Gunjan Garg Holds More Shares Than CMD Outside Promoter List

Gunjan Garg holds 36,90,000 equity shares, 4,23,530 more than Chairman and Managing Director, or CMD, Subhash Agarwal’s 32,66,470 shares. The Red Herring Prospectus identifies Gunjan Garg as Head Human Resources and Subhash Agarwal’s daughter, while naming four other individuals, including Subhash Agarwal, as promoters.

Why does Gunjan Garg hold more shares than the CMD?

Gunjan Garg holds more shares than Subhash Agarwal because the prospectus separately reports Gunjan Garg’s 36,90,000 shares and Subhash Agarwal’s 32,66,470 shares in its key managerial personnel and senior management shareholding table. The table classifies Subhash Agarwal as key managerial personnel, or KMP, in his CMD role, while it classifies Gunjan Garg as senior management personnel, or SMP, and Head Human Resources.

The difference between Gunjan Garg’s and Subhash Agarwal’s disclosed holdings is 4,23,530 shares. Selvaraj Rangaswamy, the whole-time director, is reported with 46,18,650 shares, making his the largest holding among the 10 KMP and SMP entries. Seven entries, including Chief Financial Officer Lalit Kumar and Company Secretary and Compliance Officer Mauli Rushil Mehta, show nil shareholdings.

The disclosure separates employment status from formal promoter status. Gunjan Garg’s SMP classification describes her management role, whereas the promoter section identifies individuals formally designated as promoters in the Red Herring Prospectus. Holding more shares than Subhash Agarwal therefore does not itself make Gunjan Garg a named promoter.

Is Gunjan Garg on the four-person promoter list?

No. The Red Herring Prospectus names Subhash Agarwal, Selvaraj Rangaswamy, Anita Agarwal and Kanagalakshmi Selvaraj as the company’s four promoters. Those four promoters together hold 99,01,910 equity shares, representing 91.62% of the pre-issue paid-up equity share capital as of the prospectus date, and Gunjan Garg is not included in that named list.

The prospectus reports Gunjan Garg’s 36,90,000 shares in the KMP and SMP table, alongside her Head Human Resources position. In the separate promoter table, Subhash Agarwal holds 30.22% and Selvaraj Rangaswamy holds 42.74% of the pre-issued, subscribed and paid-up equity share capital. The different tables provide two distinct disclosure categories rather than a single designation for all shareholders.

The prospectus says the four listed individuals comprise the promoters as of its date. It says Subhash Agarwal, Selvaraj Rangaswamy and Anita Agarwal were the initial promoters, and that Kanagalakshmi Selvaraj was appointed as a promoter and director in 2025. It does not make an equivalent statement naming Gunjan Garg as a promoter.

How is Gunjan Garg connected to Subhash Agarwal?

Gunjan Garg is disclosed as Subhash Agarwal’s daughter in the relationship table covering KMP and SMP. The table identifies this as the relationship disclosed under Section 2(77) of the Companies Act, 2013, which addresses relatives for the stated management disclosures.

Gunjan Garg also appears in the promoter-group disclosure as a daughter of Subhash Agarwal. The prospectus says natural persons can form part of the promoter group under Regulation 2(1)(pp)(ii) of the Securities and Exchange Board of India Issue of Capital and Disclosure Requirements Regulations, or SEBI ICDR Regulations, because of their relationship with a promoter. Promoter-group status is disclosed separately from the four-person promoter list.

The supplied prospectus pages render Gunjan Garg’s name inconsistently in some narrative and promoter-group entries, while the KMP and SMP shareholding table records Gunjan Garg with 36,90,000 shares. The relationship table identifies the CMD’s daughter, and the management table identifies the Head Human Resources. These are the disclosures that connect Gunjan Garg’s employment role, family relationship and reported holding.

What is Gunjan Garg’s management role and pay?

Gunjan Garg is Head Human Resources and was promoted to that role on April 1, 2025. The prospectus says Gunjan Garg joined the company as Assistant Manager, commercial, in 2013, later moved into the human-resources function and has around 12 years of professional experience.

Gunjan Garg received a salary of Rs 24.02 lakh for the financial year ended March 31, 2026. That was above the Rs 20.61 lakh disclosed for Technical and Business Development Head Pushparajsingh Sisodiya and Rs 19.68 lakh for Sales and Marketing Head, Drives Division, Paresh Patil. The prospectus does not report a profit-sharing plan for KMP and SMP.

All KMP and SMP are described as permanent employees. The company says it has no employee stock option scheme, employee stock purchase scheme or similar scheme that gives equity-share options to employees. It also says no non-salary-related benefit was paid or given to KMP or SMP in the preceding two years, or is intended to be paid, other than in the ordinary course of employment.

What does this ownership split show about the promoter group?

The ownership split shows that the prospectus discloses substantial family shareholding outside the four-person named promoter list. Gunjan Garg is a promoter-group relative and SMP with 36,90,000 shares, while the four named promoters are reported with 99,01,910 shares, or 91.62% of pre-issue paid-up equity capital. The prospectus presents Gunjan Garg’s holding separately from the aggregate attributed to the named promoters.

The distinction separates formal promoter designation from family relationship and management employment. The prospectus states that promoters are interested in the company through promotion, their shareholding, directorships and distributions on shares, as well as to the extent of shares held by their relatives. It identifies Gunjan Garg as Subhash Agarwal’s daughter in the promoter group but identifies only four people as promoters.

The disclosure does not state why Gunjan Garg holds 36,90,000 shares or describe the acquisition of those shares in the supplied pages. It does establish that Gunjan Garg’s reported holding exceeds Subhash Agarwal’s reported holding by 4,23,530 shares. Any change in the distinction would require a later disclosure changing either the promoter list, the promoter-group disclosure or the shareholding figures.

Conclusion

Gunjan Garg’s 36,90,000-share holding exceeds Subhash Agarwal’s 32,66,470 shares even though Gunjan Garg is reported as Head Human Resources rather than as a named promoter. The prospectus places Gunjan Garg in the promoter group as Subhash Agarwal’s daughter, showing that family ownership disclosures and the four-person promoter designation do not fully overlap.

The next disclosed governance step is the application of the SEBI Prohibition of Insider Trading Regulations, 2015, upon listing of the equity shares on the SME Platform of BSE Limited. The company says its Board has adopted a code to regulate, monitor and report trading by employees and connected persons, with the Company Secretary and Compliance Officer responsible for procedures and monitoring under Board supervision.