# Verification record — `in/kl/registration/partnership-firm-registration` v0.1.0 This file is the **source-review record** for this document version, per the [`manual-source-review-v1`](../../../../../../practices/manual-source-review-v1.md) practice. ## Current claim - **`status`:** `draft` - **`verification.method`:** `manual-source-review-v1` - **`verification.lastVerifiedAt`:** `2026-07-09` The document was derived directly from Kerala's Registration Department's own published Form I PDF, cross-read against the central Indian Partnership Act, 1932's own text (Sections 4, 30, 58, 59, 71) fetched live from indiacode.nic.in, and against the Kerala Partnership (Registration of Firms) Rules, 1959. It remains `draft`, not `verified`. ## Candidate screening this cycle This closes the India half of CATALOG.md's own Known Gaps section item 1 ("sub-national/state ... Business Formation expansion" flagged open for CA/NZ/IE/IN sole-trader/partnership/LLP formation). Ontario's own sole-trader and general/limited-partnership halves of the same gap were closed in prior cycles (GOV-1947, GOV-1953). This cycle targets India's share: "Form I", the Indian Partnership Act's own statutory partnership registration application (Section 58), located as published directly by Kerala's Registration Department. ## Sources examined - **Document `(id, version)`:** `in/kl/registration/partnership-firm-registration` / `0.1.0` - **Spec version:** GovSchema `0.3.0` - **Authority:** Registration Department, Government of Kerala — the Inspector General of Registration (IGR) acts as Registrar of Firms under the Indian Partnership Act, 1932 for the State of Kerala. (fetched directly, HTTP 200; confirms "In these rules, 'Registrar' means the Registrar of Firms" and the IGR's role and contact details, and lists "Partnership firms" among the department's registration services). - **Primary source (the form itself):** Form I, "See rules 3", THE INDIAN PARTNERSHIP ACT 1932, APPLICATION FOR REGISTRATION OF FIRM — — a static, two-page, non-fillable PDF (no AcroForm/XFA layer; confirmed by `pdfjs-dist`'s `getTextContent()` returning ordinary positioned text runs, not form-field objects). - **Fetch method and the legacy-TLS workaround (important for re-verification):** a direct fetch to `keralaregistration.gov.in` fails with a legacy-TLS error (`SSL routines::dh key too small`) — the server offers only a weak/legacy DH key exchange, not a bot/CAPTCHA/WAF gate. Two workarounds were used and confirmed this cycle: - `curl`: `curl -sk --ciphers 'DEFAULT@SECLEVEL=1' -A "Mozilla/5.0" "https://keralaregistration.gov.in/fileUploads/indianpartnershipact_form1.pdf" -o form1.pdf` → HTTP 200, 6406 bytes. - Node's global `fetch` (the same fetch `tools/verify-sources.mjs` uses internally) fails the identical TLS error by default, but succeeds when the process is started with `NODE_OPTIONS="--tls-cipher-list=DEFAULT@SECLEVEL=1"` set in the environment — confirmed this cycle with `NODE_OPTIONS="--tls-cipher-list=DEFAULT@SECLEVEL=1" node -e "fetch('https://keralaregistration.gov.in/fileUploads/indianpartnershipact_form1.pdf").then(...)"`, which returned HTTP 200 and the identical 6406-byte payload as the `curl` fetch. **A reviewer re-verifying this document's `source.url` with `tools/verify-sources.mjs` MUST run it with that same `NODE_OPTIONS` value set in the environment**, e.g.: `NODE_OPTIONS="--tls-cipher-list=DEFAULT@SECLEVEL=1" node tools/verify-sources.mjs registry/in/kl/registration/partnership-firm-registration/0.1.0` — without it, the live re-fetch fails with the TLS error (falling back to a Wayback-history check rather than a live 200) even though the citation is genuinely live and unauthenticated. - **Field-extraction method:** the fetched PDF's bytes were loaded with `pdfjs-dist` (`legacy/build/pdf.js`, `getDocument()` + `page.getTextContent()` per page, joining each page's text-run `str` values) — a fresh extraction performed this cycle, not reused from any earlier session. Two pages recovered (`numPages: 2`). The extracted text matches the field content, section labels, partner-table structure, and the full N.B. footnote text quoted throughout this document and `schema.json` verbatim (character-for-character, modulo whitespace introduced by the row/column text-run join order — this is a static, fixed-layout PDF with a two-column address/signature block on page 1, so a naive left-to-right, top-to-bottom text-run join interleaves those two columns' words; every quoted phrase below was independently confirmed against the raw per-run text, not just the joined string, to rule out a join-order artifact changing a word's meaning). - **Statutory cross-read:** THE INDIAN PARTNERSHIP ACT, 1932 (Act No. 9 of 1932), consolidated text — — fetched directly (HTTP 200, 339326 bytes), extracted the same way with `pdfjs-dist` (26 pages). Sections read in full: 4 (definition of "partnership"/"partner"/"firm"), 30 (minors admitted to the benefits of partnership), 58 (application for registration), 59 (registration), and 71 (power to make rules). Exact quotes are reproduced in the scope decisions below. - **State rules cross-read:** the Kerala Partnership (Registration of Firms) Rules, 1959, Rule 3 ("Form and verification of statements under sections 58 & 60") — confirmed via a live fetch of , which quotes Rule 3 as: "The statement submitted to the Registrar under sections 58 and 60 of the Act shall respectively be in Forms I and II annexed to these rules together with the fees specified in those forms and shall be verified in the manner indicated therein." This corroborates Form I's own printed heading, "FORM 'I' (See rules 3)". - **Retrieved / reviewed:** 2026-07-09. - **Reviewer:** GovSchema Engineering (Standards Engineer — initial authoring source review). ## Scope decision 1 — jurisdiction/directory path: sub-national (Kerala), not central **Decision:** `in/kl/registration/partnership-firm-registration`, `jurisdiction.subdivision: IN-KL`, `jurisdiction.level: subnational`. **Reasoning.** The Indian Partnership Act, 1932 is a central statute (applies to "the whole of India", Section 1(2)), but Section 71 expressly delegates rule-making for the registration process to each **State Government**: > "71. Power to make rules. — (1) The State Government may by notification > in the Official Gazette make rules prescribing the fees which shall > accompany documents sent to the Registrar of Firms... (2) The State > Government may also make rules — (a) prescribing the form of statement > submitted under section 58, and of the verification thereof..." This is exactly what happened in Kerala: the Kerala Partnership (Registration of Firms) Rules, 1959, made under this Section 71 power, prescribe Form I itself ("Rule 3... shall respectively be in Forms I and II annexed to these rules") and Kerala's own Registrar of Firms is the state's Inspector General of Registration, not a central official. Confirming the hypothesis further, the Act's own "STATE AMENDMENT" notes throughout Chapter VII (see the extracted Act text) show multiple states (Goa, Rajasthan, Uttarakhand, Maharashtra, Karnataka) independently amending or substituting their own Section 58/59/59A/69A/70 rules, fees, and even the form's own online/offline procedure — confirming each state genuinely runs its own Partnership Rules and Registrar of Firms, not one uniform form used verbatim nationwide. This document is therefore properly modelled as a **sub-national** Kerala schema, at `in/kl/...`, mirroring this registry's existing sub-national convention (`ca/on/registration/...`, `ch/zh/sta/...`, `us/ca/...`). ## Scope decision 2 — repeating partner rows (1-5) **Decision:** model `partner1FullName`/`partner1PermanentAddress`/ `partner1DateOfJoining` and the same three sub-fields for `partner2` as **required**; the same three sub-fields for `partner3`/`partner4`/`partner5` (plus a fourth, `partnerXMinorAdmittedToBenefits` — see decision 4) as **optional**, matching Form I's own fixed 5-row printed table. **Reasoning.** GovSchema v0.3 has no `array`/repeating-field type (`spec/proposals/0009-composite-repeating-values.md`, GSP-0009, still `Status: Proposed`, confirmed by grepping the entire `registry/` tree for `"type": "array"` — zero matches). Form I's own printed layout is a **fixed** 5-row table (not an unbounded repeat, unlike the XFA `` groups found in the Ontario partnership schemas), so a bounded, flattened, numbered-field design is the right shape rather than a narrowed single-partner model. Section 4 of the Act defines a partnership as "the relation between **persons** who have agreed to share the profits of a business" (plural, and "persons who have entered into partnership with one another are called individually 'partners' and collectively 'a firm'") — a partnership requires at least two partners. Following this registry's best precedent for a small, fixed-count repeat (`ca/ircc/passport-application-first-adult`'s `reference1FullName`/ `reference2FullName`, both required for exactly 2 references), this document models `partner1*`/`partner2*` as required and `partner3*` through `partner5*` as the form's own optional additional rows. ## Scope decision 3 — witness field: closed enum **Decision:** `witnessCategory` is a closed `enum` of 8 values. **Reasoning.** Form I's own N.B. reads, verbatim from this cycle's own fresh extraction: "This form must be signed by all partners or their agents specially authorised in this behalf in the presence of a witness or witnesses who must be either Gazetted officer, Advocate, Attorney, Vakil, Honorary Magistrate, Chartered Accountant, Income tax Practioner or Registered State Auditor." (the source's own text has the typo "Practioner", missing an "i"; this document's enum value `income_tax_practitioner` is spelled correctly as a machine key, since GovSchema field `name`/`enum` values are stable identifiers, not verbatim source transcriptions — the verbatim source text, typo included, is quoted here and in the field's own `description`/`sourceRef`). This is an **exhaustive "either...or" list with no trailing "etc."/"such as"/"or other" qualifier** — confirmed by reading straight through to the sentence's own full stop after "Registered State Auditor." — so it is modelled as a closed `enum`, not free text. ## Scope decision 4 — minor partner clause: a real, disclosed field **Decision:** a boolean field, `partnerXMinorAdmittedToBenefits`, modelled on the optional partner slots only (`partner3`, `partner4`, `partner5`), not on the two required partner slots (`partner1`, `partner2`). **Reasoning.** Form I's own N.B. footnote states: "If any partner is a minor the fact whether he is entitled to the benefits of partnership should be set out therein." Section 30 of the Act governs this directly: > "30. Minors admitted to the benefits of partnership. — (1) A person who > is a minor according to the law to which he is subject may not be a > partner in a firm, but, with the consent of all the partners for the > time being, he may be admitted to the benefits of partnership." Since a minor **"may not be a partner"** (only admitted to the *benefits* of partnership), a minor cannot occupy one of the two required partner slots this document models (`partner1`/`partner2`, chosen specifically because Section 4 requires at least two genuine partners for a partnership to exist) — restricting `partnerXMinorAdmittedToBenefits` to the optional `partner3`-`partner5` slots is the legally consistent design, not an arbitrary choice. This rises to a real field (rather than being left out of scope for v0.1.0) because the form prints it as an explicit, named data point the applicant must address for any partner who is a minor, and Section 30 gives it a precise statutory meaning to cite in the field's own `description`. ## What was confirmed against the source | Source element | Field(s) | |---|---| | Page 1, "Presented or forwarded to the Registrar of Firms for filing by Sri/Smt..." | `presentedByName` | | Page 1, preamble / "The Firm Name" | `firmName` | | Page 1, "Place of business :- (a) Principal Place :" | `principalPlaceOfBusiness` | | Page 1, "Place of business :- (b) Other Places :" | `otherPlacesOfBusiness` | | Page 1, "Duration of the Firm:" | `durationOfFirm` | | Page 1, partner table rows 1-5, "Name of partners in full" / "Permanent Address (in full)" / "Date of joining the firm" | `partner1FullName`...`partner5DateOfJoining` | | Page 2, N.B. footnote, minor clause | `partner3MinorAdmittedToBenefits`, `partner4MinorAdmittedToBenefits`, `partner5MinorAdmittedToBenefits` | | Page 1, "Station :........." / "Date :........." | `declarationStation`, `declarationDate` | | Page 2, N.B., witness categories | `witnessCategory` | | Page 1, preamble statement ("We, the undersigned... hereby apply for registration...") | `documents[].registrationStatementAttestation` | | Page 2, per-partner declaration block ("I ... do hereby declare that the above statement is true and correct...") | `documents[].partnerVerificationDeclaration` | Every field's `sourceRef` cites the page and printed label/section it was taken from. Section 58(1)'s own six statutory content items (a-f: firm name, principal place, other places, date of joining, names/addresses, duration) map one-to-one onto `firmName`, `principalPlaceOfBusiness`, `otherPlacesOfBusiness`, `partnerXDateOfJoining`, `partnerXFullName`/ `partnerXPermanentAddress`, and `durationOfFirm` respectively — confirmed by reading Section 58(1) verbatim (quoted in scope decision 1's source and directly below) side-by-side with the form's own printed labels. Section 58(1), quoted in full from this cycle's own extraction of the indiacode.nic.in Act text: "The registration of a firm may be effected at any time by sending by post or delivering to the Registrar of the area in which any place of business of the firm is situated or proposed to be situated, a statement in the prescribed form and accompanied by the prescribed fee, stating — (a) the firm name, (b) the place or principal place of business of the firm, (c) the names of any other places where the firm carries on business, (d) the date when each partner joined the firm, (e) the names in full and permanent addresses of the partners, and (f) the duration of the firm. The statement shall be signed by all the partners, or by their agents specially authorised in this behalf." — confirms Form I asks for exactly this content, nothing more, nothing fabricated. ## What is NOT independently confirmed / out of scope - **The filing fee** ("Filings fee Rs. 15/-" printed on Form I). Not modelled as authoritative data, consistent with every other schema in this registry — fees printed on a static form are liable to be outdated (Kerala's own rules have been amended since, per the "Kerala Partnership (Registration of Firms) (Amendment) Rules, 2025" found during this cycle's research but not itself fetched/verified, since fees are out of scope regardless of their current value). - **A partnership with more than 5 partners.** Form I's own printed table caps at 5 rows; a firm with 6+ partners is out of scope for this document. - **Amendment/change filings** under Sections 60 (alteration of firm name or principal place), 61 (branches), 62 (partner name/address changes), 63 (change in constitution/dissolution) — distinct forms/transactions (Form I only covers the initial Section 58 registration statement), not fetched or modelled this cycle. - **The precise legal meaning of "duration of the firm" as free text.** `durationOfFirm` is modelled as a bounded free-text string (matching the form's own blank-line presentation), not a closed `enum` of e.g. "at will"/"fixed term", since the Act itself (Section 7) only names "partnership at will" as the default when no provision is made — it does not enumerate a closed set of duration types. - **The precise content and format of the online EGROOPS filing channel** (`egroops.kerala.gov.in`, referenced by third-party sources found during this cycle's research but not itself fetched or modelled) — this document is derived from Form I's own static/printable PDF, not the online portal's own field set, which may differ in presentation though not in the underlying Section 58 statutory content. - **The Kerala Partnership (Registration of Firms) (Amendment) Rules, 2025** — found referenced during this cycle's research (a third-party regtech update page) but not itself fetched; Form I's own PDF, fetched directly this cycle, is treated as the authoritative current form absent a confirmed amendment to Form I's own content (as distinct from the fee schedule, which is out of scope regardless per above). ## Scope and jurisdiction notes - This is GovSchema's **first India sub-national schema** — every other `in/*` schema in the registry (`in/eci`, `in/incometax`, `in/mca`, `in/mea`, `in/mha`, `in/morth`) is a central-government process. This document sits at `in/kl/...` per scope decision 1. - No `visibleWhen`/`requiredWhen` conditional logic is used: every field's requiredness is a static fact derivable directly from Section 58(1)'s own content list (for `firmName`/`principalPlaceOfBusiness`/`durationOfFirm`/ `partner1*`/`partner2*`) or from the form's own optional-row structure (for `partner3*`-`partner5*` and `otherPlacesOfBusiness`), with no conditional branch in the source to model. This also avoids gating an optional field's requiredness on another optional field being non-empty via `notEquals` against an absent value — a known anti-pattern in this registry. - `declarationStation`/`declarationDate`/`witnessCategory` are marked `required: true` by inference from their necessity to complete a valid statement and its verification, not from an explicit "mandatory field" marker — Form I is a static, printed (non-XFA/AcroForm) PDF with no such marker system at all, unlike the Ontario/Malaysia dynamic-form precedents in this registry. This inference is disclosed here rather than asserted silently. ## Worked example A fully valid, plausible mock filing (a three-partner Kerala partnership, "Nair & Menon Trading Company," partners Priya Nair, Arjun Menon, and Lakshmi Pillai, principal place of business in Ernakulam with one additional branch place in Thodupuzha, "at will" duration, witnessed by an advocate) was constructed as a JSON data instance covering all 16 populated fields (the 12 required fields, plus 4 of this document's 14 optional fields — `presentedByName`, `otherPlacesOfBusiness`, and `partner3`'s three sub-fields plus its `partner3MinorAdmittedToBenefits: false`). This document's own `fields[]` array was mechanically translated into an ordinary JSON Schema (draft 2020-12) — `type`/`validation` per field become `properties..type`/sibling keywords, `required: true` fields become top-level `required` — and the mock instance was validated against that derived schema with `ajv` (the same `ajv` version `tools/validate-ajv.mjs` and `tools/govschema-client` already depend on, resolved from `tools/node_modules/ajv`). Result: **26 properties, 12 required, valid**. A negative control was also run against the same derived schema: removing `partner2FullName` and setting `witnessCategory` to an out-of-enum value (`"notary_public"`) correctly produced two validation errors (`must have required property 'partner2FullName'` and `witnessCategory must be equal to one of the allowed values`), confirming the derived schema's `required`/`enum` constraints are actually enforced, not just present. This document itself was also separately validated against the GovSchema v0.3 meta-schema with both `tools/validate-ajv.mjs` and `tools/validate.mjs` (see "Path to a `verified` claim" below for what remains to reach `status: verified`). The mock instance and derived JSON Schema are not committed to the registry, consistent with this registry's existing precedent of not persisting worked examples as registry fixtures. ## Path to a `verified` claim (next step) To advance to `status: verified`, a reviewer drives the live Kerala Registration Department's online filing channel (EGROOPS) or an in-person filing with a mock statement and records the outcome here — shipping a new schema version if discrepancies are found (VERSIONING.md §3, immutability). ## Re-verification Per the practice's Cadence, `nextReviewBy` is set to **2027-01-09** (6 months).