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HomeDocumentsDocument Guides › Board Resolution

Board resolution — the decisions that cannot be passed by circulation, and the filing exemption almost everybody gets wrong

A board resolution looks like the simplest document a company ever produces: half a page, a name, an authority. It is also the document most often produced the wrong way — passed by circulation when the Act requires a meeting, signed without quorum, silent about an interested director, or filed with the Registrar when no filing was needed. None of that shows at the time. All of it shows later, when a lender, a buyer’s advocate or an auditor goes through the file.

Drafting from ₹900 Same day – 2 days Certified true copy format included Nothing payable in advance
Can every board decision be taken by circulating a paper to the directors?No. Section 175 of the Companies Act, 2013 allows resolutions by circulation, but Section 179(3) lists powers the Board may exercise only by resolutions passed at a meeting — including borrowing money, investing the company’s funds, granting loans or giving guarantees, issuing securities and approving the financial statement. A circulated resolution on any of those is not a valid exercise of the power. And even for matters that can be circulated, if not less than one-third of the directors require it to be decided at a meeting, it must go to a meeting.

What a board resolution is

A company is a person in law but it has no hands. Everything it does, it does through people, and the body that decides what those people may do is the board of directors. A board resolution is the record of one of those decisions.

That is worth saying plainly because of what follows from it. The resolution is not the transaction. It is the authority for the transaction. When a bank asks for a resolution before it opens an account, it is not collecting paperwork — it is satisfying itself that the person signing the forms was authorised by the company to sign them. When a court registry asks for one, it is checking that the person filing has standing to file for the company.

Which means a resolution is judged by whether it does that job. A beautifully typed page that does not identify the person, or does not say precisely what they may do, or was passed in a way the Act does not permit, fails at exactly the moment it is needed.

The one-line version. A resolution answers one question for an outsider: was this person authorised by the company to do this thing? Everything in the drafting exists to answer that question cleanly.

When you actually need one

Swipe to see the whole table
SituationWho asks for itMust it be at a meeting?
Opening a bank account, changing signatoriesThe bank Not by itself, but banks usually prefer a meeting resolution
Borrowing money, availing a facilityThe lender Yes — Section 179(3)
Giving a guarantee or security for a loanThe lender Yes — Section 179(3)
Investing the company’s fundsAuditor, counterparty Yes — Section 179(3)
Issuing shares or debenturesRegistrar, subscriber Yes — Section 179(3)
Approving the financial statement and Board’s reportAuditor, Registrar Yes — Section 179(3)
Authorising a person to sign an agreementThe counterpartyNo
Authorising a person to appear before a tax or regulatory authority That authorityNo
Authorising somebody to act in litigationThe court registryNo
Appointment or resignation of a director, shifting the registered office RegistrarUsually at a meeting, and often with shareholder approval too

The third column is the one to read before you decide how to pass it.

Section 179(3) — meeting only

This provision decides more resolutions than any other, and most people have never read it.

Section 179(3), Companies Act, 2013 (in substance).

The Board of Directors of a company shall exercise the following powers only by means of resolutions passed at meetings of the Board

(a) to make calls on shareholders in respect of money unpaid on their shares;
(b) to authorise buy-back of securities;
(c) to issue securities, including debentures, whether in or outside India;
(d) to borrow monies;
(e) to invest the funds of the company;
(f) to grant loans or give guarantee or provide security in respect of loans;
(g) to approve financial statement and the Board’s report;
(h) to diversify the business of the company;
(i) to approve amalgamation, merger or reconstruction;
(j) to take over a company or acquire a controlling or substantial stake in another company;
(k) any other matter which may be prescribed.

Note clause (k). The rules made under the Act add further matters to that list, so the statutory eleven is a floor rather than a ceiling. Note also the proviso to the section, which allows the Board to delegate certain of these powers — borrowing, investing and granting loans — to a committee, the managing director, the manager or another principal officer, by a resolution passed at a meeting. So even the delegation has to be done at a meeting.

The practical consequence is simple and it catches companies constantly. A term loan is sanctioned, somebody circulates a resolution for signature because getting three directors into a room is inconvenient, and the file now contains a document that is not a valid exercise of the borrowing power. Nobody notices — until due diligence, or a dispute about whether the borrowing was authorised.

Section 175 — resolution by circulation

For everything outside that list, circulation is a perfectly proper mechanism, and for a small company it is often the sensible one. But it has two conditions that are routinely ignored.

Section 175, Companies Act, 2013 (in substance).

No resolution shall be deemed to have been duly passed by the Board or by a committee by circulation unless the resolution has been circulated in draft, together with the necessary papers, to all the directors, or members of the committee, at their addresses registered with the company, and has been approved by a majority of them as are entitled to vote on the resolution.

Provided that where not less than one-third of the total number of directors for the time being require that any resolution under circulation must be decided at a meeting, the chairperson shall put the resolution to be decided at a meeting of the Board.

A resolution passed by circulation shall be noted at a subsequent meeting of the Board or the committee and made part of the minutes of that meeting.

Three things to take from that. It must go to all the directors, at their registered addresses, in draft, with the papers. A one-third block can force it into a meeting. And it is not finished when the last director signs — it has to be noted in the minutes of a later meeting, and companies forget this step almost universally.

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Quorum, and why it invalidates more than people think

Section 174(1) fixes the quorum for a Board meeting at one-third of the total strength of the Board, or two directors, whichever is higher, and any fraction in that one-third is rounded up to one.

So a board of three needs two. A board of five needs two. A board of seven needs three. And a board of two needs both — which is the case for a great many private limited companies, and which means that in a two-director company there is no such thing as a Board meeting attended by one person.

Section 174 also deals with what happens when the number of interested directors reduces the remaining directors below quorum — the remaining directors, not being less than two, may act for the purpose of increasing the number of directors or of calling a general meeting. And where a meeting could not be held for want of quorum, unless the articles say otherwise, it stands adjourned to the same day in the next week at the same time and place.

Two directors, one signature. In a two-director private company, a resolution recorded as passed at a meeting where only one director was present is not a valid resolution. This is the commonest defect we find in company files, and it is invisible until somebody reads the minutes properly.

The meeting calendar

Section 173(1), Companies Act, 2013 (in substance).

Every company shall hold the first meeting of the Board of Directors within thirty days of the date of its incorporation, and thereafter hold a minimum number of four meetings of its Board every year, in such a manner that not more than one hundred and twenty days shall intervene between two consecutive meetings of the Board.

Two numbers, both absolute: four in a year, and never more than 120 days apart. A company that holds all four in December has not complied, because the gap rule is separate from the count rule.

Meetings are called on notice — the Act requires at least seven days’ notice in writing to every director, at the registered address, by hand, post or electronic means, with provision for a meeting at shorter notice to transact urgent business subject to the conditions the Act specifies. Where notice was short, say so in the minutes rather than leaving it to be inferred.

One Person Companies and small companies

The Act does not apply the full calendar to the smallest companies.

Section 173(5), Companies Act, 2013 (in substance).

A One Person Company, small company, dormant company and a private company that is a start-up shall be deemed to have complied with the provisions of this section if at least one meeting of the Board has been conducted in each half of a calendar year and the gap between the two meetings is not less than ninety days. This shall not apply to a One Person Company in which there is only one director.

And for the single-director One Person Company, Section 122 supplies the answer: where there is only one director, it is sufficient that the resolution is entered in the minutes book, signed and dated by the director, and that date is deemed to be the date of the meeting for all purposes under the Act.

So a one-director OPC does not hold meetings — but it does keep a minutes book, and the resolution still has to be recorded, signed and dated. Skipping the book because there is nobody to meet is a different mistake from skipping the meeting.

Video conferencing

Section 173(2) permits directors to participate in a Board meeting in person or through video conferencing or other audio-visual means, as may be prescribed, which are capable of recording and recognising the participation of the directors and of recording and storing the proceedings of the meeting along with the date and time.

There were historically restrictions on dealing with certain items — approval of the financial statement, the Board’s report, the prospectus, audit committee matters and approval of a merger or takeover — through video conferencing, and the rules on this have been amended over time. Rather than print a position that may have moved, we confirm the current rule for the specific item before advising on it.

What does not change is the record. Where a director participates remotely, the minutes should say so, name the director, and record that the participation was capable of being recorded as required. Minutes that describe everybody as present in a room when two people were on a call are inaccurate minutes, and inaccurate minutes are a statutory problem rather than a cosmetic one.

Interested directors

Section 184(2) requires every director who is in any way, whether directly or indirectly, concerned or interested in a contract or arrangement entered into or to be entered into with a body corporate or a firm or other entity in which the director has the prescribed interest, to disclose the nature of that interest at the Board meeting in which the contract or arrangement is discussed, and not to participate in such meeting.

The drafting consequence is a single sentence that should appear in the resolution itself, and usually does not: that the interested director disclosed the nature of the interest, did not participate in the discussion or vote on that item, and that quorum was present without counting that director where the rules so require.

Without it, the resolution is silent on a statutory requirement that was either met or not met, and silence is not evidence of compliance. With it, the point is closed on the face of the document.

Minutes and secretarial standards

The resolution is the decision. The minutes are the record of the meeting at which it was taken, and the Act treats the record seriously.

MGT-14 — the exemption people get wrong

This is the point on which we are asked for a second opinion more than any other in this area, usually because two advisers have said opposite things.

Section 117 requires a copy of every resolution of a description specified in Section 117(3) to be filed with the Registrar in the prescribed form within the prescribed period, and Form MGT-14 is that form. One of the descriptions in Section 117(3) is resolutions passed in pursuance of Section 179(3) — that is, the meeting-only list above.

The exemption. By a notification in June 2015, the Central Government exempted private companies from that clause of Section 117(3). The practical result is that an ordinary private limited company does not file MGT-14 for resolutions passed under Section 179(3) — borrowing, investing, granting loans, and the rest of that list. Public companies do.

Two cautions, because this is exactly the kind of point that goes stale. First, the exemption is attached to that clause, not to Section 117 as a whole — other resolutions listed in Section 117(3) are still filed by private companies. Second, exemption notifications have conditions, and a company in default of its filing obligations may not be able to rely on them. We check the position for your company rather than assuming it.

The certified true copy

Nobody outside the company sees the minutes book. What they take instead is a certified true copy, and getting its format right is most of what a bank or a registrar is actually assessing.

A usable certified true copy states all of the following:

Two practical notes. Banks almost always want the specimen signature of the authorised person attested on the same document, and a copy without it comes straight back. And where the authority is meant to continue, say so — “until revoked by the Board” — rather than leaving the institution to wonder whether the authority expired with the transaction.

How a resolution should actually be worded

Most resolutions we are asked to fix fail on the same three things: they do not identify the person precisely, they do not say exactly what the person may do, and they do not state the limit.

Swipe to see the whole table
WeakWhy it failsBetter
“Resolved that the company may open a bank account.” No bank, no branch, nobody authorised Names the bank and branch, names the signatories, states the mode of operation
“Mr X is authorised to do all necessary acts.” Unbounded authority nobody will accept at face value Lists what he may do, and states the ceiling and the period
“Resolved to take a loan.” No lender, no amount, no security described Names the lender, the facility, the amount, the security and who may sign
“The board approves the agreement.” Which agreement, with whom, dated when? Identifies the counterparty and the document, and authorises a named person to execute it

A useful discipline when drafting: read the resolution as though you were the bank officer who has never met anybody in the company. If you could not tell from the page who is authorised and how far the authority goes, it needs another draft.

The bank account resolution

The most frequently requested resolution of all, and the one most often returned by the branch. What banks generally look for:

When the signatories change later, do not amend the old resolution — pass a fresh one that expressly revokes the earlier authority and substitutes the new one, and deliver it to the branch. A superseded signatory who was never formally removed is a real operational risk, not a paperwork quibble.

Authorising somebody to act in a proceeding

Where a company sues, defends, files a complaint or appears before an authority, the person acting for it has to be authorised, and registries check this. A resolution for that purpose should name the person, describe the proceeding or the class of proceedings, and state what the person may do — sign and verify pleadings, engage advocates, swear affidavits, appear, and give evidence where required.

Two things worth getting right. Make the authority wide enough to cover the whole matter rather than a single step, so that a fresh resolution is not needed at every stage. And where the authority is for a specific case, identify the case; where it is general, say so, and be aware that some forums prefer a specific authorisation.

The company still needs an advocate to conduct the matter — a resolution authorises a person to act for the company, it does not give that person a right of audience. Our directory is free to search and we take no commission.

Board resolution or shareholders’ resolution?

Swipe to see the whole table
Board resolutionShareholders’ resolution
Passed byThe directorsThe members, in general meeting
WhereAt a Board meeting, or by circulation where permitted At an annual or extraordinary general meeting, or by postal ballot where allowed
MajorityA majority of directors present and voting Simple majority for an ordinary resolution; at least three times the votes in favour as against, for a special resolution
Typical matters Day-to-day management, banking, borrowing within limits, authorising signatories Altering the articles, changing the name or objects, and the matters the Act reserves to members
If you use the wrong one The decision is not authorised — and the defect is structural, not clerical

Several transactions need both, in sequence, and in the right order. Where a shareholders’ approval is required, the Board first approves and calls the general meeting; the members then pass their resolution; and only then does the company act.

LLPs and partnerships

An LLP has no board of directors and therefore passes no board resolutions. Decisions are taken by the partners, in the manner the LLP agreement provides, and what a bank or an authority asks for is an authorisation or resolution of the designated partners in that form. A partnership firm works similarly, through the partnership deed and an authority letter or partners’ resolution.

The mistake to avoid is asking for “a board resolution” from an entity that has no board, and then producing a document that describes a meeting that could not have happened. Tell us the entity type and what the institution asked for, and we will draft the thing that actually fits. We also handle the underlying registrations — private limited and LLP — if the entity does not exist yet.

Why back-dating is a bad idea

The request comes up constantly: a decision was taken months ago, nobody recorded it, and now a bank or an auditor wants a resolution dated back then.

Do not. The minutes book has consecutively numbered pages and a sequence; the resolution will sit alongside other entries with their own dates; the bank’s own file has dates; and the statutory provisions on minutes treat the record as something that is kept, not something that is reconstructed. A date that does not fit is precisely what somebody looking for a problem will find.

The honest alternative works and takes ten minutes: pass a resolution today that records what was decided and when, and ratifies and confirms the acts done pursuant to it. That is a normal, unremarkable corporate step. It tells the truth, it closes the gap, and it does not put anybody in a position they cannot explain.

Where these go wrong

Time and cost

A resolution is drafted in Same day – 2 days. The part that takes judgment is the question before the drafting: can this decision be taken the way you propose to take it, does it need a meeting, does it need shareholders as well, and does it need a filing.

Swipe to see the whole table
WhatPaid toTypical timing
Drafting, from ₹900 Us, after the work is doneSame day – 2 days
Notice, minutes and attendance record, where you want the full setUs Same turnaround
Registrar filing fee, where a filing is requiredThe Ministry portal Within the prescribed period
Notarisation or apostille, where the document goes abroadNotary or the authority Add time for it

We do not mark up government fees. Nothing is payable in advance — placing the order is free, we check how the decision has to be taken before we draft anything, and payment comes after the work is done.

The five-minute check before you pass it.
  • Is the matter in the Section 179(3) list? If yes, it needs a meeting.
  • Is quorum present — one-third or two directors, whichever is higher?
  • Is any director interested? Has the disclosure been recorded and the non-participation noted?
  • Does the resolution name the person, state exactly what they may do, and set a limit?
  • If it is a bank resolution, are the specimen signatures attested on the same page?
  • Does this also need a shareholders’ resolution, and in what order?
  • Is a filing required — and is your company one that is exempted from it?
  • Will the minutes be entered within thirty days?
FAQ

Board resolutions — questions people ask

What is a board resolution?
It is the formal record of a decision taken by the board of directors of a company. The board is the body that acts for the company, and a resolution is how that action is evidenced — which is why a bank, a registrar, a court or a counterparty will ask for one before they accept that a particular person may act on the company’s behalf. It is not a contract and it is not an agreement; it is a minute of a decision.
When do I actually need one?
Whenever somebody outside the company has to be satisfied that the company authorised something. Opening a bank account, changing authorised signatories, borrowing, giving a guarantee, appointing somebody to sign an agreement, authorising a person to appear in a proceeding or before a tax authority, applying for a tender, issuing shares, appointing or accepting the resignation of a director, shifting the registered office — each of these is ordinarily supported by a resolution.
Can a board decision be taken without holding a meeting?
Often yes, by circulation. Section 175 of the Companies Act, 2013 allows a resolution to be passed by circulation, and it is deemed passed when approved by a majority of the directors entitled to vote. But there are two conditions people forget: if not less than one-third of the total number of directors require that the resolution be decided at a meeting, the chairperson must put it to a meeting instead; and a resolution passed by circulation must be noted at a subsequent Board meeting and made part of its minutes.
Are there decisions that can only be taken at a meeting?
Yes, and this is the single most common mistake we see. Section 179(3) lists powers the Board can exercise only by means of resolutions passed at meetings — among them making calls on shareholders, authorising buy-back, issuing securities including debentures, borrowing monies, investing the funds of the company, granting loans or giving guarantees or providing security in respect of loans, approving the financial statement and the Board’s report, diversifying the business, approving amalgamation or reconstruction, and taking over or acquiring a controlling stake in another company. Rules made under the Act prescribe further matters. Passing any of these by circulation does not work.
What is the quorum for a board meeting?
Section 174(1) sets it at one-third of the total strength of the Board, or two directors, whichever is higher, and any fraction is rounded up to one. A meeting held without quorum is not a valid meeting, and a resolution passed at it is not a valid resolution — which is exactly the kind of defect that surfaces two years later when a bank or a buyer’s advocate goes through the file.
How many board meetings must a company hold?
Under Section 173(1), the first Board meeting must be held within thirty days of incorporation, and thereafter a minimum of four meetings every year, with a gap of not more than one hundred and twenty days between two consecutive meetings. Section 173(5) provides a relaxed regime for a One Person Company, a small company, a dormant company and a private company that is a start-up — at least one meeting in each half of a calendar year, with a gap of not less than ninety days between the two.
Does a board resolution have to be filed with the Registrar?
Some do, and here is the nuance almost everybody gets wrong. Resolutions passed under Section 179(3) fall within the filing requirement in Section 117, which is done in Form MGT-14 within the prescribed period. But private companies were exempted from that particular clause by a notification in June 2015, so an ordinary private limited company does not file MGT-14 for its Section 179(3) resolutions. Public companies do. Other resolutions listed in Section 117(3) are filed regardless of the type of company.
What is a “certified true copy” and why does the bank want one?
A bank or a registrar does not get to inspect your minutes book, so what they take instead is a copy of the resolution certified as a true copy by a director or the company secretary, on the company’s letterhead, with the date of the meeting and the names of those present. That certified copy is what goes into their file. Getting the format right the first time is most of the job, because a rejected copy usually means a fresh visit.
Can a director who is interested in the matter vote on it?
No. Section 184(2) requires a director who is in any way concerned or interested in a contract or arrangement to disclose the nature of the interest at the meeting, and such a director shall not participate in the meeting on that item. A well-drafted resolution records that the interested director disclosed the interest and did not participate — a resolution silent on the point invites a challenge later.
How does this work for a One Person Company?
Section 122 deals with it. Where a One Person Company has only one director, it is enough that the resolution is entered in the minutes book, signed and dated by the director, and that date is deemed to be the date of the meeting for all purposes under the Act. You still need the record; you just do not need a meeting of one person with himself.
Can directors attend by video conference?
Yes. Section 173(2) permits participation by video conferencing or other audio-visual means, provided the participation can be recorded and stored as prescribed. There were historically restrictions on dealing with certain matters through video conferencing, and the rules on that have been amended over time, so confirm the current position for the specific item before you rely on it. Where a director attends remotely, the minutes should record it as such.
When do the minutes have to be prepared?
Section 118 requires minutes of the proceedings of every meeting to be entered in the books maintained for that purpose within thirty days of the conclusion of the meeting, with the pages consecutively numbered. Section 118(10) goes further and requires every company to observe the secretarial standards specified by the Institute of Company Secretaries of India in respect of Board and general meetings. Those standards are a statutory requirement, not merely good practice.
Does a board resolution need stamp paper?
No. A resolution is an internal record of a decision and is ordinarily typed on the company’s letterhead, not on stamp paper. What may be chargeable is the document the resolution authorises — the agreement, the deed, the power of attorney. Our e-stamp paper guide deals with that side.
Does it need to be notarised?
Not as a general rule. Certification by a director or the company secretary is what most institutions want. Some specific situations — particularly where a document is going abroad — call for notarisation and sometimes apostille, and we handle that through our notary attestation service.
What is the difference between a board resolution and a shareholders’ resolution?
Who takes the decision. A board resolution is passed by the directors at a Board meeting or by circulation. A shareholders’ resolution — ordinary or special — is passed by the members in general meeting, and is required for the matters the Act reserves to them, such as altering the articles or approving certain related-party transactions. Using the wrong one is not a formality error; the decision is simply not authorised.
What is the difference between an ordinary and a special resolution?
That distinction belongs to shareholders’ resolutions rather than to the Board. An ordinary resolution is carried by a simple majority; a special resolution requires the notice to specify the intention to propose it as such and to be passed by not less than three times the votes cast in favour as against. The Act specifies which matters need which. A board resolution is passed by a majority of the directors present and voting.
Can a board resolution be back-dated?
It should not be, and it is a worse idea than it looks. The minutes book is a statutory record with numbered pages, resolutions are relied on by outsiders, and a resolution whose date does not fit the surrounding record is exactly what an investigator, a lender or an opposing party looks for. If a decision was taken and never recorded, the correct course is to record and ratify it now, on today’s date, with the history stated honestly.
Our company is a private limited with two directors. How much of this applies to us?
Most of it. The quorum rule applies, the Section 179(3) list applies, the requirement to record minutes applies, and the secretarial standards apply. What is relaxed for smaller companies is the frequency of meetings under Section 173(5) and the MGT-14 filing for Section 179(3) resolutions. Small does not mean exempt; it means a shorter list of obligations, each of which still has to be met.
Can you draft resolutions for an LLP?
An LLP does not have a board of directors, so it does not pass board resolutions. Decisions are taken by the designated partners in the manner the LLP agreement provides, and what banks and authorities ask for there is a resolution or authorisation of the partners in the form the agreement contemplates. We draft those as well — tell us what the institution has asked for and we will match it.
What do you charge, and do I pay in advance?
Drafting starts at ₹900 and ordinarily takes Same day – 2 days. Any government filing fee is paid at actuals and never marked up. Nothing is payable in advance — placing the order is free, we first check whether the decision can be taken the way you propose to take it, and payment comes after the work is done.
Related

The rest of the company file

Private limited registration LLP registration Resolution drafting Authorisation letter Employment agreement NDA Partnership deed E-stamp paper Indemnity bond All document guides

Tell us what the company has decided, and who is asking to see it.

Those two answers decide whether it needs a meeting or can be circulated, what the resolution has to say, whether a filing follows, and what the certified true copy must contain for the bank or registrar to accept it first time.

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