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Microlesson · 5-min read

Effect of Memorandum and Articles – Section 10

# Section 10 – Binding Force of MOA and AOA

## The statutory contract

Once registered, the MOA and AOA bind the company and its members as if each member had personally signed them and agreed to observe every clause.

This creates what is known as the 'statutory contract' — a unique relationship that is part contract, part constitutional document.

## The four-way binding analysis

RelationshipBound by MOA/AOA?
(a) Company → MembersYES — company is bound to its members
(b) Members → CompanyYES — members are bound to the company
(c) Members → MembersNORMALLY NO — but YES when acting through the company (and per the Rayfield exception)
(d) Company / Members → OutsidersNO — MOA/AOA do not bind the company to outsiders

## Members' monetary obligations

All monies payable by a member to the company under the MOA or AOA are a debt due from the member to the company — recoverable as such (e.g., unpaid calls on shares).

## The three illustrative cases

### (a) Member ↔ Company → Borland's Trustee v Steel Bros & Co Ltd

The AOA said that on a member's bankruptcy his shares would be sold at a price fixed by the directors. Borland's trustee in bankruptcy argued he was not bound and could sell at true value. Held: the AOA contract is an original incident of the shares; having bought on those terms, the trustee must observe them.

### (b) Company ↔ Member → Wood v Odessa Waterworks Co

The AOA said directors could 'declare a dividend to be paid to members'. The company proposed to issue debenture bonds in lieu of cash. A member sought to restrain this. Held: 'paid' prima facie means paid in cash; the AOA bound the company to pay cash dividend, and debentures were not 'payment in cash'.

### (c) Member ↔ Member → Rayfield v Hands

Clause 11 of the AOA required a member intending to transfer his shares to inform the directors, who 'will take the said shares equally between them at a fair value'. The directors, who were also members, refused, arguing the article could not bind them in their capacity as directors. Held: treating them as members, the directors were compelled to buy Rayfield's shares at fair value — a rare instance where the AOA was held to bind members inter se.

> Take-away: members generally are not bound to each other by the AOA, except where the clause clearly contemplates a member-to-member obligation.

Worked example

### Example 1

Calls on shares as a debt: XYZ Ltd's AOA permits the board to call up unpaid amounts on shares. A member who refuses to pay can be sued by the company for recovery of the call money — it is a 'debt due' under Section 10.

### Example 2

Outsider cannot sue on AOA: A supplier finds a clause in the AOA permitting commission on sales. The supplier cannot enforce this against the company because the MOA/AOA do not bind the company to outsiders. (Note: he may, however, have a separate contractual right outside the AOA.)

⚠️ Common exam mistakes

  • Believing the MOA/AOA bind outsiders — they do not; that is the Eley v Positive Government Security Life Assurance Co principle.
  • Forgetting that members are NORMALLY not bound inter se by the AOA — Rayfield is a narrow exception.
  • Treating unpaid calls as an ordinary contractual claim — they are a 'debt due' under Section 10, with statutory recovery support.
  • Quoting Wood v Odessa as a case about dividends only — its real point is that the AOA binds the COMPANY to the MEMBER.
Bare-Act text Section 10 · The Companies Act, 2013 · click to expand
Section 10(1): Subject to the provisions of this Act, the memorandum and articles shall, when registered, bind the company and the members thereof to the same extent as if they respectively had been signed by the company and by each member, and contained covenants on its and his part to observe all the provisions of the memorandum and of the articles. (2) All monies payable by any member to the company under the memorandum or articles shall be a debt due from him to the company.
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