Kenya company law: Restriction of appointment of directors of a company

There are various restrictions which the Companys Act imposes on appointment of directors and these restrictions must be fulfilled for one to be appointed as director.

(1)        Appointment by Articles

Section 182(1) states that a person shall not be capable of being appointed director of a company by the articles unless, before registration of the articles, he has signed and delivered to the registrar for registration a consent in wanting to act as a director and either: -
(a)     signed the memorandum for a number of shares not less than his qualification shares, or
(b)    taken from the company and paid or agreed to pay for his qualification shares
(c)     Signed and delivered to the registrar for the registration, an undertaking in writing to take from the company and pay for his qualification shares.

These provisions do not apply to: -
(a)    A company without share capital.
(b)    A private company.
(c)    A company which was a private company before becoming a public company.

(2)        Qualification Shares

Under Section 183 (1), it shall be the duty of every director who is by the articles of the company required to hold a specified share qualification and who is not qualified to obtain his qualification within 2 months after his appointment or within the shorter time as fixed by the articles.

Section 183(3) provides that the director shall vacate office if he fails to obtain his share qualification or ceases to hold the required number of shares

Case: R vs. Camps (1962) Court of Appeal for E.A.
The respondent, in his capacity as a director of a company, had been charged with several offences under the companies Act.  Although the directors of the company had under article 96 of the company’s articles of association duly appointed him to be the director and he had acted as such, he never acquired the required share qualification but in a statutory return, subsequent to his appointment, he was shown as a director which was fixed at one fully paid up share in his own right.

Article 87 which agrees with the terms of section 183(1) of the Act provided that the office of the director shall be vacated if a director ceased to hold the number of shares required to qualify him for office or fails to acquire the same within 2 months after his appointment.

The court held that as the respondent had never possessed or acquired his qualifying share, his appointment was invalid and that there were no cases for him to answer.

It was also held that the respondent was never even a de facto director and that in any event a de facto director was not criminally liable as a director under the Company’s Act. 

Against that decision, the Attorney General appealed to the High Court and the case was dismissed but on further appeal, the High Court held that: -
(i)                 The word “director” in the Company’s Act includes a de facto director.
(ii)               The respondent was duly and validly appointed a de jure director but he ceased to be a de jure director two months later as he failed to acquire his share qualification within that time.
(iii)             If the respondent acted as a director after the expiration of two months from his appointment, he was then a de facto director and he was a director for the purpose of those sections of the Company’s Act which it was alleged he had contravened. 
“Appeal allowed, acquittal set aside”.

Therefore if a director does not vacate office but continues to act as a director, he ceases to be a de jure director and becomes a de facto director.  Under Section 183(4), a de facto director is incapable of being reappointed director of the company until he has obtained his qualification shares and under Section 183(5), he is liable to a fine not exceeding one hundred shilling for everyday that he acts as a director of the company.

(3)        Age Limit

Section 186 provides that no person shall be capable of being appointed a director if at the time of his appointment: -
(a)    He has not attained the age of 21.
(b)    He has attained the age of 70.
 This provision does not apply if the company’s articles provide otherwise or a special notice of the resolution was given to the company.

Section 142 defines “special notice” as a notice given to the company not less than 28 days before the meeting at which the relevant resolutions are to be moved.

(4)        Undischarged Bankrupts

Section 188 provides that if a person who has been declared bankrupt or insolvent by a competent court and who has not received his discharge, acts as a director of any company, shall be liable to imprisonment for a term not exceeding 2 years or to a fine not exceeding Sh. 10,000 or both.

(5)        Fraudulent Persons

Section 189(1) empowers the court to make an order restraining a person from being appointed, or act as a company’s director for a period not exceeding 5 years if: -
(a)    The person is convicted of any offence in connection with the promotion, formation or management of the company, or
(b)    in course of winding up, it appears that the person had been guilty of fraudulent trading.

(6)        Individual Voting

Section 184(1) provides that the appointment of directors of a company which is not a private company is to be voted on individually, unless a motion for the appointment of the two or more persons as directors by a single resolution was agreed upon by the meeting without any vote against it.

A resolution moved in contravention of this provision is void under Section 184(2) even if no objection is moved.  The aim of this provision is to prevent a company’s members being virtually forced to vote for directors who they do not want.