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Microlesson · 5-min read

Applicability of Voting Under Postal Ballot (Section 110)

# Voting by Postal Ballot — Applicability

## 1. What is a Postal Ballot?

Under Sec 2(65), postal ballot means voting by post or through electronic mode. Members vote remotely without assembling.

## 2. Which Items Can/Must be Transacted by Postal Ballot?

CategoryTreatment
Items notified by the Central GovernmentMust be transacted only by postal ballot
Other business itemsMay be by postal ballot, except: ordinary business OR items requiring hearing of director/auditor

Rider: Items mandated under (a) may also be transacted at a general meeting if e-voting (Sec 108) facility is available.

## 3. Legal Effect

A resolution approved by requisite majority via postal ballot is deemed passed at a general meeting.

## 4. Exemptions

  • One Person Company (OPC)
  • Companies with up to 200 members

## 5. Items Mandated for Postal Ballot

Sr.Business ItemSection
1Alteration of objects clause of MOASec 13
2Alteration of AOASec 2(68)
3Change in registered office beyond local limitsSec 12(5)
4Change in objects for which funds raisedSec 13(8)
5Issue of shares with differential voting/dividend rightsSec 43(a)(ii)
6Variation in rights of shares/debenturesSec 48
7Buy-back of sharesSec 68(1)
8Election of small shareholders' directorSec 151
9Sale of whole/substantial undertakingSec 180(1)(a)
10Loans/guarantees/securities beyond prescribed limitsSec 186(3)

## 6. Voting Rights & Ballot Types

  • Voting rights proportional to paid-up share capital holding.
  • Types: Assent | Dissent | Partial | Invalid (signature issues, overwriting).

## 7. When is the Resolution Passed?

If assents exceed dissents (subject to the majority required — ordinary or special).

Worked example

### Example 1

Example 1 — Small company: ABC Pvt Ltd (150 members) wants to alter its objects clause. Answer: Although Sec 13 alteration is a mandated postal-ballot item, ABC Pvt Ltd has ≤ 200 members and is exempt from postal ballot. Can use a general meeting.

### Example 2

Example 2 — Buy-back: LMN Ltd (listed) plans buy-back u/s 68. Answer: Mandatory postal ballot, OR a general meeting if e-voting (Sec 108) is offered.

### Example 3

Example 3 — Ordinary business: A company seeks to adopt financial statements via postal ballot. Answer: Ordinary business cannot be transacted by postal ballot.

⚠️ Common exam mistakes

  • Treating postal ballot as available for ordinary business — it is excluded.
  • Forgetting OPCs and ≤ 200-member companies are exempt entirely.
  • Confusing 'differential voting rights' under Sec 43(a)(ii).
  • Stating postal ballot is only by post — Sec 2(65) includes electronic mode.
  • Missing that mandated items may also be done at a general meeting with e-voting.
Bare-Act text Section 110 read with Sec 2(65) and Rule 22 · Companies Act, 2013 · click to expand
Section 110: (1) Notwithstanding anything contained in this Act, a company (a) shall, in respect of such items of business as the Central Government may, by notification, declare to be transacted only by means of postal ballot; and (b) may, in respect of any item of business, other than ordinary business and any business in respect of which directors or auditors have a right to be heard at any meeting, transact by means of postal ballot... (2) If a resolution is assented to by the requisite majority of the shareholders by means of postal ballot, it shall be deemed to have been duly passed at a general meeting convened in that behalf.
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