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Microlesson · 5-min read

Prospectus [Sec 2(70)]

# Prospectus — Section 2(70)

Prospectus means any document described or issued as a prospectus and includes:

  • a Red Herring Prospectus (RHP), or
  • a Shelf Prospectus, or
  • any notice, circular, advertisement or other document inviting offers from the public for the subscription or purchase of any securities of a body corporate.

## Two layers of the definition

1. Formal sense: A document expressly described / issued as a prospectus.

2. Functional sense: ANY notice, circular, advertisement, etc. — irrespective of label — if it invites the public to subscribe to or purchase securities.

This means the form doesn't matter; the function (public invitation) does.

## Key terms also picked up by the definition

  • Red Herring Prospectus — a prospectus filed before the price/quantum of securities is finalised.
  • Shelf Prospectus — a prospectus issued by certain companies allowing multiple issuances within a window without filing a fresh prospectus each time.

## Why this breadth matters

If a company circulates a glossy 'product brochure' that effectively invites the public to subscribe to its NCDs, that brochure is a prospectus under Sec 2(70) — and all the liability provisions of the Act (mis-statements, civil and criminal liability, etc.) apply.

## Quick distinguishers

  • Letter of offer to existing members (rights issue) — not a prospectus.
  • Private placement offer letter — governed separately under Sec 42; it is not a public invitation, so the brochure-style breadth of Sec 2(70) doesn't catch it.

Worked example

### Example 1

Example. A company publishes a full-page advertisement in newspapers inviting the public to subscribe to its debentures and giving the company's financials and terms of issue. The document is not titled 'Prospectus'. Is it a prospectus? Yes — under Sec 2(70), 'any notice, circular, advertisement... inviting offers from the public for the subscription or purchase of any securities' qualifies as a prospectus.

⚠️ Common exam mistakes

  • Restricting 'prospectus' to formally-titled documents. A newspaper advertisement, circular, or even a letter can be a prospectus if it invites the public.
  • Forgetting that RHP and Shelf Prospectus are expressly included.
  • Confusing prospectus with the private placement offer letter under Sec 42 — the latter is a private invitation and is governed separately.
Bare-Act text Section 2(70) · Companies Act, 2013 · click to expand
Prospectus means any document described or issued as a prospectus and includes a red herring prospectus or shelf prospectus or any notice, circular, advertisement or other document inviting offers from the public for the subscription or purchase of any securities of a body corporate.
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