Which of the following is not ‘Voluntary Liquidation’ of a company?

Correct option is C

Voluntary liquidation (also called voluntary winding up) takes place when the members themselves decide to wind up the company. As per the Companies Act, voluntary winding up occurs when:
1. The period fixed for the company’s duration expires
2. A specific event occurs as per Articles requiring dissolution
3. The company passes a special/ordinary resolution to wind up
Thus, options (a), (b), and (d) fall under voluntary liquidation.
However, when membership falls below the statutory minimum, it becomes a case of compulsory winding up by the Tribunal, not voluntary. Statutory minimum membership requirements:
· Public Company → Minimum 7 (old Act) / 2 members continuing under new rules for conversion
· Private Company → Minimum 2 members
If membership drops below the statutory requirement and remains so, it becomes a ground for Tribunal-ordered winding up, not voluntary winding up.
Hence, the correct answer is: Option (c) is NOT voluntary liquidation.