Sunday, 3 January 2016

What is the Role of Liquidators ? Kenyan Insolvency Law

ROLE OF LIQUIDATORS
A liquidator is just like a bankruptcy trustee. A liquidator is basically a specially appointed officer whose work is to wind up the affairs of the company[1]. They are often used when a company goes bankrupt[2]. A liquidator is responsible for collecting all the assets of a company and settling all claims against the company[3]. They can be appointed by creditors, shareholders or by a court order[4]
So what exactly are the general roles of liquidator’s as provided under the insolvency Act 2015?
In the event of a voluntary liquidation, the liquidator may exercise the court powers of settling a list of contributories[5], make calls on unpaid shares[6], Convene general meetings[7] and pay companies debts[8].
In the event of a creditor’s voluntary liquidation, the liquidator is to assume all control of the company’s assets[9], dispose of perishable goods that may diminish in value[10] and take any action necessary to protect the company’s assets[11]
The liquidator is entitled to distribute assets to the payment of creditors[12]. They also have the power to dispose of onerous property this is property that has no net value for example it includes an unprofitable contract and unsaleable property[13]. Further they may transfer company assets to employees[14].
The liquidator must lodge from time to time reports to the registrar of companies with regards to the state of liquidation[15].
The liquidator may pay any class of creditors in full[16], they can make any compromise or arrangement with creditors[17]. He/she has power to borrow money for the beneficial realization of the company's assets[18]. The liquidator has power to defend and bring a suit in the company’s name[19] and carry out company’s business so long as is necessary for a beneficial liquidation[20].
The liquidator can without seeking approval, sell any of the company's property[21] and lastly the liquidator has the power to appoint an agent to carry out business which he/she is unable to do[22]
DISSOLUTION OF COMPANIES AFTER LIQUIDATION[23].
        i.            Voluntary liquidation.
This only applies to a company whose final accounts and returns[24] have been lodged with the registrar[25] by the liquidator[26].  The registrar shall register them and the company shall be dissolved within three months of registration[27]. The court has discretion to alter the date of dissolution to a later one on the application of the liquidator or any other person with locus standi, in such a case a copy of the application shall then be lodged with the registrar within seven days of the order of registration[28].   Failure of lodging a copy of the order with the registrar is an offence that attracts a fine or not exceeding Ksh. 2000[29]. Continuance failure of registration attracts a daily penalty of a fine not exceeding Ksh. 2000 for each day[30]. The importance of lodging the copy with the registrar is for the formality of registration as well as availing the document to the public for inspection upon payment of a certain amount[31].
      ii.            Early dissolution of a company.
This is essentially compulsory liquidation of a company. This occurs once the court makes an order for the dissolution of a company and the liquidator becomes the official receiver[32]. An application of dissolution is then made by the official receiver to the registrar if satisfied that the realisable assets of the company are insufficient to cover the expense of the liquidation as well as the assessment that the affairs of the company do not require further investigation[33]. In practice this is normally accompanied with the public interest question. The intention to make this application for early liquidation should be notified to the creditors and contributories of the company; this is the final duty of the official receiver and no other obligation may be imposed on him or her[34]. The registrar then registers the application within 30 days of receiving it and the company is then considered dissolved[35].
Consequence of the notice given by the Official Receiver to creditors and contributories of the Company.
The official receiver, creditors and contributories of the company may apply to the Court for direction upon receiving notice of intention to dissolve the company[36]. The direction being sought is either to invalidate the notice or defer the date of dissolution[37]. The application shall be based on grounds that dispute the condition of application by the official receiver; that is that realisable assets of the company are sufficient to cover the expenses of liquidation and that the affairs of the company do require further investigation or any other reasonable ground that would make the dissolution inappropriate[38].  The applicant who receives the direction must lodge it with the registrar within 7 days of the order failure of which attracts a penalty of Ksh. 2000 and a daily penalty of the same amount of the failure persists[39].
    iii.            Dissolution otherwise than voluntary or early dissolution.
This is a notice served for the purpose of removal of the Official receiver[40] or by the Official receiver that liquidation of the company by the court is complete[41]. This shall be then lodged with the registrar within 30 days of making of the order. An application to alter this may be made by a person with locus standi and who must file any order arising from this application within seven days failure of which result in an offence similar to the one for voluntary or early dissolution[42].
OFFENCES RELATING TO CONDUCT BEFORE AND DURING LIQUIDATION
The Insolvency Act 2015 (Division 10, sections 498- 510) provides for certain offences that are subject to criminal proceedings that may arise in the course of dealing with liquidators. This may be before or during the process of liquidation. The parties that may be liable for such offences according to the Act are: An officer or former officer of a company that is in liquidation, a person who is or has acted as a liquidator of such a company, a person who has been concerned in the promotion, formation or management of such a company. The offences highlighted are as follows:
a)      Offences Involving Commission of Fraudulent Acts in Anticipation of Liquidation
This offence covers fraudulent acts ranging from concealing any part of a company’s property, to concealing, destroying, mutilating, or falsifying any document affecting or relating to the company’s affairs or property. This is as regards the twelve month duration immediately preceding the commencement of liquidation of the company.
b)      Offences Involving Transactions to Defraud Creditors of a Company in Liquidation
Liability under this offence entails the following acts where an officer: 
(i) Has made or caused to be made a gift or transfer of, or charge on, or has caused or connived at the levying of execution against, the company's property; or
(ii) Has concealed or removed any part of the company's property since, or within the two months preceding, the date of any unsatisfied judgment or order for the payment of money obtained against the company
      (c)  Offences Involving Misconduct Committed in the Course of Liquidation of a Company
(d)   Offence to Falsify Documents in Relation to a Company in Liquidation
(e)    Offence to Make Material Omission from Statement Relating to Financial Position of Company in Liquidation
(f)    Offence to Make False Representations to Creditors of Company in Liquidation

Furthermore, the Act provides for certain powers of the court to make orders: against delinquent directors, officers of the company and others found to have participated in fraudulent trading by companies in liquidation among others. The court may order the aforementioned to repay, restore or account for the money, property or any part of it with interest at a rate of the courts choice.
On the discovery of any of the mentioned offences, the Act provides for the liquidator to apply for an order causing such persons to be disqualified from: Acting as a director of a company or as a partner in a limited liability partnership, being/acting as a liquidator of a company or limited liability partnership, being /acting as a supervisor of a voluntary arrangement approved by a company or a limited liability partnership or even in any way directly or indirectly being concerned in the promotion, formation or management of a company.
It is important to note that the defenses available to those accused of involvement in the aforementioned offences are: To prove that the accused had no intention to defraud or to prove that the accused had no intent to conceal the state of affairs of the company or to defeat the law.
LIQUIDATION OF UNREGISTERED COMPANIES
Meaning of an Unregistered Company
An unregistered company includes any company other than a company registered in the Companies Act 2015.[43] An unregistered company may be liquidated as a registered company that is through compulsory liquidation otherwise liquidation by court order.[44] However voluntary liquidation as in the cased of liquidation of registered companies does not apply to unregistered companies.[45]
Circumstances under which an unregistered can be liquidated
An unregistered company can be liquidated in the following scenarios[46]:
1.      Where the company has been dissolved, ceased to carry on business or is carrying on business only for the purpose of liquidating its affairs.
2.      If the company is unable to pay its debts
3.      If the Court is of the opinion that it is just and equitable for the company to be liquidated.
Situations in which an unregistered company is unable to pay its debts[47]
1.      If there is a creditor to which the company owes an amount exceeding Ksh. 75,000 and the creditor has served in the appropriate manner recognized under the law, a written demand requiring the company to pay the amount due and the company has failed to pay, secure or compound the amount to the creditor’s satisfaction within 21 days after notice was served. The amount, 75,000, is subject alteration by increase or decrease as per the insolvency regulations. However no alteration affects any case determined before the alteration took effect.[48]
2.      An unregistered company is also unable to pay its debts if legal proceedings have been brought against any member of the company for the a debt or demand due or claimed to be due from the company and notice of the bringing of proceedings have been served and 21 days after service, the company has not paid, secured or compounded for the debt or demand, obtained a stay to the proceedings or indemnified the defendant to the defendant’s reasonable satisfaction against the proceedings or any costs incurred by him or her in relation to the debt.[49]
3.      If under a judgment, decree or order by a court an execution or other process is issued in favor of the creditor against the company or any of its members and such judgment, order or decree is returned unsatisfied or if it is proved to the Court that the company is unable to pay its debts as they fall due.[50]
4.      If it is proved to the satisfaction of the court that the value of the company’s assets is less than the amount of its liabilities taking into account its contingent and prospective liabilities.
Companies incorporated outside Kenya.[51]
If a company incorporated outside Kenya carries on business in Kenya and has ceased to carry on business in the country where it was registered/ incorporated, it can be liquidated as an unregistered company under the Insolvency Act 2015. This provision also applies where the company has been dissolved or ceased to exist in the country in which it was incorporated.
Contributories in liquidation of unregistered companies.[52]
A contributory is each person who is liable to pay or contribute to the payment of;
1.      Any debt or liability of the company
2.      Any amount for the adjustment of the rights of members among themselves
3.      Expenses of liquidating of the company
Each contributory is liable to contribute to the company’s assets all due from them in respect of their liability.
Power of the Court to stay or restrain proceedings.[53]
A creditor may make an application to stay or restrain legal proceedings against a contributory of an unregistered company after the application for liquidation has been made but before the making of a liquidation order is extended by the Court.
Actions stayed on Liquidation order.[54]
Once a liquidation order has been made, no legal proceedings may be begun or continued against a contributory in respect of any debt of the company except by the approval of and subject to the terms of the court.
Conclusion: Cumulative Provisions.[55]
The provisions of the Act on liquidation of an unregistered company are cumulative or in addition to those on liquidation of registered companies by court order(compulsory liquidation). Furthermore, a court liquidator may exercise e his or her powers in liquidating unregistered companies as he or she would in liquidation of registered companies.


[2] Ibid
[4] Ibid
[5] Sec 462(4)(a) Insolvency Act 2015
[6] Sec 462(4)(b) Insolvency Act 2015
[7] Sec 462(4)(c) Insolvency Act 2015
[8] Sec 462(5) Insolvency Act 2015
[9] Sec 463(2)(a) Insolvency Act 2015
[10] Sec 463(2)(b) Insolvency Act 2015
[11] Sec 463(2)(c) Insolvency Act 2015
[12] Sec 471(1) Insolvency Act 2015
[13] Sec 476(1) Insolvency Act 2015
[14] Sec 484 Insolvency Act 2015
[15] Sec 489 Insolvency Act 2015
[16] Third Schedule Part 1(1) Insolvency Act 2015
[17] Third Schedule Part 1(2) Insolvency Act 2015
[18] Third Schedule 4(1) Insolvency Act 2015
[19] Third Schedule part 2(6) Insolvency Act 2015
[20] Third Schedule part 2(7) Insolvency Act 2015
[21] Third Schedule part 3(8) Insolvency Act 2015
[22] Third Schedule part 3(13) Insolvency Act 2015
[23] Divison 9, Insolvency Act, 2015, Kenya.
[24] See section 402 0r 414 of the Insolvency Act 2015.
[25] The registrar in this case is the registrar of companies within the meaning of the Companies Act, Cap 468 of the Laws of Kenya.
[26] Insolvency Act of Kenya,2015; Section 494  (1).
[27] Ibid section 494 (2) read together with (3).
[28] Ibid section 494 (4) read together with (5).
[29] Ibid section 494 (6).
[30] bid section 494 (7).
[31] Companies Act, Cap 468 of the Laws of Kenya.
[32] The insolvency Act of Kenya, 2015; section 495 (1).
[33] Ibid section 495 (2).
[34] Ibid section 495 (3) read together with (4).
[35] Ibid section 495 (5) read together with (6).
[36] Ibid section 496 (1).
[37] bid section 496 (3).
[38] bid section 496 (2).
[39] bid section 496 (4) read together with (5) and (6).
[40] Ibid section 468 (9).
[41] Ibid section  497 (1).
[42] Ibid section  497 (2), (3), (4), (5), (6).
[43] Insolvency Act 2015 Part VII s. 512
[44] Insolvency Act 2015 s. 513
[45] Ibid s. 512(2)
[46] Ibid s.514(1)
[47] Ibid s. 514(2)
[48] Ibid s. 514(3)
[49] Ibid s.514(4)
[50] Ibid s.514(5)
[51] Ibid s.515
[52] Ibid s.516
[53] Ibid s.517
[54] Ibid s.518
[55] Ibid s.519

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