Company election validity and interim injunction principles: documentary record sustained directors' prima facie title and blocked requisition-based displacement.

Minutes, scrutineers' report and statutory filings supported the annual general meeting election, attracting the Companies Act presumption that the meeting was duly called, held and conducted. The challenge that defeated candidates should be treated as elected merely because no votes were cast against them was rejected as unsustainable. A requisition under section 169 of the Companies Act, 1956, could not be used to dislodge directors already validly elected through the prescribed procedure. In the absence of contrary evidence rebutting the documentary record, the plaintiffs' election and right to act as directors stood on a strong prima facie footing, and civil court jurisdiction was not barred.

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Issues: Whether the plaintiffs established a prima facie case to sustain the interim injunction and whether the requisitioned extraordinary general meeting could be restrained on the footing that the plaintiffs' election as directors was validly completed.

Analysis: The election proceedings of the annual general meeting were supported by the minutes, the scrutineers' report, and the statutory filings, attracting the presumption under the Companies Act that the meeting was duly called, held, and its proceedings validly taken. The challenge that the defeated candidates should be treated as elected merely because no votes were cast against them was rejected as unsustainable. The Court further held that the requisition under section 169 of the Companies Act, 1956, could not be used to dislodge directors who had been validly elected through the prescribed procedure. In the absence of contrary evidence rebutting the documentary record, the plaintiffs' election and right to function as directors stood on a strong prima facie footing, and civil court jurisdiction was not barred.

Conclusion: The plaintiffs' case was upheld, the interim injunction was made absolute, and the applications seeking modification or vacation of the injunction failed.

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