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Microlesson · 5-min read

Reporting Satisfaction of Charge (Section 82)

# Reporting Satisfaction of Charge (Section 82)

A charge does not disappear from the public register on its own. When the underlying debt is repaid (i.e., the charge is 'satisfied'), the company must actively notify the ROC so the register can reflect reality.

## 1. Time Limit for Intimation

  • The company shall intimate satisfaction of a registered charge to the ROC in Form CHG-4 within 30 days from the date of payment or satisfaction.
  • Special carve-out: For IFSC Private Ltd and IFSC Public Ltd companies, this period is 300 days, with additional fees applicable.

## 2. Extended Period

The Registrar may allow intimation within 300 days on application by the company or the charge-holder, on payment of additional fees.

## 3. ROC's Procedure on Receiving Intimation

1. The ROC sends a notice to the charge-holder requiring them to show cause within 14 days why payment or satisfaction in full should not be recorded.

2. If no cause is shown → ROC enters a memorandum of satisfaction in the register and informs the company.

3. No notice is required if Form CHG-4 is already signed by the charge-holder (since their consent is implicit).

4. If the charge-holder shows cause → ROC records that note in the register and informs the company.

## 4. Certificate of Satisfaction

When the ROC enters a memorandum of satisfaction in full, it issues a Certificate of Registration of Satisfaction of Charge in Form CHG-5.

## 5. Relationship with Section 83

Section 82(4) clarifies that the provisions of Section 82 do not restrict the ROC's powers under Section 83 to enter satisfaction on its own evidence, even without any intimation from the company.

## Quick Summary Table

StepFormWho Acts
Intimate satisfactionCHG-4Company (or charge-holder)
Notice to charge-holderROC (skipped if CHG-4 signed by charge-holder)
Certificate of satisfactionCHG-5ROC

Worked example

### Example 1

Example 1 — Routine satisfaction: A loan of ₹1 crore is fully repaid on 1st June. CHG-4 is signed by both the company and the bank and filed on 20th June. Since the charge-holder has signed, the ROC issues CHG-5 directly without sending a 14-day notice.

### Example 2

Example 2 — Charge-holder's objection: Company files CHG-4 unilaterally claiming full repayment. The ROC notices the charge-holder. The charge-holder replies within 14 days that only 80% was repaid. The ROC records this objection in the register instead of entering full satisfaction.

### Example 3

Example 3 — Extended window: Company forgets to file CHG-4 within 30 days. It may apply to ROC for an extension and intimate within 300 days with additional fees.

⚠️ Common exam mistakes

  • Forgetting that satisfaction must be actively reported — it doesn't happen by itself.
  • Thinking the 14-day show-cause notice always applies — if CHG-4 is signed by the charge-holder, no notice is needed.
  • Confusing CHG-4 (intimation of satisfaction) with CHG-5 (ROC's certificate confirming satisfaction).
  • Believing the 300-day extension is automatic — it requires an application and additional fees.
Bare-Act text Section 82 · Companies Act, 2013 · click to expand
Section 82(1) – A company shall give intimation to the Registrar in the prescribed form, of the payment or satisfaction in full of any charge registered under this Chapter within a period of thirty days from the date of such payment or satisfaction.
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