Anurag P. Poddar, promoter of balkrishna paper mills , has submitted a formal declaration under Regulation 31(4) of the SEBI (Substantial Acquisition of Shares and Takeovers) Regulation, 2011, confirming that no encumbrance—direct or indirect—was created on the promoter group's shareholding during the financial year ended 31st March, 2026. The declaration, dated 3rd April, 2026, was addressed to BSE Limited, the National Stock Exchange of India Limited, and the Audit Committee of Balkrishna Paper Mills Limited.

Declaration Details

The declaration was made by Anurag P. Poddar on behalf of himself, the Promoter Group, and Persons Acting in Concert (PAC). It confirms that no encumbrance was created, either directly or indirectly, on the promoter shareholding during the financial year ended 31st March, 2026. The key details of the declaration are summarised below:

Regulatory Compliance

The declaration is in compliance with Regulation 31(4) of the SEBI (Substantial Acquisition of Shares and Takeovers) Regulation, 2011, which mandates promoters and promoter groups to annually disclose whether any encumbrance has been created on their shareholding. The submission was made to both major stock exchanges—BSE Limited and the National Stock Exchange of India Limited—as well as to the Audit Committee of Balkrishna Paper Mills Limited, ensuring full regulatory transparency.

Summary

The promoter of Balkrishna Paper Mills Limited has confirmed that no encumbrance was created on 1,93,15,802 equity shares, constituting 59.95% of the company's shareholding, during the financial year ended 31st March, 2026. The declaration, submitted on 3rd April, 2026, fulfils the annual disclosure requirement under Regulation 31(4) of the SEBI Takeover Regulations and has been duly communicated to BSE Limited, the National Stock Exchange of India Limited, and the company's Audit Committee.

Balkrishna Paper Mills Limited has received return letters from both BSE Limited and the National Stock Exchange of India Limited regarding its proposed Scheme of Reduction of Share Capital under Section 66 read with Section 52 of the Companies Act, 2013. The company informed the exchanges about receiving these return letters dated April 13, 2026, through a communication dated April 18, 2026.

Regulatory Development and Return Letters

Both exchanges returned the draft scheme citing the non-applicability of Regulation 37 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015. The return was based on a recent amendment to Regulation 37(6)(b) notified through a gazette notification dated December 13, 2024.

Scheme Details and Exemption Criteria

The proposed scheme involves writing off accumulated losses of the company against its share capital, applied uniformly across all shareholders on a pro rata basis. According to the exchanges, this type of scheme falls under the exemption provided in Regulation 37(6)(b) of the SEBI (LODR) Regulations.

The key observations made by both exchanges include:

• The draft scheme solely involves writing off accumulated losses against share capital
• The application is uniform across all shareholders on a pro rata basis
• Such schemes are exempt from Regulation 37 requirements as per the December 13, 2024 amendment
• The reduction of unlisted Non-Convertible Redeemable Preference Shares (NCRPS) issued to promoters does not fall under SEBI/exchange purview

Regulatory Framework and Compliance

The exchanges clarified that schemes which solely provide for writing off accumulated losses against share capital or reserves of listed entities, when applied uniformly on a pro rata basis, are exempt from Regulation 37 requirements. These schemes only need to be filed with recognized stock exchanges for disclosure purposes.

Outstanding Approvals and Next Steps

Despite the return of the draft scheme by the exchanges, the company noted that the scheme remains subject to various statutory and regulatory approvals. These include approvals from the National Company Law Tribunal (NCLT) and the shareholders of the company.

The company's communication was signed by Omparakash Singh, Company Secretary and Compliance Officer, and included copies of the return letters from both exchanges as enclosures. The scheme was originally approved by the Board of Directors on December 23, 2025, subject to receipt of various statutory and regulatory approvals.