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Microlesson · 5-min read

Alteration of Articles of Association – Section 14

# Alteration of Articles – Section 14

## The default rule

A company may alter its articles by passing a Special Resolution, subject to:

  • the provisions of the Companies Act, 2013, and
  • the conditions contained in its Memorandum.

This general power is wide enough to include alterations that convert a private company into a public company or vice versa.

## Conversion of Public ➜ Private: extra hurdle

A conversion of a public company into a private company is NOT valid unless approved by the Central Government (power delegated to the Regional Director).

StepRequirement
Apply to RDIn e-Form RD-1
Time-limit to applyWithin 60 days of passing the SR
FeesAs per Companies (Registration Offices and Fees) Rules, 2014

Documents to be filed with RD-1:

1. Draft of the altered MOA and AOA showing proposed alterations.

2. Minutes of the general meeting at which the SR was passed, with vote details and names of dissenters.

3. Board resolution / Power of Attorney (not earlier than 30 days) authorising the application.

4. Declaration by KMP confirming compliance with applicable sections and rules.

## Auto-conversion of a Private to a Public Company

If, after alteration, the articles of a private company no longer contain the three statutory restrictions of Section 2(68) (restriction on transfer of shares, cap of 200 members, prohibition on public invitation), the company automatically ceases to be a private company from the date of such alteration.

## Filing of the alteration – Section 14(2)

  • Every alteration plus the CG/RD's order (where applicable) must be filed with the Registrar in Form INC-27.
  • Time limit: 15 days from the alteration.
  • A printed copy of the altered articles must also be filed.
  • The ROC shall register the same.

## Effect after registration – Section 14(3)

Once filed and registered, the alteration is valid and operates as if it were originally contained in the Articles.

## Limitations on the Power to Alter Articles

Even a unanimous shareholders' meeting cannot ignore these limits:

1. The altered articles must not exceed the powers given by the MOA or conflict with the MOA.

2. They must not be inconsistent with the Companies Act, 2013 or any other statute.

3. The alteration must be bona fide for the benefit of the company as a whole.

4. The altered articles must not contain anything illegal or against public policy.

5. The articles cannot be altered to provide for expulsion of a member — this is settled law as well as a Department clarification.

## Section 15 – Alteration to be noted on every copy

Every alteration of MOA or AOA must be noted in every copy of the document issued thereafter. Default attracts a penalty of ₹1,000 per copy issued without the alteration, on the company and every officer in default.

Worked example

### Example 1

Public to Private conversion: XYZ Ltd (public) passes an SR on 1 April 2026 to become a private company. It must file e-Form RD-1 with the Regional Director by 31 May 2026 (within 60 days) along with the altered draft MOA/AOA, minutes, board authorisation and KMP declaration. After RD's order, it files Form INC-27 with the ROC within 15 days.

### Example 2

Private becomes public by default: A private company alters its articles to remove the 200-member cap. From the date of that alteration the company automatically ceases to be a private company — even if no fresh SR for 'conversion' is passed.

### Example 3

Limit on alteration – expulsion clause: Members of a private company resolve to insert an article empowering the board to expel any member who criticises management in public. Such an article is void — alteration cannot provide for expulsion of a member.

⚠️ Common exam mistakes

  • Forgetting that converting a public company to private needs RD approval — an SR alone is not enough.
  • Missing the 60-day window for filing Form RD-1 with the Regional Director.
  • Filing the alteration in the wrong form — it is INC-27, within 15 days.
  • Believing all alterations take effect immediately on passing the SR — they take effect only after REGISTRATION by the ROC.
  • Inserting an 'expulsion of member' clause — it is impermissible.
  • Treating 'bona fide for the company as a whole' as a mere ethical exhortation — courts have struck down alterations that benefit only a faction.
Bare-Act text Section 14 read with Section 15 · The Companies Act, 2013 · click to expand
Section 14(1): Subject to the provisions of this Act and the conditions contained in its memorandum, if any, a company may, by a special resolution, alter its articles including alterations having the effect of conversion of— (a) a private company into a public company; or (b) a public company into a private company: Provided that where a company being a private company alters its articles in such a manner that they no longer include the restrictions and limitations which are required to be included in the articles of a private company under this Act, such company shall, as from the date of such alteration, cease to be a private company: Provided further that any alteration having the effect of conversion of a public company into a private company shall not take effect except with the approval of the Central Government on an application made in such form and manner as may be prescribed. (2) Every alteration of the articles under this section and a copy of the order of the Central Government approving the alteration as per sub-section (1) shall be filed with the Registrar, together with a printed copy of the altered articles, within a period of fifteen days in such manner as may be prescribed, who shall register the same. (3) Any alteration of the articles registered under sub-section (2) shall, subject to the provisions of this Act, be valid as if it were originally in the articles.
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