the Supreme Court pointed out why it is necessary that only an individual should be
director of a company. It was held that the office of director being to some extent an office of trust, there should be somebody readily available who can be
held responsible for the failure to carry out the trust, and it might be difficult to fix that responsibility if the director was a corporation or an association of
persons.
The aforesaid requirement that only individuals should be appointed as directors does not extend to deemed directors coming within the provisions of
Section 7 of the Companies Act, for instance, a holding company will be deemed to be a director for purposes of Section 7, as all or the majority of the
directors of a subsidiary company are accustomed to act according to its directions:
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