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Compounding Advisory — Authorities, Eligibility & Classification

From determining the competent authority to assessing whether your offence is compoundable — a complete view of the legal framework we navigate for you.

Who Can Compound?

The authority for compounding depends on the maximum prescribed fine for the offence. The threshold of ₹25 lakhs, revised by the Companies (Amendment) Act 2017, determines jurisdiction.

TRIBUNAL

National Company Law Tribunal (NCLT)

Fine > ₹25 Lakhs

The NCLT bench having jurisdiction over the registered office of the company exercises compounding powers where the prescribed maximum fine for the default exceeds ₹25 lakhs. A speaking order with reasons is issued post personal hearing.

REGIONAL DIRECTOR

Regional Director (RD) / Authorised Officer

Fine ≤ ₹25 Lakhs

The Regional Director of MCA, or any officer specifically authorised by the Central Government, compounds offences where the maximum prescribed fine does not exceed ₹25 lakhs. Applications are filed with the concerned ROC and forwarded to the RD.

Who May Apply?

The Company

Any director of the company, specifically authorised by the Board of Directors by way of a board resolution, may represent the company and file/sign the compounding application on its behalf.

Officers in Default

Officers who are liable for prosecution under the relevant provision — including Managing Directors, Whole-Time Directors, Company Secretaries, and CFOs — may individually or jointly apply. A joint application by the company and officer is maintainable (NCLAT ruling).

Compoundable vs. Non-Compoundable

Not all offences under the Companies Act, 2013 are compoundable. Section 441(6) draws a clear line based on the nature of punishment prescribed.

✓  Compoundable Offences
  • Offences punishable with fine only
  • Offences punishable with fine or imprisonment (not both mandatorily)
  • Offences where fine or imprisonment is at the discretion of the court
  • Offences for which compounding is not already barred under §441(5)
  • Offences where no investigation u/s 210–229 is pending
✕  Non-Compoundable Offences
  • Offences punishable with imprisonment only
  • Offences punishable with imprisonment and fine (both mandatorily)
  • Same offence compounded within preceding 3 years
  • Offence under investigation initiated or pending (§§ 210–229)
  • Where court has not granted permission (in special court matters)
When Compounding is Not Allowed

3-Year Bar on Repeat Compounding

If the same offence was previously compounded and three years have not elapsed since the date of that compounding order, a fresh application for the same default is not maintainable. After the 3-year window, any subsequent commission is treated as a first offence.

Pending Investigation

Where any investigation under Sections 210–229 of the Companies Act, 2013 has been initiated or is pending, no offence covered under §441(1) shall be compounded. This is a significant departure from Section 621A of the Companies Act, 1956.

Imprisonment-Linked Offences

Offences where the prescribed punishment is imprisonment only, or imprisonment and fine together, are categorically non-compoundable under §441(6) — irrespective of any contrary provision under the Code of Criminal Procedure, 1973.

Not Sure if Your Offence is Compoundable?

JurisTatva Advisors will assess your default, identify the competent authority, and chart the most efficient route to resolution.

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