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Microlesson · 5-min read

Registration of Charges & Extension of Time — Sec. 77

# Registration of Charges — Section 77

## 1. Duty to Register — Sec. 77(1)

It is the duty of the company creating a charge:

  • Within or outside India,
  • On its property, assets, or any of its undertakings,
  • Whether tangible or otherwise,
  • And situated in or outside India,

to register the particulars of the charge with the Registrar of Companies.

## 2. How to Register

ItemRequirement
FormCHG-1 (general) or CHG-9 (for debentures)
DocumentsForm + copy of instrument creating the charge, signed by both the company and the charge-holder
TimelineWithin 30 days of creation of charge
FeePrescribed fee (additional/ad valorem if delayed)
PreservationThe instrument creating/modifying a charge must be preserved for 8 years from the date of satisfaction of charge

Sec. 77 does not apply to certain charges prescribed in consultation with the RBI.

## 3. Verification of the Instrument of Charge

### Property situated in India (wholly or partly)

Copy verified by a certificate issued under the hand of:

  • A director or company secretary of the company, OR
  • An authorised officer of the charge-holder.

### Property situated outside India

Copy verified by a certificate issued either:

  • Under the seal of the company (if any), or
  • Under the hand of a director / CS / authorised officer of the charge-holder, or
  • Under the hand of some other person (not being the company) who is interested in the mortgage or charge.

This rule does not apply to charges created/modified by a banking company in favour of the RBI under the RBI Act, 1934.

## 4. Extension of Time — Two Regimes

The rules differ based on when the charge was created:

### A. Charge Created Before 2nd Nov 2018

```

Step 1: Register within 30 days of creation

│ (if missed)

Step 2: Register within 300 days of creation

on payment of additional fees

│ (if missed)

Step 3: Register within 6 months from 2nd Nov 2018

with additional fees (different rates for

different classes of companies)

```

### B. Charge Created On or After 2nd Nov 2018

```

Step 1: Register within 30 days of creation

│ (if missed)

Step 2: Register in next 30 days (i.e., within 60 days

from creation) with additional fees

│ (if missed)

Step 3: Register within a further 60 days (i.e., total

120 days from creation) with ad-valorem fees

```

## 5. Procedure for Seeking Extension

1. Company files an application to the Registrar in Form CHG-1 (or CHG-9 for debentures).

2. The application must be supported by a declaration from the company, signed by its CS or a director, that such belated filing shall not adversely affect the rights of any other intervening creditors.

3. Pay the required additional fee or ad valorem fee, as applicable.

### Registrar's Satisfaction

The Registrar must be satisfied that the company had sufficient cause for not filing the particulars and instrument within the original 30-day period. Only then will registration in the extended period be allowed.

## 6. Rights of the Lender / Charge-Holder

The rights of the charge-holder are not affected by the delay — they remain as they were before the actual registration, i.e., rights are deemed to have accrued from the date of creation of charge, even where actual registration happens within the extended period.

## 7. Quick Recap Table

ParticularDetail
Initial period30 days from creation
Extended period (post 2 Nov 2018)+ 30 days + 60 days = 120 days total
FormsCHG-1 / CHG-9
Preservation of instrument8 years from satisfaction
Signed byBoth company and charge-holder

Worked example

### Example 1

Example 1 — Within 30 days:

ABC Ltd. creates a charge on its factory in favour of SBI on 1st June 2026 for a term loan. By when must the charge be registered?

Answer: Within 30 days of creation, i.e., by 30th June 2026, by filing Form CHG-1 with the copy of the instrument signed by both ABC Ltd. and SBI, along with prescribed fees.

### Example 2

Example 2 — Belated filing (post 2-Nov-2018):

PQR Ltd. creates a charge on 1st January 2026. It fails to register within 30 days. What are its remaining options?

Answer:

  • First extension: Register within next 30 days (by 1st March 2026, i.e., 60 days from creation) with additional fees.
  • Second extension: Register within a further 60 days (by 30th April 2026, i.e., 120 days from creation) with ad valorem fees.
  • The application in CHG-1 must include a declaration by CS/director that intervening creditors' rights are not affected and the Registrar must be satisfied that sufficient cause existed for the delay.

### Example 3

Example 3 — Rights of charge-holder on delayed registration:

A charge created on 5th March is registered with extension on 15th May. Between these dates, another creditor lent money to the company. Whose rights prevail?

Answer: The first charge-holder's rights are deemed effective from the date of creation (5th March). The required declaration ensures that intervening creditors' rights are not adversely affected — protecting the priority of any bona fide creditor who lent during the gap.

⚠️ Common exam mistakes

  • Confusing the two extension regimes — the 300-day route applies only to charges created before 2 Nov 2018; later charges follow the 30 + 30 + 60-day regime (max 120 days).
  • Forgetting that both the company and the charge-holder must sign the instrument copy filed with the Registrar.
  • Using the wrong form — CHG-1 for general charges; CHG-9 specifically for charges related to debentures.
  • Assuming Registrar must automatically grant extension — Registrar must be satisfied of sufficient cause; extension is discretionary, not automatic.
  • Believing rights of the charge-holder start from date of registration — they actually relate back to the date of creation of the charge.
  • Confusing preservation period — instrument must be preserved for 8 years from date of satisfaction, not 8 years from creation.
Bare-Act text Section 77 read with Rule 3 of Companies (Registration of Charges) Rules, 2014 · Companies Act, 2013 · click to expand
Section 77(1): It shall be the duty of every company creating a charge within or outside India, on its property or assets or any of its undertakings, whether tangible or otherwise, and situated in or outside India, to register the particulars of the charge signed by the company and the charge-holder together with the instruments, if any, creating such charge in such form, on payment of such fees and in such manner as may be prescribed, with the Registrar within thirty days of its creation. Provided that the Registrar may, on an application by the company, allow such registration to be made— (a) in case of charges created before the commencement of the Companies (Amendment) Ordinance, 2019, within a period of three hundred days of such creation; or (b) in case of charges created on or after the commencement of the Companies (Amendment) Ordinance, 2019, within a period of sixty days of such creation, on payment of such additional fees as may be prescribed.
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