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March 6, 2026
BSE Limited National Stock Exchange of India Limited
Phiroze Jeejeebhoy Towers, Exchange Plaza, Bandra Kurla Complex Bandra (E),
Dalal Street, Mumbai - 400 001 Mumbai-400051
BSE Scrip Code: 532692 NSE Symbol: RMCL
Subject: Reply to Common Queries Raised by BSE and NSE
Common queries raised by BSE Limited and National Stock Exchange of India Limited,
Accordingly, we hereby submit our consolidated response to all the common queries as under:
Queries Raised by Exchanges Our Reply
Company has not done The company was under the control of old management till
submission of compliances till October 22, 2020
from March 2015 till August
2022, which has resulted in non- The Company was admitted into Corporate Insolvency
compliance and penalties being Resolution Process (CIRP) on October 22, 2020.
levied.
From October 22, 2020 to August 01, 2022, the Company was
under the control and management of the Resolution
Professional pursuant to the initiation of CIRP under the
Insolvency and Bankruptcy Code, 2016.
Hon’ble NCLT vide order dated August 1, 2022 approved
Resolution plan submitted by the new management. (Now
company is in control of new management)
As per para no. 27 of the Hon’ble NCLT order dated August 1,
2022 is reproduced herein below:
“We hold that the Resolution Applicant cannot be saddled
with any previous claim against the Corporate Debtor prior
to initiation of its CIRP. For the permits, licenses, leases, or
any other statutory right vested in the Corporate Debtor
shall remain with the Corporate Debtor and for the
continuation of such statutory rights, the Resolution
Applicant has to approach the concerned statutory
authorities under relevant laws.”
As per chapter 7 (para no. 7.5) of the resolution plan is
reproduced herein below:
“It is assumed that all approvals, consents, licences, business
permits etc. given to the CD, including without limitation the
approvals provided to the CD by the relevant authorities of
State Government/Central Government shall continue to
remain valid and in force, post approval of this Resolution
Plan and in case for any reason they have been withdrawn /
cancelled before the effective date, such withdrawal I
cancellation of approvals, consents, licences, business
permits etc shall be treated as null and void and they will be
treated as valid and shall continue to be in-force. Further if
any such or further approval / sanctions / Certificate etc are
required for commencing the
production/manufacturing/business, the same shall be
treated as having been granted by the relevant competent
authority/relevant departments of State
Government/Central Government and all levies/charges /
penalty, if any will stand waived off on approval of the
Resolution plan”
The Hon’ble NCLT, vide its Order dated November 10, 2025,
has waived all penalties up to August 01, 2022 and has
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 cannot
do any filing prior to 2020 when the company was in control
of old management.
Also the new management cannot do any filing for the period
2020 till 2022 when the company was in control of Resolution
Professional.
A copy of the Hon’ble NCLT CIRP Order dated October 22,
2020 is annexed herewith and marked as Exhibit A.
A copy of the Hon’ble NCLT Order for approval of Resolution
plan dated August 1, 2022 is annexed herewith and marked as
Exhibit B.
Certified copy of Resolution Plan is annexed herewith and
marked as Exhibit C.
A copy of the Hon’ble NCLT Order dated November 10, 2025
is annexed herewith and marked as Exhibit D.
The Company has not complied The Hon’ble NCLT, Ahmedabad Bench, vide its Order dated
with the Regulations related to August 01, 2022, approved the Resolution Plan pursuant to
Corporate Governance which the Company reduced its existing share capital from
(Regulations 17 to 27). 9,12,95,775 equity shares to 6,82,185 equity shares.
As per the provisions of Regulation 15(2) of SEBI (LODR)
Regulations, 2015, the 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 the above threshold limits;
therefore, the provisions of Regulations 17 to 27 of SEBI
(LODR) Regulations, 2015 are not applicable to the Company.
Please note the company received temporary ISIN no.
INE172H01022 from NSDL and CDSL. However company is yet
to receive listing approval from BSE and NSE. Hence on both
the exchanges the old paid up capital is still reflecting.
Consolidated Financial Results The Company had informed both the Exchanges vide letter
not submitted for the quarter dated November 4, 2023 regarding the proposed acquisition
ended December 2025 (only of majority stake in Phytoatomy Private Limited.
standalone results received).
Further, vide update dated January 23, 2026, the Company
clarified that the proposed acquisition is still under process
and has not been completed, and accordingly, the Company
has not acquired any control or shareholding in Phytoatomy
Private Limited.
Therefore, the requirement for submission of consolidated
financial results under Regulation 33 of SEBI (LODR)
Regulations, 2015 is not applicable to the Company at
present.
The Company has consistently disclosed in its quarterly
financial results and in responses to queries raised by the
Exchanges that consolidated financial results are not
applicable in its case.
All the filings w.e.f. August 01, 2022 are in place and reflected on the BSE Portal. As a successful
Resolution Applicant, we cannot do any filing prior to August 01, 2022 as the Company was in
control of Resolution Professional.
Hence, we request you to withdraw the penalty levied by both the Exchanges.
Thanking You,
For RADHA MADHAV CORPORATION LIMITED
Nitin Jain
Director and CFO
(DIN: 09833381)
I ,f
, 'o
qoMPANY
tN THE NATION,AL IAYV TRIBUNAL
AHMEPAB.AD
ptvtsroN
<"f BENCH
couBT -
ITEM No.156
IA/78(AHM)2022 in
CP(IB) 669 of 2019
Prqcqesinpq un$ef Segtion 30J61 & 31 IFC'20:!B
IN THE MATTER OF:
Rajeev Dhingra RP of Radha Madhav corporation Ltd ........Applicant
Committee of Creditors & Ors ......,.Res pondents
gfde,r, deliUS:red qn-,01t /081?0??
Cotarn:
Madan B. Gosavi, Hon'ble Member(J)
Kaushalendra Kumar $ingh, Hon'ble Member(I)
PRESEIII.T:
Applicant
For the :
For the ResPondent :
ORPER
The case is fixed for prohu* ouncement of the order. The order is
pronounced in the oPen court, vide separate sheet.
.SD.
.SD-
KAUSHALENDRA KUMAR SINGH MADAN B GOSAVI
MEMBER (TECHNICAL) MEMBER {JUDICIAL}
BEFORT THE ADJUDICATII'IG AUTHORITY
1IIATIO1TAL COMPAI{Y LAST TRIBUIIIAL
AH1VIEDABAD BEI{CH
AHMEDASAD
couRT-1
IA I{o. 78 of 2022
CP lIBl I{o. 669 of 2O19
IA No. 78 of 2or22
application under Section 30(6] of the Insolvency and Bankruptcy
Code, 20 161
R4ieev Dhingra
Resolution Professional of
Radha Madhav Corporation Limited (In CIRP)
Having add.ress at:
BG 5A/488, DDA Flats, Paschim Vihar,
New Delhi - 110063
....Applicant
Versus
1. Committee of Creditors
A-27O, 1*t & 2'd Floor,
Defence Colony,
NewDelhi- 11OA24
2. Mitesh Anilkumar Agarural
Ex-Managing Director of Corporate Debtor
H.No. Is l728l 15,
Krtj,
Radha Madhav
Opposite Gem ?Laza,
Dunetha Na:ri Daman - 396210
IA 78 of 2a22 in CP {IB) 669 of 2019
3" Abhishek Agarwal
Ex-Joint Managing Director of corporate Debtor
H.No. L3 /728/ Ls,
Radha Madhav Kunj,
Opposite Gem Plaza,
Dunetha Nani Da:nan - 396210
4. Incoms Tax DePartment
Income Tax Office,
Vapi, 8th Floor, Fortune Square-Il,
Above TBZ, Chala,
Gujarat- 3961"91
.,..Respondents
CP (IBl lilo. 669 of 2O19
application und,er section 9 of the Insolvency and Bankruptcy
Cade, 20161
In thr? matter qfi
Mr. Ilarish Vedkumar Arrand
C-2O4, Kanti APts, Mount Mary Road,
Bandra (West),
Mr,rmbai - 4OOO5O
Applicant / OPerational Creditor
Versus
M/s. Radha Madhav CorPoration
Surwey No. 5019,
Adaman Indus
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