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Microlesson · 5-min read

Civil Liability for Misstatements in Prospectus (Sec 35)

# Section 35 — Civil Liability for Misstatements

## A. Compensating the Loss

If a person suffers loss by acting on a misleading statement or omission in the prospectus, the following are liable to compensate:

1. The Company;

2. Every Director at the time of issue;

3. Every Proposed Director named in the prospectus;

4. Every Promoter of the company;

5. Every Expert whose statement is included;

6. Every person who authorized the issue of the prospectus.

## B. Defenses — Exceptions to Liability

A person shall not be liable if they prove any of the following:

1. They withdrew consent before the prospectus was issued, and it was issued without their authority or consent;

2. They gave public notice that the prospectus was issued without their knowledge or consent;

3. They relied on an expert's authority, believing the expert's statement to be true and the expert was competent.

## C. Unlimited Liability for Fraud

If the prospectus was issued with fraudulent intent to deceive investors:

  • Those responsible are personally liable for all losses;
  • There is no limitation of liability.

## Civil vs Criminal — Quick Compare

AspectSec 34 (Criminal)Sec 35 (Civil)
TriggerUntrue/misleading statementLoss suffered by subscriber
LiabilitySec 447 — fraud (jail + fine)Compensation to subscriber
Loss required?NoYes
DefensesImmaterial / reasonable beliefWithdrawal, public notice, expert reliance
Fraud caseAlways liable under 447Personal unlimited liability

## Practical Takeaway

Sec 35 is about money back to the investor. Sec 34 is about punishment of the wrongdoer. Both can run simultaneously — they are not mutually exclusive.

Worked example

### Example 1

Example 1: An expert valuer's statement in the prospectus is later found false. A director who relied on the valuer's certificate is sued under Sec 35. What can he plead?

Answer: He can plead the defense of having relied on the expert's authority — provided the expert was competent and the director had reasonable grounds to believe the expert's statement was true.

### Example 2

Example 2: A promoter signs off on a fraudulent prospectus knowing the financials are inflated. Investors lose ₹100 crore. The company has only ₹20 crore. Can the promoter limit his liability?

Answer: No. Where fraud is established, liability under Sec 35 is personal and unlimited. The promoter is liable for the full ₹100 crore loss.

⚠️ Common exam mistakes

  • Confusing Sec 34 (criminal) with Sec 35 (civil) — different elements and defenses.
  • Forgetting that 'experts' are also liable under Sec 35.
  • Missing that fraud removes all liability limits — full personal liability applies.
  • Believing a director can escape Sec 35 by saying 'I didn't read it' — withdrawal of consent must be done before issuance with public notice.
Bare-Act text Section 35 · Companies Act, 2013 · click to expand
Section 35(1): Where a person has subscribed for securities of a company acting on any statement included, or the inclusion or omission of any matter, in the prospectus which is misleading and has sustained any loss or damage as a consequence thereof, the company and every person who is a director of the company at the time of the issue of the prospectus; has authorised himself to be named and is named in the prospectus as a director; is a promoter of the company; has authorised the issue of the prospectus; and is an expert referred to in sub-section (5) of section 26, shall, without prejudice to any punishment to which any person may be liable under section 36, be liable to pay compensation to every person who has sustained such loss or damage.
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