Shree Hanuman Sugar & Industries Files Annual Secretarial Compliance Report for FY26 Amid Ongoing CIRP
Shree Hanuman Sugar & Industries Limited filed its Annual Secretarial Compliance Report for the year ended 31st March, 2026, amid an ongoing CIRP initiated by the NCLT, Kolkata Bench on 27th September 2024. The report flags non-compliance under Regulation 6(1) of SEBI LODR Regulations for failure to appoint a qualified Company Secretary, resulting in a BSE-imposed fine of Rs. 108560 and a freeze on promoter demat accounts. The Resolution Professional has acknowledged the violation and is stated to be in the process of addressing the requirement. Compliance with Secretarial Standards and Performance Evaluation was also reported as non-compliant, attributed to the suspension of Board powers under CIRP.

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Shree Hanuman Sugar & Industries Limited has submitted its Annual Secretarial Compliance Report (ASCR) for the year ended 31st March, 2026, as examined by Practicing Company Secretary Nupur Mimani (ACS No.: A37847, C.P. No.: 16805). The report, dated 13/05/2026, was prepared in accordance with SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, and covers the company's compliance status across multiple SEBI regulations during the review period. Notably, the company has been undergoing Corporate Insolvency Resolution Process (CIRP) since 27th September 2024, pursuant to an order by the Hon'ble NCLT, Kolkata Bench.
CIRP Status and Regulatory Implications
With the initiation of CIRP on 27th September 2024, the powers of the Board of Directors stand suspended, and all authority has been vested in the Resolution Professional (RP). As a consequence, pursuant to sub-regulations (2A) and (2B) of Regulation 15 of SEBI LODR Regulations, 2015, the provisions of Regulations 17, 18, 19, 20, and 21 — covering Board composition, Audit Committee, Nomination and Remuneration Committee, Stakeholders Relationship Committee, and Risk Management Committee — are not applicable to the company during the insolvency resolution process period.
Key Non-Compliance and Regulatory Action
The report identifies one instance of non-compliance during the review period. The following table summarises the deviation and the action taken:
| Parameter: | Details |
|---|---|
| Compliance Requirement: | Appointment of a qualified Company Secretary as Compliance Officer — Regulation 6(1) |
| Deviation: | Non-Compliance |
| Action Taken By: | BSE Ltd. |
| Type of Action: | Fine |
| Detail of Violation: | Imposition of fine and freeze of demat accounts of the promoters |
| Fine Amount: | Rs. 108560 |
| PCS Observation: | Kindly appoint Company Secretary (CS) and comply with the regulation |
| Management Response: | CIRP initiated by NCLT order dated 27.09.2024; Board powers suspended; RP is in process to comply |
The management has acknowledged the non-compliance, attributing it to the suspension of the Board and the ongoing CIRP, with the Resolution Professional stated to be in the process of addressing the regulatory requirement.
Affirmations Under BSE Circular
In accordance with BSE Circular Reference No. 20230410-41 dated April 10, 2023, the Practicing Company Secretary has provided affirmations on key compliance parameters. The table below presents the compliance status across all assessed areas:
| Sr. No. | Particulars | Compliance Status |
|---|---|---|
| 1. | Secretarial Standards | No |
| 2. | Adoption and Timely Updation of Policies | Yes |
| 3. | Maintenance and Disclosures on Website | Yes |
| 4. | Disqualification of Director | Yes |
| 5. | Details Related to Subsidiaries | NA |
| 6. | Preservation of Documents | Yes |
| 7. | Performance Evaluation | No |
| 8. | Related Party Transactions | NA |
| 9. | Disclosure of Events or Information | Yes |
| 10. | Prohibition of Insider Trading | Yes |
| 11. | Actions Taken by SEBI or Stock Exchanges | Yes |
| 12. | Additional Non-Compliances | Yes |
Key observations from the affirmations include:
- Secretarial Standards (Sr. No. 1): Marked as No, indicating non-compliance with applicable Secretarial Standards issued by the Institute of Company Secretaries of India (ICSI).
- Performance Evaluation (Sr. No. 7): Marked as No, as the company was unable to conduct performance evaluation of the Board, Independent Directors, and Committees given the CIRP status.
- Subsidiaries (Sr. No. 5) and Related Party Transactions (Sr. No. 8): Marked as NA — the company has no subsidiaries, and related party transaction provisions were not applicable during the review period.
- Additional Non-Compliances (Sr. No. 12): The PCS noted that no Company Secretary was appointed during the year under review.
Regulations Examined
The ASCR covered compliance with the following SEBI regulations, with certain regulations noted as not applicable during the review period:
- SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015
- SEBI (Issue of Capital and Disclosure Requirements) Regulations, 2018
- SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 2011
- SEBI (Buyback of Securities) Regulations, 2018 — Not Applicable
- SEBI (Share Based Employee Benefits) Regulations, 2014 — Not Applicable
- SEBI (Issue and Listing of Debt Securities) Regulations, 2008 — Not Applicable
- SEBI (Issue and Listing of Non-Convertible and Redeemable Preference Shares) Regulations, 2013 — Not Applicable
- SEBI (Prohibition of Insider Trading) Regulations, 2015
- SEBI (Depositories and Participant) Regulations, 2018
The report was signed by Nupur Mimani, Practicing Company Secretary, from Kolkata, with UDIN: A037847H000348289 and Peer Review No. 5781/2024. No actions were taken by SEBI or stock exchanges beyond those already disclosed, and no previous compliance observations were pending for action.
Historical Stock Returns for Shree Hanuman Sugar & Industries
| 1 Day | 5 Days | 1 Month | 6 Months | 1 Year | 5 Years |
|---|---|---|---|---|---|
| +1.73% | +0.98% | -3.06% | -21.37% | -27.08% | +89.86% |
What is the expected timeline for the Resolution Professional to appoint a qualified Company Secretary and resolve the Regulation 6(1) non-compliance, and what additional penalties could accrue if the appointment is further delayed?
How might the ongoing CIRP and accumulating regulatory non-compliances affect the prospects of potential resolution applicants bidding for Shree Hanuman Sugar & Industries under the insolvency process?
Could the freeze on promoters' demat accounts escalate to broader enforcement actions by SEBI or BSE if the Resolution Professional fails to address compliance gaps within the current financial year?




























