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Summary
7
Company Law I

TOPIC:
10
Legal Analysis on the Doctrine of Lifting the Corporate Veil
with respect to Indian Cases

UNDER THE GUIDANCE OF:

Prof. Shreya Madali

SUBMITTED BY:

BHAVYA DAYAL

SAP ID – 81022019085

ROLL NO. – A063

BBA LLB (Hons). 3rd Year

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Company Law I

DECLARATION
5
I declare that this is an original report of my research, has been written by me and has not been
submitted anywhere. The experimental work is almost entirely my own work; the collaborative
contributions have been indicated clearly and acknowledged. Due references have been
provided on all supporting literatures and resources. I declare that this research paper was
composed by myself, that the work contained herein is my own except where explicitly stated
otherwise in the text, and that this work has not been submitted for any other degree or
professional qualification.

Bhavya Dayal

Mumbai, Maharashtra

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Company Law I

ACKNOWLEGEMENT
3
I, Bhavya Dayal of B.B.A L.L.B (Hons.), third year student from Narsee Monjee Institute of
Management Studies (NMIMS) Navi Mumbai School of law and have conjointly worked
towards making this paper both meticulously and harmoniously.

Putting forth this research paper has taken me lot of sincere efforts and help and support of
other people. I want to sincerely thank our faculty of NMIMS Navi Mumbai, Prof. Shreya
Madali, who was not only supportive of our work, but also constantly pestered to move ahead
by doing numerous corrections in the paper and structure of the paper as a whole. Therefore, I
sincerely thank Prof. Shreya Madali for all her support and help.

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TABLE OF CONTENT

15
1. Abstract…………………………………………………………
2. Introduction……………………………………………….……
3. Literature Review........................................................................
4. Research Problem........................................................................
5. Objectives....................................................................................
6. Hypothesis………………………………………………….…..
7. Research Questions.....................................................................
8. Research Methodology................................................................
9. Case Analysis..............................................................................
10. Conclusion...................................................................................
11. References...................................................................................

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CHAPTER 1: ABSTRACT
11
When a company is formed, it is treated as a separate legal entity from its promoters, directors,
1
members, and employees, giving rise to the concept of the corporate veil, which separates these
parties from the corporate body. For many years, judges and academics have debated the issue
of "lifting the corporate veil." However, the issue has received little attention in the literature.
Because there is no defined set of standards in place, it is impossible to predict when the courts
1
will disregard the separate entity concept. According to the paper, many English corporate veil
cases take a similar analytical approach to the concept of instrumentality under Indian law. The
13
main aim of this paper is to study the doctrine in detail, compare it with the provisions as per
2
UK laws and its position in Indian law. In this paper, the authors seek to analyse the rule's
position under Indian law and discuss the statutory provisions of the Companies Act
2
2013 relating to corporate veil lifting. In addition, certain judicial pronouncements have been
discussed in this paper, which determine different cases in which the courts can lift the veil.

Keywords: Corporate Veil, Companies Act, Separate Entity, Company Law.

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CHAPTER 2: INTRODUCTION
Saloman v Saloman Co. Ltd established that a "company is a separate legal entity" with its own
2
identity that is independent and distinct from its members and shareholders. This is a well-
established principle recognised by many common and civil law countries around the world.
The case also states that once a company is incorporated, it becomes a 'artificial person' and
2
must be treated separately from its members. The company has its own set of rights and
2
obligations, as well as the ability to sue or be sued. This 'corporate personality' rule also
provides companies with the advantage of perpetual succession.

In accordance with the theory of perpetual succession, a company is solely dependent on itself
and survives longer than any of its members, i.e. "members may come and members may go,
but the company continues to remain until it is wound up by due procedure of law." It is
2
possible to assert that there is a'veil' that separates the company and its members. Members of
the company frequently abuse this corporate veil to commit fraudulent activities and to shield
themselves from any legal proceedings initiated against them for any wrongdoing. In such
cases, courts disregard the corporate personality of the corporate body and pierce through the
veil to identify and prosecute the actual perpetrators.
2
The courts' principle of "lifting the corporate veil" can be viewed as a "exception" to the
2
corporate personality rule of corporate law. Because corporate personality is the foundation of
a company, courts are frequently faced with a quandary when it comes to lifting the veil, as
misapplication of this rule may harm the company's business prospects and result in suboptimal
outcomes.

CHAPTER 3: LITERATURE REVIEW


1. Personality of public corporation and lifting the corporate veil, by Bahadur &
Krishna (1972)

The phrase "piercing the corporate veil" refers to a situation in which courts disregard limited
liability and hold shareholders or directors personally liable for a company's actions or debts.
1
Corporate veil penetration is common in closed companies. While state laws vary, courts
typically have a strong presumption against breaching the corporate veil and will do so only if
there has been significant wrongdoing. Courts recognise the benefits of limited liability because
it "promotes the establishment of public markets for stocks, enabling the liquidity and
1
diversification benefits that such markets provide those investors." Creditors typically have no

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Company Law I

1
recourse against corporate stockholders if certain conditions are met. When a company is
formed illegally in order to avoid liability, creditors may be able to see through the corporate
veil.

2. Piercing the corporate veil: Focussing the inquiry, By Cathy S. Krendl & James
R. krendl (1978)
1
In contrast to the individuals who comprise it, the legal personality conferred on a corporation
1
by legislation is arguably the most fundamental concept of company law and serves as a critical
1
building block of our economic and legal structures. However, the concept is not absolute:
courts have used their authority to disregard the company's distinct identity in order to treat it
as if it were one with its controller. However, the higher courts have only rarely defined the
1
basis for and scope of this authority. The article compares previous judicial assessments of
penetrating the corporate veil in England to the most recent approach to the same issue in Indian
courts.

3. Wedded to Salomon: Evasion, Concealment and confusion on piercing the veil of


the one – man company, By Hannigan & Brenda (2013)

In contrast to the individuals who comprise it, the legal personality conferred on a corporation
by legislation is arguably the most fundamental concept of company law and serves as a critical
1
building block of our economic and legal structures. However, the concept is not absolute:
courts have used their authority to disregard the company's distinct identity in order to treat it
as if it were one with its controller. However, the higher courts have only rarely defined the
1
basis for and scope of this authority. The article compares previous judicial assessments of
penetrating the corporate veil in England to the most recent approach to the same issue in Indian
1
courts. A court may breach the corporate veil to prevent the company or its controller from
benefiting from the firm's legal personality. However, this is only permissible in certain
1
circumstances. Even if the criteria are met in almost every case where it is applied, the
circumstances in practise reveal a legal link between the firm and its controller, so piercing the
corporation's veil isn't required.

4. Lifting the corporate veil, By P. M. Bakshi (1989)


1
Earlier in the year 1897, the legal world witnessed the House of Lords' literal interpretation of
1
the law, disregarding the notions of equity and fairness. However, the concept of lifting the
corporate veil entails moving the iron curtain a little to peer into the firm's backstage to see

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1
who's individuals behind the company and to also know about the true brains behind a
corporation. The paper discusses a variety of situations in which it is necessary to lift the iron
30 1
curtain in order to gain a better understanding of the purpose of a corporation's incarnation in
the first place. The theory of removing the corporate veil serves as a check on anyone seeking
to profit from their wrongdoing by hiding behind the firm, taking refuge, and engaging in acts
that the law otherwise prohibits. This paper attempts to describe how this concept has been
questioned while also contributing to the enrichment of jurisprudence. It also assesses the cases
1
in which lifting the veil is justified in order to achieve the goals of justice. Furthermore, this
article constructs an analysis from the doctrine's inception to its current form.

CHAPTER 4: RESEARCH PROBLEM


31
There has been little research into how the doctrine of piercing the corporate veil differs in
India and the United Kingdom. Few studies have looked into how this doctrine differs from the
corporate personality rule. This research also looks at how this doctrine is applied in Indian
law. This study focuses on all of these gaps, which, once identified, will aid companies and
researchers in future studies as well as when they are involved in legal battles.

CHAPTER 5: OBJECTIVE
21
This research paper expects to comprehend the Doctrine of Piercing the Corporate Veil. The
primary targets of the examination are –

2
 To study the doctrine as an exception to the corporate personality rule

 To compare the applicability of the doctrine in India and UK

 To learn the position of the doctrine in Indian law

1
CHAPTER 6: HYPOTHESIS
One of the fundamental concepts of corporate law is that the formation of a company under the
Companies Act creates a separate legal entity from its members. However, if it is discovered
that the company engaged in illegal activity or that its operations were not carried out in
accordance with the rules, the shareholders may be held personally liable and their personal
18
assets seized. What is the purpose of piercing the corporate veil?

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Company Law I

1
If a court pierces the corporate veil of a corporation or LLC, the owners, shareholders, or
members may be held personally liable for corporate obligations. Creditors may seize the
owners' primary residence, bank account, investments, and other property in order to pay the
corporate debt.

4
CHAPTER 7: RESEARCH QUESTIONS

Several questions pop up in our minds when we see cases where we read about Micro Finance
and its impact,

 What is Corporate Veil?


29
 What is the use of the Doctrine of piercing te corporate veil?
 How is it used differently in the UK?
 What is its position in India Law?

4
CHAPTER 8: RESEARCH METHODOLOGY

The research methodology used is secondary research, an approach which includes gathering
information from secondary sources such as academic papers, journals, and reports available
for public use both online and offline. Some of the sites which were used to compile this paper
4
are, the Research Gate, Manupatra, SCC, Mondaq, etc. Majority of the data is collected from
the internet, through multiple websites, research articles, papers, and channels, with the sources
being duly cited at the end. After data collection, it has been combined and collated in a
comprehensive and understandable format, to increase the overall effectiveness of this paper.

CHAPTER 9: CASE ANALYSIS


34
1. RATIONALE FOR LIFTING THE VEIL - AN EXCEPTION TO CORPORATE
PERSONALITY RULE.

The principle of a company's separate legal identity emerged following the landmark Saloman
case in England, and it was gradually accepted and recognised by common laws around the
2
world. In the landmark judgement of L.I.C India v Escorts Ltd. & Others3 (Hereinafter referred
to as the 'LIC Case,' the Hon'ble Supreme Court of India upheld the principles espoused in the
Saloman case, but also provided certain exceptions in which the rule of corporate personality
of a company can be ignored by the adjudicating authority, and the true perpetrator can be
recognised and penalised. Because the company and its members are distinct entities4, it is

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2
assumed that "a veil exists between the company and its members." This veil is frequently used
by company members to commit mischief or other fraudulent activities, as well as to protect
themselves from legal action. In such cases, the court has no choice but to lift the corporate
veil in order to identify the true member at fault. Once the court has lifted the veil and the true
perpetrator has been identified, the accused can be tried for his fraudulent activity or mischief
2
in accordance with the law.

The benefit of being recognised as a separate legal entity can only be retained by a company if
2
no fraudulent activity is taking place, or if the company is genuine and not a sham or an agency.
In the landmark decision of Littlewoods Mail Order Stores Ltd. v. IRC5, it was held that only
incorporation of a company does not cast a complete veil over the corporate personality of a
company limited by shares. A court can always pierce the veil and peer behind the mask to find
the true perpetrator hiding behind the veil. It was thus held in the case that, in general, a
company will be regarded as a separate legal entity; however, when this privilege of legal entity
is used to defeat the purpose of the same, the courts will disregard the notion of legal entity,
2 33
and the company will be treated as an association of members6. The court stated in United
States v. Milwaukee Refrigeration Transit Company7 that "a corporation will be regarded as a
legal entity as a general rule, but when the notion of legal entity is used to defeat public
convenience, justify wrong, protect fraud, or defend crime, the law will regard the corporation
as an association of persons."
2
The corporate veil piercing doctrine is an exception to the general principle of corporate
personality. The two primary reasons for the existence of such exceptions are that, first,
corporations cannot always be treated as separate legal persons or independent entities because
they are artificial persons, and thus incapable of committing any crime or tort because doing
2
so requires mens rea. As a result, courts must disregard the principle of corporate personality
2
in order to determine the true intentions of the company's members and directors. Second, if
the rule of separate legal personality is strictly and unambiguously applied, it is obvious that
interested members can always "hide" behind the veil of limited liability.

2. COMPARISION WITH UK
35 1
Indian Company Law evolved in the United Kingdom. The Companies Act of 1956 marked
the beginning of Company Law in our country. Many changes have occurred in the business
environment since then, and as a result of these changes, the Companies Act, 2013, was
enacted. In India, the Saloman principle is regarded as a fundamental principle of corporate

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1
law. This act also incorporates the corporate veil doctrine. Because the adoption of the
1
corporate veil doctrine had far-reaching consequences, it was felt necessary to limit its scope.
This was done to accommodate the corporate structure's complexity. The doctrine was
1
narrowed by modifying the Saloman principle. The corporate veil was decided to be pierced in
certain circumstances, and the shareholders or directors of the company could be held liable
and asked to share the company's liabilities.

The Saloman Principle has been applied in a number of cases in India. It has been used in
criminal, fraudulent, and constitutional cases. It has frequently been cited in taxation cases. The
1
Income Tax Act contains no express provision addressing the piercing of the corporate veil. In
India, the revenue authorities have allowed the courts to examine taxation cases through the
1
legal framework. One such case entered the picture in 2012. Vodafone International Holdings
B.V. v. Union of India was the case. The revenue authorities issued a show-cause notice to the
company in this case. They claimed that the transfer of 67 percent of an Indian entity as a result
1
of the purchase of shares in another offshore company would result in a capital gain tax of Rs
12000 crores. The company claims that because the company was formed in another country,
1
the revenue authorities lack jurisdiction to issue a tax demand. Multiple entities separated these
two parties, and the authorities wanted to ignore them all by focusing on only one motive:
attribution of one company's share as acquisition of another.
1
The veil piercing was permitted by the High Court. The case was heard by the Supreme Court,
and the decision of the High Court was reversed. According to Chief Justice Kapadia, foreign
investors enter India through foreign holding companies and SPVs that have been recognised
by Indian tax laws and corporate. The recognition of this practise provides some relief to
1
foreign investment firms. The majority believed that tax authorities would be permitted to
pierce the veil if they could demonstrate that the transaction in question was tax avoidant in
nature. According to the court, the revenue department must focus on the purpose of the
1
transaction while considering a number of indicators. As a result, the tax authorities' chances
of piercing the corporate veil are reduced. In conclusion, while the verdict in this case provides
1
some relief to foreign investors, it also provides ample opportunity for tax authorities to pierce
1
the veil in the future. Guidelines have been issued, and they can be applied to cases involving
foreign investors. The decision in this case should be remembered, and legal counsels must
ensure that transactions are structured in such a way that the client's interests are protected
while avoiding scrutiny from tax authorities.

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3. POSITION AS PER INDIAN LAW


32
The concept of a company's separate legal entity is also covered by the Fundamental Rights
enshrined in the Indian Constitution. In Chiranjitlal Chaudhary v. Association of India8, the
Supreme Court stated that the fundamental rights guaranteed by the Constitution are accessible
22
not only to individuals but also to corporate bodies. Article 21 states that no individual can be
deprived of his or her life or liberty except in accordance with legal procedures. A corporate
body has the right to individual life and liberty under Article 21, but in exceptional
circumstances, the same individuality privilege can be revoked using the legal procedure. In
10
the LIC Case, the Supreme Court of India enshrined such exceptions for disregarding the
10
concept of corporate personality and lifting the veil by tribunals. The circumstances in which
the Tribunal can lift the corporate veil have been broadly classified as "Statutory Provisions"
and "Judicial Interpretations."
25
a. Statutory Provisions

According to Section 2(60) of the Companies Act of 2013, "any officer or member of the
company who has committed any wrong or illegal offence shall be liable for punishment or
penalty in the form of imprisonment or fine, as prescribed by the law for that particular
offence." The section also specifies which portfolios will be held liable under the term "officer
in default." The Act does not specifically mention the provisions for 'lifting of corporate veil,'
but it has given courts and tribunals the authority to disregard the company's corporate
personality privilege in cases where any member of the organisation has committed any fraud
or mischief. According to Section 7(7) of the Act, "when a company has been incorporated by
furnishing false or incorrect information, or has actively concealed any material fact or
information or documents filed in the process of incorporating such company, using fraudulent
means and tactics, the tribunal has the power to take action and pass such orders, as it may
think fit for regulation of the company's management." The Tribunal may also direct that the
company's name be removed from the "register of companies," that it be wound up, or that any
26
other order be made in the best interests of the company, its members, and creditors. According
to Section 7(6) of the Act, if it is proven that the company provided false and incorrect
information during the incorporation process, or actively concealed or suppressed any vital
16
material fact or information fraudulently, the promoters, persons named as first directors of the
12
company, and persons making declaration under 7(1)(b) will be held liable under Section 447
of the Act. Section 447 establishes the penalties and punishments for any wrongdoing, fraud,

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or illegal activity committed by any person associated with the company. Criminal liabilities
for making false and misleading statements in a company's prospectus have been highlighted
in Section 34 of the Act, whereas Section 35 highlights civil liabilities that arise in the same
situation.

According to Section 248(2)18 of the Act, "a company may file an application to the Registrar
in the prescribed manner for the removal of the company's name from the register of companies
on all or any of the grounds specified in Section 248(1)19." However, a company can approach
the registrar only after it has discharged all of its liabilities and obtained the approval of 75%
of its members in terms of paid-up share capitals. If it is discovered that the application under
Sec. 248(2) was made solely with the intent of fraudulently escaping from the organization's
36
liabilities, defrauding any other individual, or deceiving its creditors, the officers in charge of
the company's administration will be jointly or severally liable for the same under Sec. 251,
and will be liable for the punishment of fraud under Sec. 447. The Registrar may recommend
that all individuals responsible for filing the fraud application be prosecuted.

Sec. 339 of the Act specifies liabilities arising from the company's fraudulent conduct of
business. When a company is winding up and it is discovered that the company conducted
14
certain business with the intent to defraud its creditors or any other person, or for any fraudulent
20
activity, the Tribunal has the authority to rule that any person who was a director, manager, or
officer of the company, or any other person who was involved in carrying out that particular
27
business, shall be personally liable, without any limitation of time.

b. Judicial Interpretations

There have been numerous instances where tribunals have used the theory of lifting the veil to
examine a company's corporate identity. It is a well-established principle that a company has a
17
distinct identity; however, when the company acts as an agent of its members and shareholders,
the members and shareholders are held personally liable for the organization's actions. As a
9
result, in each case, the courts must decide whether the company was acting as an agent or not.
If it is determined that the corporate has abused its privilege of separate identity and committed
37
any fraud or mischief, courts will pierce through the corporate veil to identify the true offender
24
and punish him in accordance with the law. In the interest of public policy, courts can lift the
veil to determine the true character and intent of the company. In the landmark Jyoti Limited
v. Kanwaljit Kaur Bhasin case, the Supreme Court of India applied this principle to examine

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Company Law I

the company's interests in a transactional deal, and determined that the company is liable for
9
contempt of court, and eventually the members were held liable.
12
Companies frequently use the corporate veil to avoid paying taxes. However, in such cases,
courts can infer the corporate substances to determine whether it was used for tax avoidance or
to conceal expense commitments. In the case Re: Dinshaw Maneckjee Petit, the Supreme Court
used this principle to lift the veil and investigate whether the company actively evaded taxes.
The Supreme Court ruled in Santanu Ray v. UOI that the veil can be pierced to determine
which of the directors was responsible for authorising the evasion of excise duty due to fraud
and active concealment or willful suppression of vital facts. The doctrine was applied by the
court in Re: R.G Films Ltd., and the company was found to be merely an agent of another
9
company. The Apex Court opined in The Workmen Employed in Associated Rubber Industries
Ltd., Bhavnagar v. The Associated Rubber Industries Ltd., Bhavnagar that a company's
commitment to any act in furtherance of avoiding welfare legislation will be a valid reason for
Courts to pierce the veil.
2 38
In all of the aforementioned cases, the courts used their judicial discretionary powers to pierce
the veil and discover the true intent and existence of the companies. However, in the landmark
19
decision of State of U.P. v. Renusagar Power Co., the Supreme Court explicitly stated that
28
courts should only lift the corporate veil in exceptional cases, as it is not a general settled rule.
The court should try to strike a balance between the flexibility of piercing the corporate veil
and the company's independent identity.

CHAPTER 10: CONCLUSION


Analyzing the statutes and judgments discussed in the paper, it is clear that there cannot be any
23
numerous clauses for the lifting of the corporate veil. Lifting the corporate veil is not a well-established
legal practise in India because there is no well-defined statute that specifies the conditions under which
2
the process should be initiated. In India, the rule of lifting the veil is very broad, and courts have broad
discretion as to whether or not to lift the veil. The rulings regarding the lifting of corporate veil can
neither be too lenient nor too stringent, as the extremes in both the cases can be detrimental for the
general public, hence courts have to tread carefully in this area of law. Though the principle is still an
evolving law in many jurisdictions, it has proven to be an excellent watchdog for businesses. However,
the principle should only be applied in exceptional circumstances.

As the preceding debate concludes, we can see that the United Kingdom and India have reached
1
essentially the same conclusion regarding this situation, taking into account both countries' histories
and the similarities of their respective legal systems. Focusing on the cases at hand, the Prest verdict,

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1
while consistent with the Salomon principle, may be considered unfair. In common law countries, the
Salomon case is followed and considered the Bible of all similar nature cases. It serves as the foundation
1
for all of their decisions. Every subsequent case has only built on the same foundation, which is an
excellent approach if the situation requires it, such as in civil law.
13 2
Article 21 of the constitution guarantees the right to life and liberty to corporations as well. The Courts
must resist the urge to lift the veil as a last resort. As rightly pointed out by the Apex Court in the
2
Balwant Rai Saluja & Anr. The corporate personality identity must be respected by the courts in the v.
2
Air India Ltd. & Anr case, and the principle must be applied in a restrictive manner, only in cases where
it is very clear that the company is a sham or a camouflage to avoid liabilities by the company owners.

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