Corporate and Other LawsQuestion 5371 of 221
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Question 3 (a) UINA Infra Projects Private Limited was incorporated on 1st June, 2022. Mr. X had already registered the trade name of "UINA Infra projects" on 1st April, 2018 under the Trade Marks Act, 1999. Mr. X was suffering from a pro-longed disease since 1st April, 2021. When Mr. X recovered from illness on 20th May, 2024 and joined his own office on 5th July, 2024, he came to know from his staff members that a company has been incorporated with the name UINA Infra Projects Private Limited. He lodged a complaint with CORPORATE AND OTHER LAWS the Regional Director on 10th July, 2024 requesting him to order the company to change its name. The Regional Director examined the application of Mr. X and on 11th July, 2024, issued a direction to UINA Infra Projects Private Limited to change its name. Mr. D, a director of UINA Infra Projects Private Limited contended that the above direction of the Regional Director was bad in law and therefore not proper on the following grounds: A. That the name of the company is not too identical with or too nearly resembles to the name of any other company; and B. That the stipulated time period of two years of making any complaint with respect to the name in the above ground was already over on 31st May, 2024. Referring to the applicable provisions of the Companies Act, 2013, decide, whether the contention of Mr. D is tenable. Also advise UINA Infra Projects Private Limited the time period within which the company will be required to change its name in case the direction of the Regional Director was valid. (b) (i) Members of World One Limited, holding more than 2% of the total voting power wants the company to give a special notice to move a resolution for appointment of an auditor other than retiring auditor. Explain whether members can do so as per the provisions of the Companies Act, 2013. (ii) If a member of a listed company who has casted his vote through electronic voting, can attend general meeting of the company and change his vote subsequently? (c) Explain the Latin term "Absoluta sententia expositore non indiget" and how would the same help in correctly interpreting a definition given in a legislation or statute?

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Detailed Solution & Explanation

(a) According to section 16 of the Companies Act, 2013, if, through inadvertence or otherwise, a company on its first registration or on its registration by a new name, is registered by a name which: in the opinion of the Central Government (Power delegated to the Regional Director), is of opinion that name (original or revised/new) of company is identical with or too nearly resembles to the name by which a company in existence, then, either: (i) On its own or (ii) On an application by a proprietor of already registered trade mark under the Trade Marks Act, 1999, it may direct the company to change its name. The company shall change its name or new name, as the case may be, within a period of three months from the issue of such direction, after adopting an ordinary resolution for the purpose. Application by a proprietor of registered trade mark shall be made within three years of incorporation or registration or change of name of the company. In the given question, UINA Infra Projects Private Limited was incorporated on 1st June, 2022. The trade mark of UINA Infra Projects was registered on 1st April, 2018. In terms of the above stated provisions and facts of the question, we can answer the questions as under: Part (i) - First Ground of Objection: In the first instance, the contention of Mr. D (a director of UINA Infra Projects Private Limited) is not tenable due to the fact that the restriction is not only with respect to the name of an existing company, but also as a result of an application filed before the appropriate authority by the proprietor of a registered trademark. In other words, the name of the company ”UINA Infra Projects” is verbatim identical to the trademark registered by Mr. X. Hence, the contention of Mr. D is not tenable. Part (ii) - Second Ground of Objection: In the second instance also, the contention of Mr. D is not tenable. The application should be made by the proprietor of a registered trademark within three years of incorporation or registration or change of name of the company and not within two years. CORPORATE AND OTHER LAWS (b) (i) According to section 115 of the Companies Act, 2013, where, by any provision contained in this Act or in the Articles of a company, special notice is required for passing any resolution, then the notice of the intention to move such resolution shall be given to the company by such number of members holding not less than 1% of the total voting power, or holding shares on which such aggregate sum not exceeding five lakh rupees, as may be prescribed, has been paid-up. In such a case, the company shall give its members notice of the resolution in the manner as prescribed in **Rule 23** of the Companies (Management and Administration) Rules, 2014. Further, section 140(4) of the Companies Act, 2013 (the Act), provides provision for the appointment of an auditor other than the retiring auditor. As per this section, special notice shall be required for a resolution at an annual general meeting for appointing a person as an auditor in place of the retiring auditor, or providing expressly that a retiring auditor should not be re-appointed. In the present case, the provisions of section 115 of the Act have been duly complied with. That is to say the notice of the intention to move such a resolution as to appointment of auditor other than the retiring auditor has been given by members of World One Limited, holding more than 2% (i.e. more than 1 %) of the total voting power. Accordingly, members can do so as per the provisions of the Companies Act, 2013. Alternate Answer **Rule 23(1)** of the Companies (Management and Administration) Rules, 2014 specifies that a special notice required to be given to the company shall be signed, either individually or collectively by such number of members holding not less than one percent of total voting power or holding shares on which an aggregate sum of not less than 5,00,000 rupees has been paid up on the date of notice. As per the facts of the question, Members of World One Limited, holding more than 2% of the total voting power, wants the company to give a special notice to move a resolution for appointment of an auditor other than the retiring auditor. From the above provision, it can be inferred that the members holding 2% of total voting power can approach the company to give a special notice. However, they cannot force the company to give a special notice to move a resolution for appointment of an auditor other than the retiring auditor as stated in the question. (ii) According to **Rule 20(4)** (v) (f) (C) of the Companies (Management and Administration) Rules, 2014, the notice of the meeting shall clearly state that the members who have cast their vote by remote e-voting prior to the meeting may also attend the meeting but shall not be entitled to cast their vote again. Thus, in the given question, if a member of a listed company has casted his vote through electronic voting, he can still attend the general meeting of the company but neither he can vote again nor he can change his vote. (c) “Absoluta Sententia Expositore Non Indiget” The first and primary rule of construction is that the intention of the legislature must be found in the words used by the legislature itself. Thus, if the words of a statute are capable of one construction only, then it would not be open to the courts to adopt any hypothetical construction on the ground that such hypothetical construction is more consistent with the alleged object and policy of the Act. It is a cardinal rule of construction that a statute must be construed literally and grammatically giving the words their ordinary and natural meaning. Therefore, the language used in the statute must be construed in its grammatical sense. The correct course is to take the words themselves and arrive if possible, at their meaning without reference to cases, in the first instance. If the phraseology of a statute is clear and unambiguous and capable of one and only one interpretation, then it would not be correct to extrapolate these words out of their natural and ordinary sense. When the language of a statute is plain and unambiguous it is not open to the courts to adopt any other hypothetical construction simply with a view to carrying out the supposed intention of the legislature. Thus, it is the primary duty of the court to interpret the words used in legislation according to their ordinary grammatical meaning in the CORPORATE AND OTHER LAWS absence of any ambiguity or doubt. Normally, where the words of a statute are in themselves clear and unambiguous, then these words should be construed in their natural and ordinary sense and it is not open to the court to adopt any other hypothetical construction. This is called the rule of literal construction. This principle is contained in the Latin maxim “absoluta sententia expositore non indiget” which literally means “an absolute sentence or preposition needs not an expositor”. In other words, plain words require no explanation.

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