The provisions re the exercise of rectificatory powers of a Board/Company Court under S. 38 of the Companies Act, 1913, then under S. 155 of the 1956 Act, followed by S. 111-A introduced by the 1996 Amendment to the 1956 Act, and finally, S. 59 of the 2013 Act, held, demonstrate that its essential ingredients have remained the same, and it is a summary power to carry out corrections or rectifications in the register of members. Held, the rectification must relate to and be confined to the facts that are evident and need no serious enquiry. Further, in a case of violation of the SEBI Regulations, CLB cannot exercise rectificatory jurisdiction unless and until SEBI, in the very first instance, decides if there has been a violation or not.
[IFB Agro Industries Ltd. v. SICGIL India Ltd., (2023) 4 SCC 209]