397/398 - Company Law Board - Forum Shopping - Indian Company Law

Introduction:I have seen few cases where the minority
It is a fact that it is very rare to see a petition by ashareholders or a director in a Family Company files a
group of minority or majority under section 397/398suit before a Civil Court alleging or challenging
of the Companies Act, 1956 in listed Publicsomething in the Company. As the Civil Courts are bit
Companies. As everybody knows a Company needscautious in granting an immediate relief and
to get qualified as per SEBI (DIP) regulations andentertaining a Company Dispute even, a party who
should satisfy other requirements before getting itshas approached the Civil Court may not get any relief
shares listed over a stock exchange. There can notand ultimately, after few years, he may be advised
be a listed public company where the entireto approach the Company Law Board under section
shareholding is held by a single person or entity.  The397/398 of the Companies Act, 1956 and other
allotment shares are to be in accordance with theprovisions of law.
SEBI (DIP) regulations and there will be many stakeComplications:
holders holding shares in a Company. As such,When a party who has filed a Civil Suit alleging
normally it is very rare to see a petition by thesomething and who has failed to get the intended
minority or the majority in a listed public companyrelief by the Civil Court may be opposed very
under section 397/398 of the Companies Act, 1956.strongly when he files a petition under section 397
Why many petitions are in respect of family398 of the Companies Act, 1956 highlighting the same
companies?issue which he has raised in the suit. It is really a
Most of the petitions under section 397/398 of thecomplicated issue to dealwith.
Companies Act, 1956 come from family companies orA shareholder might not have been advised well
closely held companies. Maintaining a petition by ainitially and will the same bar his corporal right to
minority or the majority under section 397/398 ofapproach the Company Law Board under section
the Companies Act, 1956 pertaining to a family3976/398 of the Companies Act, 1956?
company is very easy and it is logical. In spite ofWhether a shareholder or a minority group is allowed
plethora of corporate regulations and encouragementto abuse the process of court by filing many
to the companies to adhere to corporatepetitions and approaching various forums causing
governance, family companies are still run asvexation to the clear majority in the Company?
proprietorship concerns. In some cases, we can notWhether the Company Law Board can look into the
even find the books of account in family companiesissue which is pending before the Civil Court?
and all this issues will come to light when there comesWhether the Company Law Board can re-look into
serious dispute between or among the groups in thethe issue upon which there was a finding by the Civil
Company. Its true that a procedural irregularity willCourt?
not give rise to filing a petition under section 397/398These are few questions and these are very
of the Companies Act, 1956 and the section shouldcomplicated without having a straight answer as I
never be misused. It is also true that a proceduralfeel.  But, certainly, the rule is to be barring to do
irregularity may lead to a conclusion, at times, that itforum shopping causing a serious trouble to the
can be linked to oppression and mismanagement.majority as they should concentrate on their routine
There can not be a permanent rule as to whether abusiness without any hindrance. This is one type of
procedural irregularity can lead to a conclusion thatissue pertaining to approaching different forums and
there exist an oppression and mismanagement in thefinally approaching the Company Law Board under
Company.the provisions of Companies Act, 1956.
Point under discussion:There are cases where in a petition under section
Thus, as many family companies do not maintain397/398 of the Companies Act, 1956, there will be a
proper books of accounts and neglect filing theserious allegation and counter allegation on a particular
returns etc. with the authorities, it is so easy tothing and it will be the basis for filing and maintaining
allege oppression and mismanagement in respect ofthe petition under section 397/398 of the Companies
family companies and thus, most of the petitionsAct, 1956.  What happens is that a majority will
under section 397/398 of the Companies Act, 1956initiate a counter proceeding against the petitioner
are maintained.minority in the application under section 397/398 of
The point I want to discuss is about approachingthe Companies Act, 1956, before some other forum
various forums other than Company Law Boardand will stall the proceeding. The majority will contend
raising a Company Dispute. The jurisdiction of a civilthat they have taken appropriate steps and other
court to entertain a company dispute is aproceeding is initiated and pending and as such there
complicated issue to dealwith and there is no expressis no need of keeping a petition under section 397
bar under the Companies Act, 1956 on Civil Court's398 of the Companies Act, 1956 pending. This is
jurisdiction. This issue is sought to be addressed inanother situation where normally a simultaneous
the new Companies Bill which contain a specific barproceeding is resorted to. There are many
on the Civil Court's Jurisdiction.complicated issues and questions in the course and
Though, there is no bar in entertaining a Companythere can not be a straight jacket rule and it depends
Dispute unless an alternative and specific remedy isupon the facts and circumstances of each case.
provided though Civil Courts do not encourage suchThus, the Company Law Board is burdened with
litigation and advice the parties to approach thedischarging very complicated responsibilities under the
Company Law Board and its my personal opinion. TheCompanies Act, 1956 and many will also criticize the
Civil Courts may lack the needed expertise in dealingBoard for the delay and for not granting the relief
with Company matters and it will lead the Civil Courtsimmediately and for the delay caused due to the
at times to hold that the proper forum is Companyinsistence on the procedural compliance.
Law Board.Note: the views expressed are my personal.