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Microlesson · 5-min read

Equity Shares with Differential Rights (Rule 4)

# Equity Shares with Differential Rights (DVR Shares)

## Concept

A company limited by shares may issue equity shares with differential rights (DVRs) — i.e., shares that carry rights different from ordinary equity shares as to dividend, voting, or otherwise. These are governed by Rule 4 of the Companies (Share Capital and Debentures) Rules, 2014.

## Conditions for Issue

The issuing company must satisfy all the following conditions:

### A. Authorisation & Approval

1. Articles of Association must authorise issue of DVR shares.

2. Shareholders' approval via ordinary resolution at a general meeting.

  • For a listed public company, the resolution must be passed through postal ballot.

### B. Quantitative Cap

3. Voting power of DVR shares shall not exceed 74% of total voting power at any point of time.

### C. No-Default Conditions

4. Company has not defaulted in filing annual accounts and annual returns for the 3 financial years preceding the year of decision to issue.

5. Company has not defaulted in payment of:

  • Declared dividend
  • Interest or coupon
  • Redemption of preference shares or debentures
  • Repayment of matured deposits

6. No default in:

  • Payment of dividend on preference shares
  • Payment of interest / repayment of any term loan from PFI, SFI, or Scheduled Bank
  • Statutory dues relating to employees
  • Crediting amount in Investor Education and Protection Fund (IEPF)

> Cooling Period: Despite a default, DVR shares may be issued upon expiry of 5 years from the end of the financial year in which the default was made good.

### D. No Penal Record

7. Company has not been penalised by a Court or Tribunal during the last 3 years under:

  • RBI Act, 1934
  • SEBI Act, 1992
  • Securities Contracts Regulation Act, 1956
  • FEMA, 1999
  • Any other special Act regulating it

## Additional Procedural Requirements

RequirementDescription
Explanatory statementNotice of GM/postal ballot must contain particulars: size of issue, details of differential rights, etc.
Prohibition on conversionExisting equity shares with voting rights cannot be converted into DVR shares, and vice versa.
Board's Report disclosureBoard must disclose specified particulars in the report for the FY in which the issue was completed.
Other rightsDVR shareholders enjoy all other rights (bonus shares, rights shares, etc.) like ordinary equity holders, subject to their differential rights.
Register of MembersMust contain all relevant particulars of DVR shares and details of holders (Section 88).

## Historical Note

  • DVR shares issued under the Companies Act, 1956 continue to be regulated under those provisions.
  • Before the 2000 amendment to the Companies Act, 1956, differential voting rights shares were not permitted (though such rights existed prior to the 1956 Act).

Worked example

### Example 1

Example 1: ABC Ltd., a listed public company, wishes to issue DVR shares. Its AOA permits the issue, but it has defaulted in paying a declared dividend last year. Can it issue DVR shares immediately?

Answer: No. Since ABC has defaulted in payment of declared dividend (a Category 'e' default), it must wait 5 years from the end of the financial year in which the default is rectified before issuing DVR shares.

### Example 2

Example 2: XYZ Pvt. Ltd. proposes to issue DVR shares which will give 80% of voting rights to a single class of shareholders. Is this permissible?

Answer: No. Rule 4 caps voting power of DVR shares at 74% of total voting power at any point of time. An 80% allocation breaches the rule.

### Example 3

Example 3: PQR Ltd. was penalised by SEBI 2 years back under the SEBI Act, 1992. Can it issue DVR shares?

Answer: No. A penalty by Court/Tribunal under SEBI Act within the last 3 years disqualifies the company from issuing DVR shares.

⚠️ Common exam mistakes

  • Confusing the voting power cap as 76% — the correct limit is 74% of total voting power.
  • Forgetting that a listed public company must use a postal ballot, not just a general meeting resolution.
  • Assuming DVR shares need a special resolution — only an ordinary resolution is required (with postal ballot for listed cos.).
  • Overlooking the 3-year filing default check on annual accounts and annual returns.
  • Forgetting that conversion of existing voting equity into DVR shares (or vice versa) is prohibited.
  • Missing that the 5-year cooling-off period runs from the end of the FY in which the default was 'made good' — not from the default date itself.
Bare-Act text Rule 4 of Companies (Share Capital and Debentures) Rules, 2014 · Companies Act, 2013 · click to expand
A company limited by shares may issue equity shares with differential rights as to dividend, voting or otherwise upon compliance with the conditions specified in Rule 4 — including AOA authorisation, ordinary resolution (postal ballot for listed cos.), 74% voting cap, no defaults in filings/payments/statutory dues, and no penalty under specified sectoral Acts in last 3 years.
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