Director disclosure compliance: a single complete return covering all alterations was sufficient to cure the statutory default.

A company's duty to keep an accurate register of directors and notify changes in their particulars was treated as satisfied by a single complete return covering all alterations since the last filing. The statutory requirement to use the prescribed form and include the particulars of all directors did not require separate forms for each change, because the operative obligation was to furnish the Registrar with correct information within the prescribed time. Where one filing conveyed the requisite details and made good the default, non-filing of multiple forms did not prevent compliance. The Court therefore accepted the single consolidated form as sufficient.

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Issues: Whether the company's filing of one form containing all alterations in the particulars of its directors was sufficient to make good the default under the statutory scheme, or whether separate forms were required for each change.

Analysis: The application sought to compel the company to make good its default in notifying changes in the particulars of its directors. The statutory scheme imposed an absolute duty to keep an accurate register of directors, to notify changes within the prescribed period, and to use the prescribed form for such return. The requirement that the form contain the particulars of all directors did not alter the substance of the obligation, which was to furnish the Registrar with correct information. A single complete form setting out all changes that had occurred since the last return satisfied the statutory requirement so far as the default could be rectified. The Court held that the failure to file multiple forms did not defeat compliance where one complete filing conveyed the requisite information.

Conclusion: Filing one form containing all the alterations was sufficient, and the applicant succeeded.

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