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Microlesson · 5-min read

Private Company [Sec 2(68)]

# Private Company — Section 2(68)

A Private Company is one which:

1. has a minimum paid-up share capital as may be prescribed (currently NIL after 2015 amendment); AND

2. by its Articles of Association, satisfies all three restrictions below.

## The three Articles-based tests

RestrictionWhat it says
(i) Transfer of sharesArticles must restrict the right to transfer its shares (e.g., right of first refusal in favour of existing members).
(ii) Cap on membersLimit members to 200 (does NOT apply to an OPC).
(iii) No public invitationArticles must prohibit any invitation to the public to subscribe for any securities.

## Counting members for the 200 cap — important carve-outs

  • Joint holders of shares → counted as ONE member, not many.
  • Persons NOT counted in the 200 limit:
  • (a) Persons who are presently in the employment of the company.
  • (b) Ex-employees who became members during employment and continue to hold shares after leaving.

## Section 8 company exception

The requirement of prescribed minimum paid-up share capital is NOT applicable to a Section 8 company — provided it complies with Section 92 (annual return) and Section 137 (filing of financial statements).

## Visual: How to test if a company is private

```

Step 1: Does Articles restrict share transfer? → No → Not private

Step 2: Does Articles cap members at 200? → No → Not private

Step 3: Does Articles prohibit public invite? → No → Not private

Step 4: Min PUSC as prescribed (NIL today).

All Yes → Private Company

```

## Quick contrast with Public Company

A Public Company is simply one that is NOT a private company (and has prescribed min PUSC). So absence of any one of the three Articles restrictions makes a company public.

Worked example

### Example 1

Example 1 — Counting members. ABC Pvt Ltd has 195 outside members + 8 current employees who are members + 5 ex-employees (who became members during employment and still hold shares) + 7 joint holdings (Mr. X + Mrs. X each pair). Is the 200 cap breached? Joint holdings → count as 7 members (not 14). Outside members 195 + 7 joint = 202. Employees (8) and ex-employees (5) are excluded. So countable members = 202, which breaches the 200 limit. The company must convert to public or take corrective action.

### Example 2

Example 2 — OPC. An OPC has only 1 member. The 200-member cap does not apply to it (express exception in clause ii).

⚠️ Common exam mistakes

  • Forgetting that all THREE restrictions must be in the Articles — not just one. Many students recall only the 200-member cap.
  • Counting joint holders as multiple members. Joint holders = ONE member.
  • Including current employees and ex-employees (who became members during employment) in the 200 limit — they are excluded.
  • Thinking minimum PUSC for a private company is still ₹1 lakh — the requirement has been omitted; presently it is NIL.
  • Forgetting the Section 8 carve-out on PUSC requirement.
Bare-Act text Section 2(68) · Companies Act, 2013 · click to expand
Private Company means a company having a minimum paid-up share capital as may be prescribed, and which by its articles: (i) restricts the right to transfer its shares; (ii) except in case of OPC, limits the number of its members to 200: Provided that in case of joint holding — they shall be treated as a single member. Provided further, the following shall not be included in the number of members: (a) persons who are in the employment of the company; and (b) persons who, having been formerly in the employment of the company, were members of the company while in that employment and have continued to be members after the employment ceased. (iii) prohibits any invitation to the public to subscribe for any securities of the company. Exception: The requirement of prescribed minimum PUSC is not applicable to Section 8 companies (provided that Section 92 and Section 137 are complied with).
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