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Microlesson · 5-min read

Resolutions and Agreements to be Filed (Section 117)

# Resolutions and Agreements to be Filed with the Registrar

## Filing Requirement [Section 117(1)]

A copy of every resolution / agreement covered under Section 117(3), together with the explanatory statement under Section 102 (if any), shall be filed with the Registrar:

  • Within 30 days of passing/making thereof;
  • In Form MGT-14 (Rule 24, Companies (Management & Administration) Rules, 2014);
  • Along with the prescribed fee.

A copy of every resolution which alters the articles and every agreement referred to in sub-section (3) must be embodied in or annexed to every copy of the articles issued after the resolution/agreement.

### Special Carve-outs on the 30-day period

Company TypeFiling Period
Normal company30 days
Specified IFSC Public Company60 days
Specified IFSC Private Company60 days

## Resolutions / Agreements Covered [Section 117(3)]

1. Special Resolutions.

2. Resolutions agreed to by all members that would otherwise have required a special resolution.

3. Any Board resolution / agreement relating to appointment, re-appointment, renewal or variation of terms of a Managing Director.

4. Resolutions/agreements agreed to by any class of members, which otherwise needed a specified majority, and resolutions binding such class even if not agreed to by all.

5. Resolutions for voluntary winding-up under Section 59 of the Insolvency and Bankruptcy Code, 2016.

6. Resolutions passed under Section 179(3) (Board powers).

## Exemptions for Private Companies

Clause (g) of Section 117(3) [referring to Section 179(3) Board resolutions] does not apply to:

  • Private companies (provided no default in filing financial statements u/s 137 or annual return u/s 92).
  • Specified IFSC Public Companies.

## Loans / Guarantees in Ordinary Course of Business

Filing is not required for resolutions under Section 179(3)(f) (loans, guarantees, security) passed in ordinary course of business by:

  • (a) a banking company;
  • (b) NBFCs registered under Chapter IIIB of RBI Act, 1934 (as prescribed in consultation with RBI);
  • (c) Housing finance companies registered under National Housing Bank Act, 1987.

No person under Section 399 is entitled to inspect or obtain copies of such resolutions.

## Penalty for Contravention [Section 117(2)]

DefaulterInitial PenaltyContinuing FailureMaximum
Company₹10,000₹100/day after first day₹2,00,000
Every officer in default (including liquidator)₹10,000₹100/day after first day₹50,000

Worked example

### Example 1

Example — Special Resolution Filing

ABC Ltd. passes a special resolution to alter its articles on 5th April 2024.

Action required:

  • File Form MGT-14 with Registrar by 5th May 2024 (within 30 days).
  • A copy of the resolution must be embodied in or annexed to every copy of the articles issued after 5th April 2024.

Example — IFSC Private Company

XYZ Specified IFSC Private Ltd. passes a special resolution on 1st March 2024.

Filing deadline: 30th April 2024 (60 days, not 30 days).

Example — Penalty Computation

A company delays filing of a special resolution by 60 days beyond the 30-day deadline.

  • Initial penalty: ₹10,000
  • Continuing failure: 59 days × ₹100 = ₹5,900
  • Total: ₹15,900 (capped at ₹2,00,000)

⚠️ Common exam mistakes

  • Forgetting that the explanatory statement under Section 102 must also accompany the filing.
  • Treating Section 117(3)(g) [Section 179(3) resolutions] as applicable to private companies — it is exempt if no default exists in s.137 / s.92 filings.
  • Applying 30 days to IFSC companies — they have 60 days.
  • Confusing Section 102 (explanatory statement) with separate Section 117 filing — both go together to Registrar in MGT-14.
  • Believing that banking/NBFC/HFC resolutions for loans in ordinary course of business must be filed — they are exempt under proviso to Section 117(3).
Bare-Act text Section 117 · Companies Act, 2013 (read with Rule 24, Companies (Management and Administration) Rules, 2014) · click to expand
A copy of every resolution or any agreement, in respect of matters specified in sub-section (3) together with the explanatory statement under section 102, if any, annexed to the notice calling the meeting in which the resolution is proposed, shall be filed with the Registrar within thirty days of the passing or making thereof in such manner and with such fees as may be prescribed... If any company fails to file the resolution or the agreement under sub-section (1) before the expiry of the period specified therein, such company shall be liable to a penalty of ten thousand rupees and in case of continuing failure, with a further penalty of one hundred rupees for each day after the first during which such failure continues, subject to a maximum of two lakh rupees and every officer of the company who is in default including liquidator of the company, if any, shall be liable to a penalty of ten thousand rupees and in case of continuing failure, with a further penalty of one hundred rupees for each day after the first during which such failure continues, subject to a maximum of fifty thousand rupees.
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