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Microlesson · 5-min read

Alteration of Articles of Association (Section 14)

## Alteration of AOA (Section 14)

### Fundamental Principle (Case: Andrews v. Gas Meter Co.)

A company CANNOT divest itself of the power to alter its articles. (Andrews v. Gas Meter Co. [1897] 1 CH 161)

### Matters Not Covered in MOA

If the MOA is silent on a matter, it can be dealt with by altering the AOA.

### Procedure for Alteration of AOA

1. The company may alter its AOA by passing a Special Resolution (SR), subject to the Act and the MOA.

2. Alteration includes Conversion of Company Type:

  • Private → Public, or
  • Public → Private.

3. CG Approval for Public → Private Conversion

  • Approval required within 60 days from passing the SR.
  • Filed using e-Form RD-1 with the RD along with fee.

Documents to attach:

  • Draft MOA & AOA with proposed changes.
  • Copy of GM minutes, SR details, votes, and dissenters' names.
  • Copy of BR / POA authorizing the application, dated within 30 days.
  • Declaration by KMP confirming compliance with relevant laws/rules.

### ROC Filing

  • Alteration + CG's approval (if applicable) + printed copy of altered AOA filed with ROC within 15 days.
  • Once registered, the alteration is valid as if originally included in the AOA.

### Noting Alteration in Every Copy (Sec 15)

Every copy of the AOA shall reflect alterations made. If not, the company and its officers are liable for a penalty of ₹1,000 per copy issued without noting the alteration.

### Quick Compare: Private↔Public Conversions

ConversionCG Approval?
Private → PublicNOT required (just SR + ROC filing)
Public → PrivateREQUIRED — RD's approval within 60 days

Worked example

### Example 1

Example 1: ABC Pvt. Ltd. wants to convert to a public company. Procedure? Answer: Pass SR altering AOA; file with ROC within 15 days. No CG approval needed.

### Example 2

Example 2: XYZ Ltd. (public) wants to convert into a private company. Procedure? Answer: Pass SR; file e-Form RD-1 with RD within 60 days; attach draft MOA/AOA, GM minutes, BR/POA (within 30 days), KMP declaration; after RD approval, file with ROC within 15 days with printed altered AOA.

⚠️ Common exam mistakes

  • Forgetting that Public → Private needs CG (RD) approval, but Private → Public does not.
  • Missing the 60-day window for filing RD-1, or the 15-day ROC filing window.
  • Forgetting that BR/POA must be dated within 30 days.
  • Forgetting penalty under Sec 15 for issuing AOA copies without noting alterations.
Reference: Section 14 — Companies Act, 2013
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