LEEL Electricals Submits FY21 Secretarial Compliance Report

Date: 05.06.2026

Compliance Report Submission

LEEL Electricals Limited submitted its Annual Secretarial Compliance Report for the Financial Year ended March 31, 2021, prepared by M/s G Aakash & Associates, Company Secretaries. The XBRL filing of the same could not be made due to a technical error in validation.

The report covers compliance examination with various SEBI regulations including:

• SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015
• SEBI (Prohibition of Insider Trading) Regulations, 2015
• SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 2011
• Several other regulations where no events occurred during the year

Compliance Findings

The report confirmed compliance with multiple regulatory requirements:

• Secretarial Standards compliance: YES
• Policy adoption and timely updates: YES
• Functional website maintenance and disclosures: YES
• No disqualified directors under Section 164 of Companies Act, 2013: YES
• Document preservation as per SEBI LODR Regulations: YES
• Performance evaluation of Board and Committees: YES
• Related party transactions with Audit Committee approval: YES
• Timely disclosure of events under Regulation 30: YES
• Compliance with Prohibition of Insider Trading Regulations: YES
• No actions taken by SEBI or Stock Exchanges: NO
• No resignation of statutory auditors: NA
• No additional non-compliances: YES

Insolvency Proceedings Background

The report provides critical context about the company's insolvency proceedings:

1. Corporate Insolvency Resolution Process (CIRP) was initiated on March 04, 2020, by order of NCLT, Allahabad Bench, on a petition filed by MKM Technologies Private Limited.

2. Mr. Arvind Mittal (Registration No. IBBI/PA-001/IPP01358/2018) was appointed as Interim Resolution Professional (IRP), and the powers of the Board of Directors stood suspended during the proceedings.

3. Mr. Ganga Ram Agarwal (Registration No. IBBI/IPA-002/IP-N00874/2018-1920/12777) was later appointed as Resolution Professional and took control of the company's management and operations per NCLAT order dated 21.12.2020.

4. Upon failure to achieve a Resolution Plan, liquidation proceedings were initiated against the company by NCLT order dated 06.12.2021, with the RP confirmed as liquidator.

5. The company was successfully sold as a going concern under liquidation to Krishna Ventures Limited (KVL/Acquirer), approved by NCLT order dated 21.03.2024. The Liquidator issued the Sale Certificate dated 12.06.2024.

Board Responsibilities During Insolvency

The report clarifies that:

• The Directors of the Reconstituted Board were not in office for most of the review period (FY 2020-21)
• During CIRP/Liquidation period (March 4th, 2020 to July 1st, 2024), the Resolution Professional/Liquidator managed the company
• The reconstituted board is not responsible for fiduciary duties regarding the period prior to acquisition, per Section 32A of IBC 2016
• No records were available with the new management due to the CIRP process
• The company is currently implementing the approved NCLT Order and undertaking compliance activities
• Regulations 17, 18, 19, 20 and 21 were not applicable during CIRP proceedings per Regulation 15(2A) and 15(2B)

No Material Non-Compliances

The report indicates no material non-compliances with SEBI regulations and circulars/guidelines for the financial year under review.

Report Certification

The Secretarial Compliance Report was issued by G Aakash & Associates, Company Secretaries, signed by Aakash Goel (Proprietor, Membership No.: A57213, CP No.: 21629), dated December 2, 2025.