Choose the evidence route and the correct event
Section 83 of the Companies Act, 2013 lets the Registrar make an entry concerning a registered charge on satisfactory evidence even without company intimation. The statutory grounds include full or partial satisfaction of the secured debt and release of part of the charged property or undertaking, or that part ceasing to belong to the company. An internal ledger balance or request alone does not alter the public register.
Read the applicable text: Companies Act, 2013, sections 77, 79 and 81–83 Companies (Registration of Charges) Rules, 2014, rules 3, 6 and 8(2) 2018 amendment to the Companies (Registration of Charges) Rules, including rule 8(1).
Separate debt and collateral records
For payment or satisfaction, trace the facility terms, lender confirmation, repayments and any other legally effective discharge. For collateral release, identify the asset and the lender’s release terms. A sale or replacement of a charged asset does not establish free title or full satisfaction. Match the evidence to the charge ID and map the remaining assets, facilities and lenders separately. If the transaction modifies the terms, conditions, extent or operation of a registered charge, check the separate modification duty under sections 77 and 79 and the applicable CHG-1 or CHG-9 filing.
Distinguish section 83 from ordinary full satisfaction
Section 82(1) requires the company to intimate payment or satisfaction in full within 30 days. Its proviso allows the Registrar to permit filing by the company or charge holder within 300 days on payment of the prescribed additional fee. Rule 8(1) prescribes CHG-4 for full satisfaction. Section 82(4) preserves the Registrar’s separate power. Under Rule 8(2), where the Registrar enters a memorandum of full satisfaction under either section, the Registrar issues CHG-5. Do not treat partial release or repayment as that full satisfaction entry or assume an alternative route excuses an existing duty.
Verify the entry and notice from their own dates
Section 83(2) requires the Registrar to inform affected parties within 30 days of making the register entry. This is a Registrar notification period, distinct from the company’s filing duties. Retain proof of the actual entry and notification and use the exact recorded scope in lender and closing confirmations. Where the entry is missing or incomplete, seek clarification using the evidence trail rather than marking the whole facility discharged.
Six worked illustrations
All facts and amounts are fictional. Calculations illustrate the stated assumptions, not a predetermined legal outcome.
Illustrative example 1: Part payment leaves a balance
A registered charge secures a single facility with ₹1.20 crore debt. The lender confirms ₹45 lakh satisfied with no other adjustments. ₹75 lakh debt remains. The evidence supports a partial satisfaction review, not full satisfaction.
Illustrative example 2: Collateral release without repayment
A security schedule contains four assets with stated reference values of ₹30 lakh each. The lender releases one. Three assets, with reference value ₹90 lakh, remain in that schedule; debt of ₹70 lakh has not changed.
Illustrative example 3: One of two charges closes
Debt A of ₹40 lakh is discharged in full and debt B of ₹60 lakh remains under a different registered charge. The remaining debt total is ₹60 lakh; a full satisfaction entry and CHG-5 for A do not clear B.
Illustrative example 4: Multiple facilities within one charge
A single charge secures ₹35 lakh in facility X and ₹55 lakh in facility Y. X closes, but Y remains covered. On the assumed terms secured debt declines from ₹90 lakh to ₹55 lakh. Review partial satisfaction.
Illustrative example 5: Notice clock from register entry
Release evidence is dated 2 August 2026 and the Registrar makes the entry on 12 August 2026. The date 30 days after entry is 11 September 2026; counting from the evidence date would produce 1 September, ten days too early.
Illustrative example 6: Release recorded for only one lot
A lender letter covers lots with areas of 1,200 and 800 square metres, but the register entry identifies only the 800-square-metre lot. The unmatched area is 1,200 square metres. Resolve the discrepancy; do not report 2,000 square metres released in the register.
Ten-step verification table
| Step | Action | Evidence |
|---|---|---|
| 1 | Retrieve the registered charge | Charge ID and register extract. |
| 2 | Link the affected facility and lender | Charge instrument and facility matrix. |
| 3 | Classify the event | Full satisfaction, part satisfaction or release. |
| 4 | Trace debt movement | Lender evidence and ledger reconciliation. |
| 5 | Identify property remaining under charge | Asset schedule and release instrument. |
| 6 | Check section 82 duties separately | Applicable intimation record. |
| 7 | Provide evidence for Registrar review | Signed, indexed proof. |
| 8 | Verify the entry and its date | Register extract and wording. |
| 9 | Check affected-party notice and certificate | Notice evidence and CHG-5 for full satisfaction. |
| 10 | Reconcile records for closing | Lender, charge register and finance file. |
Sixteen practitioner FAQs
1. Can the Registrar act without company intimation?
Yes, on evidence satisfying section 83.
2. Does one repayment close the registered charge?
Only a full satisfaction finding can support a full satisfaction entry.
3. Can part of the security be released with no payment?
Yes. The property-release ground is separate from repayment.
4. Is a collateral valuation proof of release?
No. Establish the legal release and identify the asset.
5. Does an asset sale clear the charge automatically?
Do not assume it; review security terms and release evidence.
6. Does a zero balance in one facility close a cross-collateral charge?
Check every facility covered by the registered instrument.
7. What is CHG-4 used for here?
CHG-4 is used for full satisfaction under section 82 and rule 8(1). Track the statutory 30-day duty and any permitted late filing separately.
8. Is CHG-5 issued for a part-release entry?
Rule 8(2) addresses a memorandum of satisfaction in full.
9. Which date starts the section 83 notification period?
The date the Registrar makes the entry.
10. Who must inform affected parties under section 83(2)?
The Registrar.
11. Does the notice period set the company’s CHG-4 deadline?
No. Track those obligations separately.
12. What if the lender’s letter lacks the charge number?
Map the letter to the instrument and confirm identity before submission.
13. May one bank letter cover several charge IDs?
Use it only to the extent its scope and supporting records establish each charge.
14. Is the register entry the same as proof of contractual discharge?
Preserve both the legal release evidence and the public entry.
15. Can a section 83 request guarantee an entry?
No. The evidence must satisfy the Registrar.
16. How should a partial release be reflected in diligence?
State the exact entry and identify the balance and property that remain covered.
Official sources
Companies Act, 2013, sections 77, 79 and 81–83 Companies (Registration of Charges) Rules, 2014, rules 3, 6 and 8(2) 2018 amendment to the Companies (Registration of Charges) Rules, including rule 8(1)