Registrar's conclusive certificate protected a charge from challenge despite inaccurate dating and late registration allegations.

Where the Companies Act made the registrar's certificate conclusive evidence that registration requirements had been complied with, the certificate could not be challenged by showing that the charge particulars misstated the true date of creation or that registration was in fact outside the statutory 21-day period. The court treated the time limit as within the scope of the certificate's conclusiveness and held that earlier errors in dating or particulars did not undermine the security. It also held that the maxim against taking advantage of one's own wrong did not defeat reliance on the certificate absent fraud or proved prejudice, and that rectification provisions did not authorise deletion of the whole registration.

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Issues: (i) Whether the registrar's certificate under section 98(2) of the Companies Act, 1948 was conclusive despite the charge being dated and registered on a basis which, in fact, placed the registration outside the 21-day period under section 95; (ii) whether the bank could be denied reliance on the certificate on the ground that it would be taking advantage of its own wrong, or whether rectification under section 101 could nullify the registration.

Issue (i): Whether the registrar's certificate under section 98(2) of the Companies Act, 1948 was conclusive despite the charge being dated and registered on a basis which, in fact, placed the registration outside the 21-day period under section 95.

Analysis: Section 95 required particulars of a company charge to be delivered within 21 days after creation, and section 98(2) provided that the registrar's certificate is conclusive evidence that the requirements of the Part as to registration have been complied with. The Court held that the time requirement was not excluded from the scope of that conclusiveness. Earlier authorities on defective particulars and incorrect statements in the register showed that once the registrar issued the certificate, the validity of the security could not be impeached by proving that the particulars were in fact inaccurate or that the charge was, in truth, out of time.

Conclusion: The certificate was conclusive, and the charge could not be avoided merely by showing that the particulars understated the true date of creation.

Issue (ii): Whether the bank could be denied reliance on the certificate on the ground that it would be taking advantage of its own wrong, or whether rectification under section 101 could nullify the registration.

Analysis: The maxim against taking advantage of one's own wrong was held inapplicable because the alleged wrong was, at most, an honest mistake in dating the charge and did not establish a breach of duty to the liquidator or creditors who were shown to have been misled. Section 101 was also held not to authorise deletion of the whole registration; at most it permitted correction of an omission or mis-statement. Those points did not displace the statutory effect of the registrar's certificate.

Conclusion: The bank was entitled to rely on the certificate, and neither the maxim nor section 101 defeated its security.

Final Conclusion: The charge remained a valid security against the liquidator, and the appeal succeeded.

Ratio Decidendi: Where the statute makes the registrar's certificate conclusive evidence of compliance with the requirements as to registration, the security cannot be impeached by proving that the particulars were wrong or that the charge was in fact registered out of time, absent fraud or a statutory basis for setting aside the registration.

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