii) address in India where the said instrument, enactments or provisions, or copies thereof, and if the same are not in the English language, a certified translation thereof in the English language can be inspected; (iv) the date on which and the country in which the company would be or was incorporated; and (v) whether the company has established a place of business in India and, if so, the address of its principal office in India; and (b) states the matters specified under section 26.
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