NARESH CHANDRA SANYAL vs CALCUTTA STOCK EXCHANGE ASSOCIATION LTD.

The Supreme Court held that under the articles of association of the Calcutta Stock Exchange Association Ltd., a member can be declared a defaulter and have their shares forfeited without the necessity of both a defaulter declaration and expulsion resolution being passed. The Court clarified that the forfeiture of shares is valid under Regulation 24 of the Companies Act, 1913, even for fully paid shares, and the proceeds from the sale of forfeited shares must be used to satisfy the member's debts to the Exchange. The appellant's challenge against the forfeiture was dismissed, affirming the legality of the Exchange's actions.