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Microlesson · 5-min read

Section 388 — Expert's Consent in Foreign Company Prospectus

# Section 388 — Expert's Consent & Allotment Provisions

## Why this matters

When a foreign company offers securities in India and its prospectus relies on an expert's statement (e.g., valuer, accountant, engineer), the investor needs assurance that the expert truly stands behind that statement. Section 388 codifies this safeguard.

## The Rule — Section 388(1)

No person shall issue, circulate or distribute in India any prospectus offering subscription in securities of a company incorporated (or to be incorporated) outside India — whether or not it has/will have a place of business in India — if:

### (a) Expert's Consent Defect — any of these:

  • Where the prospectus includes a statement purporting to be made by an expert, AND
  • The expert has NOT given written consent, OR
  • The expert has withdrawn written consent before delivery of the prospectus for registration, OR
  • The prospectus does not contain a statement that the expert has given and not withdrawn consent.

### (b) Allotment Provisions Not Effective

If the prospectus does not have the effect of rendering all persons concerned bound by all provisions of Sections 33 and 40 (issue of application forms & allotment), so far as applicable.

## Section 388(2) — Deemed Inclusion

A statement is deemed to be included in a prospectus if it is:

  • Contained in any report or memorandum appearing on the face of the prospectus, OR
  • Incorporated by reference therein, OR
  • Issued therewith.

Practical effect: Companies cannot escape liability by burying expert statements in annexures or supplementary documents.

## Visual Map

```

Foreign Co. Prospectus in India

├── Contains Expert Statement?

│ ├── YES → Need: (i) Written consent (ii) Not withdrawn (iii) Disclosure of consent

│ └── NO → Section 388(a) not triggered

└── Must trigger binding effect of Sec 33 & Sec 40

```

Worked example

### Example 1

Example 1: A UK-incorporated company's prospectus issued in India cites a valuation by a Big-4 audit firm but does not state whether consent was obtained. — Result: Section 388(1)(a) is violated; prospectus cannot be issued.

### Example 2

Example 2: A foreign company obtains an expert's consent in May, but the expert withdraws consent in June before registration. The company files the prospectus in July claiming the May consent. — Result: Violation — consent must subsist until delivery for registration.

### Example 3

Example 3: A foreign company attaches an expert's report as an annexure (issued along with prospectus) instead of including it on the face. The company claims Section 388 doesn't apply. — Result: Section 388(2) deems it included — same disclosure rules apply.

⚠️ Common exam mistakes

  • Thinking oral consent of an expert is sufficient — written consent is mandatory.
  • Forgetting that consent must NOT have been withdrawn before delivery for registration.
  • Missing the statement requirement: the prospectus must AFFIRMATIVELY state that the expert has given and not withdrawn consent.
  • Believing that incorporating expert reports by reference avoids Section 388 — Section 388(2) explicitly covers this.
  • Confusing 'expert' under Section 388 with all professional advisors — only those whose statements are purportedly made are 'experts' for this provision.
Bare-Act text Section 388 · Companies Act, 2013 · click to expand
Section 388(1): No person shall issue, circulate or distribute in India any prospectus offering for subscription in securities of a company incorporated or to be incorporated outside India... (a) if, where the prospectus includes a statement purporting to be made by an expert, he has not given his written consent, or has withdrawn his written consent before delivery of the prospectus for registration... or there does not appear in the prospectus a statement that he has given and has not withdrawn his consent as aforesaid; or (b) if the prospectus does not have the effect... of rendering all persons concerned bound by all the provisions of sections 33 and 40, so far as applicable. Section 388(2): For the purposes of this section, a statement shall be deemed to be included in a prospectus, if it is contained in any report or memorandum appearing on the face thereof or by reference incorporated therein or issued therewith.
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