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Microlesson · 5-min read

Postal Ballot — Businesses Mandatorily Transacted, Notice & Advertisement

# Postal Ballot — Mandatory Businesses, Notice & Advertisement

## What is a Postal Ballot?

A postal ballot lets shareholders vote on a resolution without physically attending a meeting. The company circulates the resolution, members send back their assent/dissent, and if the required majority is reached, the resolution is deemed passed at a general meeting.

## Businesses that MUST be transacted ONLY by postal ballot

The Act lists certain matters where the only permissible route (apart from e-voting alternative under Sec. 108) is a postal ballot:

CategoryItems
Constitutional changesAlteration of objects clause of MOA; Alteration of AOA to insert/remove private-company clauses
Office & Money usageChange of registered office outside city, town or village; Change in objects for which money was raised from public through prospectus (with unutilised amount)
Capital actionsIssue of shares with differential rights; Variation in rights of security; Buy-back
Governance/major transactionsElection of small shareholder director; Sale of whole undertaking; Loans/guarantee/security beyond limits

### Exemptions

  • Companies with ≤ 200 members — NOT required to use postal ballot.
  • One Person Company (OPC) — NOT required to use postal ballot.

## Notice of Postal Ballot

  • Sent to shareholders by registered post / speed post / courier / electronic means.
  • Members must send assent or dissent within 30 days of dispatch of notice.
  • Notice must also be placed on the company's website and remain there till the last date of receipt of postal ballots.

## Advertisement of Postal Ballot

Published in 1 English + 1 vernacular newspaper (with wide circulation where registered office is situated). It must specify:

1. Statement that business is to be transacted by postal ballot.

2. Date of completion of dispatch of notice + commencement & end of voting.

3. Statement that postal ballots received beyond the date are invalid.

4. Statement that members who didn't receive ballot may obtain a duplicate from the company.

5. Contact details of person responsible for grievances.

## Key Memory Hook

"Constitutional changes, capital actions, sale of undertaking — these don't happen at a casual show-of-hands. The Act forces companies into the formal, paper-trail route of a postal ballot."

Worked example

### Example 1

Example: A listed company has 1,500 members and wants to alter its objects clause in the MOA. Can it pass an ordinary resolution at a general meeting?

Answer: No. Alteration of objects clause is a matter that must be transacted by postal ballot under Sec. 110. The company has more than 200 members, so the exemption is not available. Although companies covered under Sec. 108 (e-voting) may transact such items at a general meeting through the e-voting route, the default mode prescribed under Sec. 110 is postal ballot.

⚠️ Common exam mistakes

  • Treating the postal ballot list as illustrative — it is mandatory; these specific items CANNOT be transacted by ordinary general meeting vote (except via Sec. 108 e-voting route for eligible companies).
  • Forgetting that companies with ≤ 200 members and OPCs are EXEMPT from the postal ballot route.
  • Assuming the 30-day voting window starts from receipt of notice — it actually starts from dispatch of notice.
  • Forgetting that the advertisement must appear in BOTH an English AND a vernacular newspaper (not either/or).
Reference: Section 110 — Companies Act, 2013
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