Company's Response to Exchange Queries
Radha Madhav Corporation Limited submitted a comprehensive response to common queries raised by BSE Limited and National Stock Exchange of India Limited on March 6, 2026. The company addressed multiple compliance issues and penalty impositions by referencing NCLT orders and resolution plan provisions.
Key Clarifications on Penalties and Compliance
The company highlighted that from October 22, 2020 to August 1, 2022, it was under the control and management of the Resolution Professional pursuant to the initiation of Corporate Insolvency Resolution Process (CIRP) under the Insolvency and Bankruptcy Code, 2016. The Hon'ble NCLT approved the resolution plan submitted by new management on August 1, 2022.
The Hon'ble NCLT, vide its Order dated November 10, 2025, has waived all penalties up to August 01, 2022 and categorically observed that no penalty can be levied for the period prior to commencement of CIRP and during the CIRP period of the Company.
In view of the aforesaid order, the new management stated they cannot do any filing prior to 2020 when the company was in control of old management, and cannot do any filing for the period 2020 till 2022 when the company was in control of Resolution Professional.
Corporate Governance Compliance Exemption
The company addressed non-compliance with Regulations 17 to 27 related to Corporate Governance by stating that the Hon'ble NCLT, Ahmedabad Bench approved the Resolution Plan which reduced existing share capital from 9,12,95,775 equity shares to 6,82,185 equity shares.
As per Regulation 15(2) of SEBI (LODR) Regulations, 2015, corporate governance provisions are not mandatory for listed entities having paid-up equity share capital not exceeding ₹10 Crore and net worth not exceeding ₹25 Crore. The company presently falls within these threshold limits, making Regulations 17 to 27 not applicable.
The company noted it received temporary ISIN no. INE172H01022 from NSDL and CDSL but is yet to receive listing approval from BSE and NSE, hence the old paid-up capital is still reflecting on both exchanges.
Consolidated Financial Results Clarification
Regarding non-submission of consolidated financial results for quarter ended December 2025, the company clarified that it had informed both exchanges vide letter dated November 4, 2023 regarding proposed acquisition of majority stake in Phytoatomy Private Limited.
Vide update dated January 23, 2026, the company clarified that the proposed acquisition is still under process and not completed, and accordingly, the company has not acquired any control or shareholding in Phytoatomy Private Limited. Therefore, requirement for submission of consolidated financial results under Regulation 33 of SEBI (LODR) Regulations, 2015 is not applicable at present.
The company has consistently disclosed in its quarterly financial results and responses to exchange queries that consolidated financial results are not applicable in its case.
Regulatory Compliance Status
The company stated that all filings with effect from August 1, 2022 are in place and reflected on the BSE Portal. As a successful Resolution Applicant, they cannot do any filing prior to August 1, 2022 as the company was in control of Resolution Professional.
The company requested both exchanges to withdraw the penalty levied.
Supporting Documentation
The response included copies of several NCLT orders:
- Hon'ble NCLT CIRP Order dated October 22, 2020 (Exhibit A)
- Hon'ble NCLT Order for approval of Resolution plan dated August 1, 2022 (Exhibit B)
- Certified copy of Resolution Plan (Exhibit C)
- Hon'ble NCLT Order dated November 10, 2025 (Exhibit D)