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M/S Meena Steels Limited vs. Punjab National Bank

Writ Petition (Civil) · 2026:DHC:8899Decided 8 Oct 2026New Delhi Bench
W.P.(C) 6329/2017CNR: DLHC013265982017
Justice Rajneesh Kumar Gupta

Background

Meena Steels had reduced its share capital years earlier and was required to refund amounts to ex-shareholders through an escrow account maintained with Punjab National Bank. The Bank filed a review petition against a 2026 order that had directed it to transfer the remaining escrow balance to a separate account in the company's name, arguing that under Section 125(2)(h) of the Companies Act, 2013, unclaimed refund money older than seven years had to go to the government's Investor Education and Protection Fund (IEPF) instead.

Decision Breakdown

The Court held that Section 125(2)(h) applies to money received by a company for allotment of securities, not to a refund arising from a court-sanctioned reduction of share capital, so the Bank's reliance on it was misplaced. Since the earlier orders had already been passed after considering the material on record and no error apparent on the face of the record was shown, the Court found no ground for review and dismissed the Bank's petition.

Lesson Learnt

A review petition is not a second chance to re-argue a case: it succeeds only where there is a genuine error apparent on the record, and a party cannot avoid complying with a specific court direction by invoking a statutory provision that does not actually cover the situation.

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