MEP Infrastructure Developers Limited has submitted its Annual Secretarial Compliance Report for the financial year ended March 31, 2024, under Regulation 24A of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015. The comprehensive report, prepared by practicing company secretary CS Shreyas Athavale of Shreyas Athavale & Co., reveals multiple regulatory compliance issues and penalties incurred during the review period.

Corporate Insolvency Resolution Process

A significant development during FY24 was the admission of MEP Infrastructure Developers into the Corporate Insolvency Resolution Process (CIRP). The National Company Law Tribunal (NCLT) Mumbai Bench, through its order dated March 28, 2024, admitted the application for initiation of CIRP under the Insolvency and Bankruptcy Code, 2016.

Regulatory Violations and Penalties

The secretarial audit identified several compliance violations that resulted in monetary penalties from stock exchanges. The most significant violations involved delayed submissions of mandatory disclosures to NSE and BSE.

Financial Results Submission Delays

The company was required to submit financial results within thirty minutes of board meeting conclusion under Regulation 33 of SEBI (LODR) Regulations, 2015. Similarly, voting results must be submitted within 48 hours of voting period conclusion under Regulation 44(3).

SEBI Enforcement Actions

MEP Infrastructure Developers received multiple notices from SEBI during the review period. The company received a show cause notice under Rule 4(1) of SEBI (Procedure for Holding Inquiry and Imposing Penalties) Rules, 1995, for alleged violations including:

• Non-compliance with Regulation 30(7) regarding material event disclosures
• Delayed disclosure of loan defaults as per SEBI Circular dated November 21, 2019
• Issues related to postal ballot voting result discrepancies

The company appointed Cyril Amarchand Mangaldas, Advocates and Solicitors, to represent it in the adjudication proceedings. However, due to the subsequent CIRP admission and moratorium, no further action was taken on these matters.

Postal Ballot Controversies

A significant compliance issue arose from the postal ballot notice dated March 11, 2023, regarding the disposal of material subsidiary MEP Infrastructure Private Limited (MIPL). The company declared certain resolutions as passed despite the scrutinizer's report indicating they were voted against and could not be passed.

SEBI intervened through its letter dated January 24, 2024, advising the company not to act on these transactions and clarifying that the resolutions cannot be considered as passed. The company disclosed this communication to stock exchanges on February 1, 2024.

Compliance Status Overview

Despite the violations, the secretarial audit confirmed compliance in several key areas:

• Secretarial Standards for board and general meetings
• Adoption and timely updation of SEBI-mandated policies
• Website maintenance and document disclosure
• Director disqualification requirements
• Performance evaluation processes
• Document preservation protocols

Management Response and Remedial Actions

The company has paid all imposed penalties and informed the respective stock exchanges as required. The board of directors was apprised of these penalties as per Regulation 17(7) of SEBI (LODR) Regulations, 2015. The company attributed some delays to inadvertent errors and operational challenges, particularly regarding the SDD software operation for insider trading compliance.

The secretarial compliance report underscores the regulatory challenges faced by MEP Infrastructure Developers during FY24, culminating in the CIRP admission that has fundamentally altered the company's operational and governance structure.

MEP Infrastructure Developers Limited (MEPIDL) has entered a crucial phase in its Corporate Insolvency Resolution Process (CIRP) as the National Company Law Tribunal (NCLT) Mumbai Bench commenced hearing proceedings on the company's resolution plan on October 14, 2025.

Key Developments

• Insolvency Proceedings: MEPIDL has been under CIRP since March 28, 2024
• Resolution Professional: Mr. Ravindra Kumar Goyal (Registration No. IBBI/IPA-001/IP-P-02019/2020-2021/13098)
• Moratorium: In effect since the start of insolvency proceedings under the Insolvency and Bankruptcy Code
• Hearing Details: IA(IBC)(PLAN) / 103(MB)2025 commenced on October 14, 2025, at NCLT Mumbai Bench (Court IV)

Regulatory Compliance

MEPIDL has adhered to regulatory requirements by providing a post-facto intimation to the stock exchanges regarding the NCLT hearing. This disclosure aligns with sub-clause 16(j) of Clause A of Part A of Schedule III of Regulation 30 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015.

Stock Information

The commencement of the NCLT hearing marks a significant milestone in MEPIDL's insolvency resolution process. Stakeholders and investors will be closely monitoring the proceedings, as the outcome could have substantial implications for the company's future operations and financial structure.

As the resolution process unfolds, further updates are expected to be communicated by the Resolution Professional in compliance with regulatory requirements. The resolution plan's details and potential impact on creditors and shareholders remain to be seen as the NCLT evaluates the proposed course of action for MEPIDL.