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Microlesson · 5-min read

Comparison: Public Offer vs. Private Placement

# Public Offer vs. Private Placement — Quick Comparison

A frequent exam question compares the timelines, refund obligations, and penalties under a public offer (Sections 23–40) with those under a private placement (Section 42). The differences are deliberate — a public offer carries broader investor protection thresholds.

## Side-by-Side Comparison

ParameterPublic OfferPrivate Placement
Offered toPublic at largeMaximum 200 identified persons in a FY (per security class)
Allotment within30 days from issue of prospectus60 days from receipt of application money
Refund within (if allotment fails)15 days15 days (from expiry of 60 days)
Interest on delayed refund15% p.a.12% p.a.
Return of Allotment (with ROC)Within 30 days of allotmentWithin 15 days of allotment (Form PAS-3)
Use of moneyAfter listing approvalOnly after allotment and filing return of allotment
Public advertisementPermittedProhibited
Mode of subscriptionCheque/DD/banking channelCheque/DD/banking channel (cash not allowed)

## Memory Aid

  • Public = 30 / 15 / 15% (faster process, broader audience, higher interest penalty).
  • Private = 60 / 15 / 12% (more time to allot, narrower audience, lower interest).

## Why the Differences Exist

  • A public offer addresses retail investors needing quick protection — hence shorter allotment and higher interest.
  • Private placement involves sophisticated/identified investors — longer allotment is workable, but tighter restrictions on use of funds and on advertisement protect the private character of the offer.

Worked example

### Example 1

Q. A company issued a prospectus and received application money on 1st April 2026. It failed to allot. By what date must the refund be made, and what interest rate applies if refund is delayed?

A. Allotment was due within 30 days (by 1st May 2026). Refund must be made within 15 days thereafter (by 16th May 2026). If delayed beyond that, interest @ 15% p.a. is payable from the expiry of the 30-day allotment period.

### Example 2

Q. Compare the timelines if the same fact pattern arose under a private placement.

A. Allotment within 60 days (by 31st May 2026); refund within 15 days thereafter (by 15th June 2026); interest @ 12% p.a. from expiry of 60 days if refund delayed. Return of allotment to be filed in Form PAS-3 within 15 days of allotment.

⚠️ Common exam mistakes

  • Swapping the interest rates — public offer is 15%, private placement is 12%.
  • Believing return of allotment timeline is the same for both — it is 30 days for public offer but 15 days for private placement.
  • Forgetting that private placement allotment is calculated from receipt of application money, while public offer allotment is from issue of prospectus.
Reference:
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