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Microlesson · 5-min read

Proxies (Section 105)

# Proxies [Section 105 read with Rule 19 of Management & Administration Rules, 2014]

A proxy is a person authorised by a member to attend and vote at a general meeting on his behalf. It is one of the most important rights of a member.

## Core Right

Any member entitled to attend and vote at a meeting may appoint another person as proxy.

## Three Big Limitations on a Proxy's Powers

A proxy:

1. Cannot speak at the meeting

2. Cannot vote on a show of hands — only on a poll

3. Cannot sign a requisition for an EGM

## When Section 105 (Proxy Right) Does NOT Apply

  • Companies not having share capital — sub-section (1) does not apply unless the articles permit.
  • Section 8 companies (charitable objects) — a member can appoint a proxy ONLY if the proxy is also a member of the same Section 8 company (Rule 19).
  • The Central Government may, by rules, prescribe other classes of companies whose members cannot appoint proxies.

## The 50/10% Rule (Rule 19)

A person can act as proxy for:

  • Not more than 50 members, AND
  • Members holding in aggregate not more than 10% of total share capital carrying voting rights.

Exception: A single member holding more than 10% may appoint one person as proxy, but that person then cannot act as proxy for anyone else.

## Form & Formalities of Proxy Instrument

RequirementProvision
Prescribed formForm MGT-11
In writing & signedBy appointer or his attorney duly authorised in writing
Body corporate appointerUnder common seal OR signed by officer/attorney duly authorised
Deposit deadlineMust reach company at least 48 hours before meeting; articles cannot demand a longer period
ComplianceIf in prescribed Form, validity cannot be questioned for non-compliance with articles' special requirements

## Notice Must Inform Members of Proxy Right

Every notice of a meeting (of a company with share capital, or whose articles allow proxy voting) must state with reasonable prominence that:

  • A member entitled to attend & vote can appoint a proxy;
  • A proxy need not be a member.

Penalty for default in this disclosure: Every officer in default → ₹5,000.

## Right to Inspect Proxies Lodged

Every member entitled to vote may inspect proxies lodged at the company:

  • Window: 24 hours before meeting starts → until meeting concludes
  • During: business hours of the company
  • Condition: Member must give at least 3 days' written notice of his intention to inspect.

## Penalty for Company-Funded Proxy Invitations

If invitations to appoint specified persons as proxy are issued at the company's expense, every officer responsible → ₹50,000 penalty.

Safe harbour: Officer is NOT liable if a form/list of willing proxies is issued only on a member's written request, and such forms/lists are available on request to every member entitled to vote by proxy.

Worked example

### Example 1

Q: Mr. A holds 12% of the share capital of XYZ Ltd. He appoints Mr. P as his proxy. Mr. B holds 0.5% and also wants to appoint Mr. P as his proxy. Is this permissible?

A: No. Since Mr. A holds more than 10% of total voting share capital, he can appoint a single proxy — but that proxy (Mr. P) cannot act as proxy for any other member. Mr. B must choose someone else.

### Example 2

Q: A general meeting is scheduled for 11:00 AM on 15 June. The articles of ABC Ltd require proxy forms to be lodged 72 hours in advance. Mr. X lodges a proxy at 4:00 PM on 13 June. Is the proxy valid?

A: Yes. Section 105(4) is overriding: a proxy received at least 48 hours before the meeting is valid, even if articles demand a longer period.

### Example 3

Q: Mr. R, a member of a Section 8 company, wants to appoint his son (who is not a member) as proxy. Can he?

A: No. Under Rule 19, a Section 8 company member can appoint as proxy only another member of the same company. The son, being a non-member, is disqualified.

### Example 4

Q: At ABC Ltd's AGM, a resolution is being voted on by show of hands. Mr. P attends as proxy for Mr. M (a member). Can Mr. P raise his hand and vote?

A: No. A proxy cannot vote on a show of hands — he can vote only when a poll is taken.

⚠️ Common exam mistakes

  • Thinking a proxy can speak at a meeting — proxies have no right to speak.
  • Thinking a proxy can vote on a show of hands — only on a poll.
  • Forgetting that the 48-hour rule under Section 105(4) overrides any longer period in the articles.
  • Applying the 50/10% cap rigidly to a member holding >10% — such a member may appoint one proxy (who can act only for him).
  • For Section 8 companies, allowing a non-member as proxy.
  • Allowing the company to issue proxy invitations at company expense to specific named persons (₹50,000 officer penalty unless safe harbour applies).
  • Forgetting the 3 days' written notice required before inspection of lodged proxies.
Bare-Act text Section 105 and Rule 19 · Companies Act, 2013 read with Rule 19 of Companies (Management & Administration) Rules, 2014 · click to expand
Section 105 (1) provides that any member of a company who is entitled to attend and vote at a meeting of the company shall be entitled to appoint another person as a proxy to attend and vote at the meeting on his behalf. A proxy shall not have the right to speak at such meeting and shall not be entitled to vote except on a poll. A person can act as proxy on behalf of members not exceeding fifty and holding in aggregate not more than 10 per cent of the total share capital of the company carrying voting rights.
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