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Microlesson · 5-min read

Voting through Electronic Means (E-voting) - Procedure under Rule 20

# Voting through Electronic Means (E-voting)

## Overview

E-voting allows members of a company to cast their votes electronically on resolutions, both before the meeting (remote e-voting) and during the meeting itself. This is governed by Section 108 of the Companies Act, 2013 read with Rule 20 of the Companies (Management and Administration) Rules, 2014.

## Key Concepts You Must Know

### 1. What the Notice Must Contain

The notice of the meeting where e-voting is offered must:

  • Indicate the process and manner for voting by electronic means
  • Specify the time schedule (period during which votes may be cast via remote e-voting)
  • Provide login ID details
  • Specify the process for generating/receiving the password and casting votes securely

### 2. Public Notice (Advertisement) Requirements

After dispatch of notices, the company must publish a public advertisement:

RequirementDetails
WhenImmediately after dispatch but at least 21 days before the general meeting
Where(a) Once in a vernacular newspaper (principal vernacular language of district where registered office is situated, with wide circulation); AND (b) Once in an English newspaper with country-wide circulation

Mandatory contents of advertisement:

  • Statement that business may be transacted through e-voting
  • Date and time of commencement of remote e-voting
  • Date and time of end of remote e-voting
  • Cut-off date
  • Manner in which new members (who acquired shares after notice dispatch) may obtain login ID/password
  • Statement that:
  • Remote e-voting shall NOT be allowed beyond stated date and time
  • Manner for voting at meeting
  • A member may attend the meeting after remote e-voting but cannot vote again
  • Only persons on register of members/beneficial owners as on cut-off date can avail e-voting
  • Website address of company and agency
  • Contact details of grievance officer

The public notice must also be placed on the website of the company (if any) and of the agency.

### 3. E-Voting Window

  • Minimum duration: Not less than 3 days
  • Closes at: 5:00 p.m. on the date preceding the date of the general meeting

### 4. The 'No Change, No Re-vote' Rule

  • Once a vote is cast via remote e-voting, it cannot be changed
  • A member may attend the general meeting after voting electronically, but cannot vote again

### 5. Blocking the Facility

At the end of the remote e-voting period, the facility must be blocked forthwith.

Exception: If the company opts to use the same electronic voting system during the general meeting, the facility may remain operational, but only for members attending who have NOT yet voted via remote e-voting.

### 6. Appointment of Scrutinizer

The Board of Directors appoints one or more scrutinizers who must be:

  • Chartered Accountant in practice, OR
  • Cost Accountant in practice, OR
  • Company Secretary in practice, OR
  • Advocate, OR
  • Any other person of repute not in employment of the company

The scrutinizer may take assistance of a person (not employed by company) well-versed with the electronic voting system.

### 7. Role of Chairman at the Meeting

The Chairman, at the end of discussion on resolutions, allows voting (with scrutinizer's assistance) by ballot/polling paper or electronic voting system for those members present at the meeting who have NOT voted via remote e-voting.

### 8. Counting of Votes — Sequence Matters!

The scrutinizer must:

1. First, count votes cast AT the meeting

2. Then, unblock votes cast via remote e-voting (in presence of at least 2 witnesses not employed by company)

3. Prepare consolidated report within 3 days of conclusion of meeting

4. Submit report to Chairman (or his authorised person) who countersigns

5. Chairman declares result forthwith

> Secrecy Rule (Explanation): The manner in which members have voted (for/against) remains SECRET and is NOT available to Chairman, Scrutinizer or any other person until votes are cast at the meeting.

### 9. Scrutinizer's Access and Register

  • Scrutinizer has access to member details (names, folios, number of shares) of those who voted electronically — but NOT the manner of voting
  • Maintains a register (manual or electronic) recording assent/dissent with: name, address, folio/client ID, number of shares, nominal value, whether differential voting rights
  • Register kept in safe custody until Chairman signs the minutes, then handed over to company

### 10. Results: Publication and Effective Date

  • Results + scrutinizer's report → placed on company's website and agency's website immediately after declaration
  • Listed companies: Simultaneously forward results to the stock exchange(s), which must place results on their website
  • Date of passing: Resolution deemed passed on the date of the relevant general meeting (subject to requisite votes)
  • The 'requisite number' = votes required for ordinary/special resolution under Section 114

### 11. Resolution Cannot Be Withdrawn

A resolution proposed for voting by electronic means cannot be withdrawn.

## Quick Memory Aid: The E-Voting Timeline

```

Notice Dispatched → Advertisement (≥21 days before meeting)

→ Remote e-voting opens (≥3 days)

→ Remote e-voting closes (5 PM, day before meeting)

→ General Meeting + voting by non-e-voters

→ Scrutinizer counts (meeting votes first, then e-votes)

→ Report to Chairman (within 3 days)

→ Result declared & published

```

Worked example

### Example 1

Example 1: Timing of Public Notice

ABC Ltd. dispatched notice of its AGM on 1st June. The AGM is scheduled for 25th June. Has the company complied with the advertisement requirement if the advertisement was published on 8th June?

Answer: The advertisement must be published at least 21 days before the general meeting. AGM is on 25th June; 21 days before = 4th June. Publication on 8th June is only 17 days before — NON-COMPLIANT. The advertisement should have been published on or before 4th June.

### Example 2

Example 2: Re-voting at Meeting

Mr. X, a member of XYZ Ltd., cast his vote in favour of a special resolution through remote e-voting on 10th August. He attended the AGM on 15th August and wishes to change his vote to 'against'. Can he do so?

Answer: No. Under Rule 20, once a vote is cast through remote e-voting, the member shall not be allowed to change it subsequently or cast the vote again. He may attend and participate in the meeting but cannot vote again.

### Example 3

Example 3: Scrutinizer Eligibility

The Board of PQR Ltd. proposes to appoint Mr. A (an employee of the finance department, also a qualified CA) as scrutinizer for e-voting. Is this valid?

Answer: No. The scrutinizer must be a person NOT in employment of the company. Although Mr. A is a qualified CA, his employment with the company disqualifies him. The Board should appoint an independent CA/CS/CMA in practice or an advocate.

⚠️ Common exam mistakes

  • Confusing the 21-day rule for advertisement (before meeting) with the 30-day rule for postal ballot (from dispatch of notice).
  • Forgetting that the scrutinizer counts votes cast AT the meeting FIRST, and only then unblocks the remote e-votes — not the other way around.
  • Assuming the Chairman can see how members voted before the meeting concludes; in fact, the manner of voting remains SECRET until votes are cast at the meeting.
  • Stating that remote e-voting must be open for at least 7 days — the actual minimum is 3 days, closing at 5 PM on the day before the meeting.
  • Believing a member who votes electronically cannot attend the meeting — they CAN attend but cannot vote again.
  • Forgetting that the scrutinizer's report must be submitted within 3 days of conclusion of the meeting (not 7 days).
  • Missing that the resolution cannot be withdrawn once proposed for electronic voting.
Bare-Act text Section 108 read with Rule 20 · Companies Act, 2013 · click to expand
Section 108: The Central Government may prescribe the class or classes of companies and manner in which a member may exercise his right to vote by the electronic means. (Read with Rule 20 of Companies (Management and Administration) Rules, 2014.)
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