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Microlesson · 5-min read

Section 391 — Application of Sections 34-36 and Chapter XX to Foreign Companies & IDRs

# Section 391 — Bridge Provision

## Purpose

Section 391 acts as a bridge that extends key Indian company-law provisions to foreign companies and IDR issuers, ensuring Indian investors get the same protections regardless of where the issuer is incorporated.

## Sub-section (1) — Misstatement Liability

Provisions of Sections 34 to 36 (both inclusive) shall apply to:

Sub-clauseApplication
(i)Issue of prospectus by a foreign company under Section 389 — same as Indian-company prospectus
(j)Issue of IDRs by a foreign company

### What are Sections 34–36?

  • Section 34: Criminal liability for mis-statements in prospectus
  • Section 35: Civil liability for mis-statements in prospectus
  • Section 36: Punishment for fraudulently inducing persons to invest money

## Sub-section (2) — Winding-up Application

Chapter XX (Winding-up) applies mutatis mutandis for closure of the place of business of a foreign company in India, as if it were an Indian company —

Trigger condition: Such foreign company has raised monies in India through offer/issue of securities under this Chapter (Chapter XXII), AND those monies have NOT been repaid or redeemed.

### Practical Implication

If a foreign company:

1. Raised money in India via prospectus/IDRs, AND

2. Has not yet repaid/redeemed those securities,

then shutting down its Indian place of business triggers Indian winding-up rules — protecting Indian creditors and investors.

## Visual Flow

```

Foreign Company

├── Issues prospectus in India → Sec 34/35/36 apply

├── Issues IDRs in India → Sec 34/35/36 apply

└── Closing Indian POB

└── If money raised + not repaid/redeemed → Chapter XX applies (mutatis mutandis)

```

Worked example

### Example 1

Example 1: A foreign company's prospectus issued in India contains a fraudulent statement about projected revenue. — Result: Investors can pursue both civil (Sec 35) and criminal (Sec 34) remedies as if it were an Indian company prospectus — Section 391(1)(i).

### Example 2

Example 2: Foreign Co. ABC raised ₹500 crore via IDRs in India in 2022. In 2026, it wants to shut its Indian liaison office. ₹200 crore of IDRs remain unredeemed. — Result: Chapter XX winding-up provisions apply mutatis mutandis under Section 391(2) — closure cannot be unilateral; Indian-style winding-up procedure must be followed.

### Example 3

Example 3: A foreign company closes its place of business in India after fully redeeming all IDRs and repaying all securities holders. — Result: Section 391(2) NOT triggered; standard closure norms apply.

⚠️ Common exam mistakes

  • Thinking Sec 34–36 are India-only protections — Section 391 extends them to foreign company prospectuses and IDRs.
  • Missing the conditional nature of Sec 391(2) — Chapter XX applies ONLY if money raised remains unrepaid/unredeemed.
  • Confusing 'mutatis mutandis' with 'verbatim' — necessary changes are made to fit the foreign-company context.
  • Forgetting that Section 391(1) covers BOTH prospectus under Sec 389 AND IDRs under Sec 390.
Bare-Act text Section 391 · Companies Act, 2013 · click to expand
Section 391(1): The provisions of sections 34 to 36 (both inclusive) shall apply to — (i) the issue of a prospectus by a company incorporated outside India under section 389 as they apply to prospectus issued by an Indian company. (j) the issue of Indian Depository Receipts by a foreign company. Section 391(2): The provisions of Chapter XX shall apply mutatis mutandis for closure of the place of business of a foreign company in India as if it were a company incorporated in India in case such foreign company has raised monies through offer or issue of securities under this Chapter which have not been repaid or redeemed.
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