BUY BACK OF SHARES – LEGAL ASPECTS

Introduction:  (c)  from odd lots, that is to say, where the lot
When a company has substantial cash resources , itof securi­ties of a public company, whose shares
may like to purchase its own shares from the marketare listed on a recognized stock exchange, is smaller
particularly when the prevailing rate of its share in thethan such marketable lot, as may be specified by the
market is much lower than the book value .the legalstock exchange; or
aspects involved in this connection are described as  (d)  By purchasing the securities issued to
under:employees of the company pursuant to a scheme of
Under section 77A of the Indian companies Act,stock option or sweat equity.
1956, a company may purchase its own shares or(6) Where a company has passed a special resolution
other specified securities out of - its free reserves;under clause (b) of sub-section (2) or the Board has
or the securities premium account; or the proceedspassed a resolution under the first proviso to clause
of any shares or other specified securities. but no(b) of that sub-section to buy-back its own shares or
buy-back of any kind of shares or other particularother secu­rities under this section, it shall, before
securities shall be made out of the proceeds of anmaking such buy-back, file with the Registrar and the
earlier issue of the same kind of shares or same kindSecurities and Exchange Board of India a declaration
of other specified securities.of solvency in the form as may be prearranged and
    (1)There is also an embargo that no companyverified by an affidavit to the effect that the Board
shall purchase its own shares or other specifiedhas made a full inquest into the affairs of the
securities unless the buy-back is authorized by itscompany as a result of which they have formed an
articles; a special resolution has been passed inopinion that it is capable of meet­ing its liabilities and
general meeting of the company authorizing thewill not be rendered insolvent within a period of one
buy-back. However, the buy-back is of less than tenyear of the date of declaration adopted by the
per cent of the total paid-up equity capital and freeBoard, and signed by at least two directors of the
reserves of the company; and   such buy-back hascompany, one of whom shall be the managing
been authorized by the Board by means of adirector, if any :
resolution passed at its meeting then the articlesProvided that no declaration of solvency shall be filed
approval and special resolution is not required. Awith the Securities and Exchange Board of India by a
company is prohibited from going for furthercompany whose shares are not listed on any
buy-back within a period of three hundred andrecognized stock exchange.
sixty-five days, reckoned from the date of the(7) Where a company buys-back its own securities, it
earlier offer of buy-back.shall extin­guish and physically destroy the securities
It is very clear that, unless the company enforcesso bought-back within seven days of the last date of
strict corporate governance principles it is hard tocompletion of buy-back.
expect from the company’s board that, it will(8) Where a company completes a buy-back of its
fairly exercise the power granted to buy back sharesshares or other specified securities under this section,
upto ten per cent of the of paid up capital and freeit shall not make fur­ther issue of the same kind of
reserves.shares (including allotment of further shares under
(2) A company cannot buy back its shares from theclause (a) of sub-section (1) of section 81) or other
market more than twenty-five per cent of the total*specified securities within a period of six months
paid-up capital and free reserves of the company atexcept by way of bonus issue or in the discharge of
a time. Further, buy-back of equity shares in anysubsisting obligations such as conversion of warrants,
financial year shall not exceed twenty-five per centstock option schemes, sweat equity or conversion of
of its total paid-up equity capital in that financial year,preference shares or debentures into equity shares.
while the debts (of all types) of the company shall 
not be more than twice the capital and its *free(9) Where a company buys-back its securities under
reserves after such buy-back. For certain companiesthis section, it shall maintain a register of the
the Central Government may prescribe a higher ratio.securities so bought, the consideration paid for the
 It gives capricious to the Central Governmentsecurities bought-back, the date of cancellation of
regarding prescribing a higher ratio for certainsecurities, the date of extinguishing and physi­cally
companies. The ratio of buyback of shares upto 25%destroying of securities and such other particulars as
may have been restricted to less than 20%, as themay be prescribed.
present limit is 1/4th of the capital of the company. 
 In case of securities listed in the recognized stock(10) A company shall, after the completion of the
exchange, the company planning for buyback shouldbuy-back under this section, file with the Registrar
get the permission of SEBI. It is important to noteand the Securities and Exchange Board of India, a
that, only fully paid up shares can be redeemed. Noreturn containing such particulars relating to the
partly paid up shares can be redeemed.buy-back within thirty days of such completion, as
(3) The notice of the meeting at which specialmay be prescribed. Provided that no return shall be
resolution is proposed to be passed shall befiled with the Securities and Exchange Board of India
accompanied by an explanatory statementby a company whose shares are not listed on any
stating—recognized stock exchange.
(a)   Full and complete disclosure of all material 
facts;(11) If a company makes default in complying with
  (b)  The inevitability for the buy-back;the provisions of this section or any rules made there
  (c)  The class of security intended to beunder, or any regulations made under clause (f) of
purchased under the buy-back;sub-section (2), the company or any officer of the
 (d)    The amount to be invested under thecompany who is in default shall be punishable with
buy-back; andimprisonment for a term which may extend to two
  (e)  The time limit for completion of buy-back.years, or with fine which may extend to fifty
 thousand rupees, or with both.
(4) Every buy-back shall be completed within twelve 
months from the date of passing the specialNotes:
resolution or a resolution passed by the Board under  (a)  “Specified securities” includes
clause (b) of sub-section (2).employees’ stock option or other securities as
 may be notified by the Central Government from
(5) The buy-back under sub-section (1) may be—time to time;
  (a)  from the existing security holders on a  (b)  “free reserves” shall have the
proportionate basis; ormeaning assigned to it in clause (b) of Explanation to
  (b)  from the open market; orsection 372A.