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Microlesson · 5-min read

Irregular Allotment - Grounds and Consequences

# Irregular Allotment

An allotment is termed irregular when statutory conditions for issuing shares to the public are violated. There is no single section defining 'irregular allotment'; instead, it is identified by reference to non-compliance with various provisions.

## Six Grounds of Irregular Allotment

### 1. No Prospectus Issued — Section 23

A company making a public offer is bound to issue a prospectus. Skipping it = irregular allotment.

### 2. Defective or Misleading Prospectus

If the prospectus is silent on mandatory disclosures, or contains misleading/false statements, any allotment made on its basis is irregular.

### 3. Prospectus Not Filed with ROC — Section 26(4)

The prospectus must be filed with the Registrar of Companies on or before the date of publication. Failure makes the allotment irregular.

### 4. Minimum Subscription Not Received — Section 39

If the minimum subscription stated in the prospectus has not been received before allotment, the allotment is irregular.

### 5. Application Money Less than Statutory Minimum

Application money must be at least 5% of the nominal value of the security (or such higher amount as SEBI may prescribe). If less, the allotment is irregular.

### 6. Listing Approval Not Obtained — Section 40

In a public issue, listing approval from one or more recognised stock exchanges must be obtained before allotment. Failure = irregular allotment.

## Quick Reference Table

GroundSection
No prospectusSec 23
Defective prospectusSec 26
Not filed with ROCSec 26(4)
Min. subscription not receivedSec 39
Application money < 5%Sec 39 / SEBI norms
No listing approvalSec 40

## Consequence

Irregular allotment exposes the company and officers to refund, interest, and penalty obligations (mainly under Sections 39 and 40).

Worked example

### Example 1

Example: A company collects ₹2 per share as application money on shares of face value ₹100. Is the allotment valid?

Answer: No. Application money must be at least 5% of nominal value, i.e., ₹5 per share. ₹2 is below the statutory floor, making the allotment irregular.

⚠️ Common exam mistakes

  • Believing irregular allotment only occurs when there is fraud — it can arise from purely procedural lapses (e.g., not filing the prospectus with ROC).
  • Confusing 5% application money rule with 25% rule — Companies Act prescribes 5% minimum; SEBI may prescribe higher (often 25%) for listed issues.
  • Forgetting that listing approval is required before allotment, not after.
Bare-Act text Sections 23, 26(4), 39, 40 · Companies Act, 2013 · click to expand
Section 39(1) – No allotment of any securities of a company offered to the public for subscription shall be made unless the amount stated in the prospectus as the minimum amount has been subscribed and the sums payable on application for the amount so stated have been paid to and received by the company by cheque or other instrument.
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