SKIL Infrastructure fails to submit encumbered shares disclosure for FY26
SKIL Infrastructure Limited could not submit the disclosure of encumbered shares for FY26 due to ongoing CIRP proceedings and a lack of funds. The Resolution Professional cited an inability to coordinate with eight promoters and five intermediaries, including stock exchanges and depositories. The company has requested that the reasons for non-compliance be placed on record.

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SKIL Infrastructure Limited failed to submit the disclosure of encumbered shares under Regulation 31(4) of the SEBI (Substantial Acquisition of Shares and Takeovers) Regulations for the financial year ended March 31, 2026. The company stated that the ongoing Corporate Insolvency Resolution Process (CIRP) and the absence of cash flow prevented it from coordinating with promoters and intermediaries required for the compliance.
The company has been under CIRP since February 1, 2024, following an order by the Hon’ble National Company Law Tribunal (NCLT), Mumbai Bench. The Committee of Creditors (CoC) was constituted after the Hon’ble National Company Law Appellate Tribunal (NCLAT) vacated a stay on October 15, 2025. In the first CoC meeting held on November 3, 2025, Purusottam Behera was appointed as the Resolution Professional.
Regulation 31(4) mandates that the promoter of a target company declare annually that they have not created any encumbrance other than those previously disclosed. Due to the lack of available funds, the company could not facilitate the necessary coordination with the listed entities to fulfill this regulatory requirement.
The following promoters and intermediaries were identified as the parties with whom coordination could not be established:
| Sr No | Particulars | Category |
|---|---|---|
| 1 | Nikhil Prataprai Gandhi | Promoter |
| 2 | Sudipan Bhaduri, Jay Mehta, Ketan Shah (Trustee of HCWLL Trust) | Promoter |
| 3 | Sudipan Bhaduri, Jay Mehta, Ketan Shah (Trustee of FDLL Trust) | Promoter |
| 4 | Rupali Gandhi | Promoter |
| 5 | Bhavesh Prataprai Gandhi | Promoter |
| 6 | Neha Gandhi | Promoter |
| 7 | Prataprai Shivlal Gandhi | Promoter |
| 8 | Pranay Mehta | Promoter |
| 9 | RTA (MUFG Intime India Pvt Ltd) | Intermediary |
| 10 | NSDL | Intermediary |
| 11 | CDSL | Intermediary |
| 12 | National Stock Exchange | Intermediary |
| 13 | Bombay Stock Exchange | Intermediary |
Consequently, the company is not in a position to submit the required disclosure. The Resolution Professional requested the authorities to note these circumstances and the consequent non-submission of the filing.
What potential penalties or enforcement actions might SEBI impose given the company's inability to comply with Regulation 31(4)?
How will the ongoing lack of coordination with promoters and intermediaries impact the timeline for the Corporate Insolvency Resolution Process?
Could the failure to disclose encumbered shares complicate the identification of potential resolution applicants or bidders for the company?






















