Letter No.6666/M1/2020-2 on virtual annual general meetings of registered societies
The Commercial Taxes and Registration (M1) Department, Secretariat, Chennai - 9, issued Letter No.6666/M1/2020-2 dated 27.10.2020, saying there is no bar under the Tamil Nadu Societies Registration Act, 1975 to hold an annual general meeting through virtual or electronic platforms such as video conferencing or other audio visual means. The Inspector General of Registration and the Registration Department then instructed District Registrars to allow registered societies to hold only the 2019-2020 annual general meeting online, subject to specific recording, access and verification conditions because of COVID-19 and lockdown restrictions.
What this document does
The Commercial Taxes and Registration (M1) Department, Secretariat, Chennai - 9, in Letter No.6666/M1/2020-2 dated 27.10.2020, clarified that the Tamil Nadu Societies Registration Act, 1975 does not require physical presence or a particular place for an annual general meeting. On that basis, the Government said there is no bar to conducting the annual general meeting through virtual or electronic platforms, including video conferencing and other audio visual means.
The Registration Department then sent instructions to all District Registrars through proceedings in Na.Ka.En.19919/A1/2020 dated 31.10.2020 and 07.11.2020.
Who it affects
This guidance affects registered societies in Tamil Nadu that could not convene annual general meetings because of COVID-19 spread and lockdown measures.
It also affects:
- District Registrars who were asked to grant permission
- society office bearers arranging the meeting
- members of societies who must be given access to attend the meeting online
What permission was allowed
The Registration Department stated that Registrars of Societies may permit societies requesting online meetings to conduct only the general body meeting for the year 2019-2020 through virtual means.
The source text says this permission was given only because of the then prevailing COVID-19 pandemic situation and to meet statutory requirements under the Tamil Nadu Societies Registration Act, 1975.
Key conditions for online meetings
Societies permitted to hold the meeting online had to follow these conditions:
- the entire meeting proceedings had to be video recorded
- the full proceedings had to be audio and video recorded without editing
- the unedited recording had to be stored in two DVDs
- those DVDs had to be submitted to the Registrar of Societies when filing the relevant records
- the society had to take proper verification and security measures so that impersonation did not happen
- for the general body meeting and election, the society administrators had to provide LOGIN ID, PASSWORD and LINK to all members of the society
- if complaints arose because this was not done, the society would be responsible, not the Registrar of Societies
Practical effect
For a society member, office bearer or adviser, this document is not a general permanent rule for all years. The Registration Department expressly limited the permission to the 2019-2020 financial year general body meeting held during the COVID-19 restrictions, and District Registrars were told to include all four guidelines when issuing permission letters.
This summary is generated from the source document to help you find what is relevant. The PDF above is authoritative. For advice on your own property, use LandLens One or speak to a qualified professional.
Common questions
Can a registered society in Tamil Nadu hold its annual general meeting online under this guidance?
Yes. The Commercial Taxes and Registration (M1) Department, Secretariat, Chennai - 9, said in Letter No.6666/M1/2020-2 dated 27.10.2020 that there is no bar to holding the annual general meeting through virtual or electronic platforms.
Was the online meeting permission given for all years?
No. The Registration Department said permission could be given only for the 2019-2020 general body meeting, and that too because of the COVID-19 pandemic and lockdown situation.
What records had to be submitted after an online society meeting?
The whole proceedings had to be recorded without editing in audio and video form, stored in two DVDs, and produced to the Registrar of Societies when the filing was made.
Who is responsible if some members do not get access to the online meeting?
The society administrators had to provide LOGIN ID, PASSWORD and LINK to all members. If complaints arose because this was not done, the society was responsible, and the Registrar of Societies was not.
