Electronic storage does not extinguish an inspection right
Rule 29 applies where a company maintains records electronically. A duty imposed by the Companies Act or its rules to permit inspection or provide copies is construed as a duty to permit electronic inspection or provide a clear reproduction of the whole or relevant part. The rule specifies payment not exceeding ₹10 per page. It does not create universal public access to every company file. Notified Companies (Management and Administration) Rules, 2014: Rule 29.
Resolve entitlement before opening the repository
Identify the record, requester’s capacity, underlying provision and any lawful restriction. Different registers, minutes and agreements can have different eligible requesters, access limits, timeframes and fee provisions. Rule 29 is the electronic delivery bridge; it does not make a Board record freely available to a person who lacks the underlying inspection right.
A fee ceiling is not an automatic tariff
Do not treat ₹10 as a compulsory fee where a lower lawful fee or free-copy entitlement applies. Check the record-specific provision, articles where relevant and request scope. The page ceiling is not a per-megabyte, per-file or per-download rule. Keep the fee working and actual payment evidence distinct from any separately applicable tax question.
Produce the relevant record clearly and securely
Scope the response to the lawful request while preserving substantive completeness, signatures, annexures and legibility. An encrypted or corrupted file that the entitled requester cannot read is not evidence of a clear reproduction merely because an email was sent. Use appropriate access controls and retain the request, entitlement assessment, page inventory, delivered version and acknowledgement. This article does not prescribe a universal password format, online portal or delivery deadline. The examples assume lawful paid-copy requests without a separate free entitlement.
Applicable primary references
Notified Companies (Management and Administration) Rules, 2014: Rule 29
Six worked illustrations
All facts and amounts below are fictional. Assumptions describe the model, not additional statutory rules.
Illustrative example 1: Ceiling calculation
A qualifying requested copy has 24 pages. At the Rule 29 ceiling, the maximum model copy fee is ₹240. This does not require charging the maximum.
Illustrative example 2: Lower applicable fee
Assume a lawful applicable fee of ₹6 per page for thirty pages. The fee is ₹180, compared with the ₹300 ceiling. The unused ₹120 headroom is not an additional charge.
Illustrative example 3: Requested part
A register has 120 pages, but the lawful request concerns a thirty-page part. The model ceiling for that part is ₹300, not ₹1,200 for the whole register: a ₹900 difference. Confirm the actual entitlement and scope.
Illustrative example 4: Excess page rate
For twenty paid-copy pages, an asserted ₹12 per page produces ₹240. The ₹10 ceiling gives ₹200; the excess page-fee component is ₹40. No separate tax treatment is assumed.
Illustrative example 5: Incomplete reproduction
A requested forty-page record is delivered with thirty-eight legible pages and two unreadable annexure pages. Legible coverage is 95%. That percentage does not establish a complete clear reproduction.
Illustrative example 6: Page count versus file count
A response contains three files with eight, twelve and five pages. Total pages are 25, giving a ceiling model of ₹250. Charging only by the three filenames does not follow the stated page unit.
Ten-step verification table
| Step | Action | Evidence |
|---|---|---|
| 1 | Identify requested record | Register, minutes or other statutory document. |
| 2 | Verify requester | Capacity and evidence. |
| 3 | Ground entitlement | Underlying Act or rule. |
| 4 | Check limitations | Lawful scope and exclusions. |
| 5 | Check time requirements | Record-specific deadline. |
| 6 | Inventory requested pages | Whole record or relevant part. |
| 7 | Determine fee | Lower/free rights and ceiling. |
| 8 | Prepare reproduction | Clear pages, signatures and annexures. |
| 9 | Deliver securely | Access appropriate to the entitled recipient. |
| 10 | Retain evidence | Request, fee working, delivered version and acknowledgement. |
Sixteen practitioner FAQs
1. When does Rule 29 operate?
Where company records are maintained electronically and an underlying inspection or copy duty exists.
2. Does it make every record public?
No. Establish the underlying entitlement.
3. Must electronic inspection remain possible?
The rule translates the existing duty into electronic inspection or the stated copy delivery.
4. Can the relevant part be reproduced?
The wording covers the whole or part, as applicable.
5. What page ceiling is stated?
Not exceeding ₹10 per page.
6. Is ₹10 always the mandatory fee?
No. Check any lower fee or free entitlement.
7. Can a free-copy right be displaced by the ceiling?
Do not use a ceiling to defeat the underlying right.
8. Is the unit megabytes?
The stated unit is pages.
9. Is every file necessarily one page?
No. Verify its actual page count.
10. Do all records have the same delivery deadline?
Check the record-specific provisions.
11. Does a requester automatically gain access to the entire repository?
No. Scope access to the lawful entitlement.
12. Is an unreadable attachment adequate merely because sent?
It does not demonstrate the clear reproduction required.
13. Why preserve annexures?
They can form a substantive part of the requested record.
14. Should a delivery record be retained?
Yes, as practical evidence of what was supplied.
15. Do the fee illustrations decide GST treatment?
No. Any applicable tax question is separate.
16. What closes the request file?
Entitlement, scope, correct fee, clear reproduction and delivery evidence.
Conclusion
Electronic storage preserves existing inspection and copy duties. Verify the requester’s right, requested scope, readable reproduction and applicable fee before delivery.