Further issue of shares

Dear All

One of the listed Company are our client.

The Company has passed following special resolutions by way of POSTAL BALLOT under the provisions of section 192A of the Companies Act, 1956;

a) Increase of authorised share capital and classification of the increased share capital into equity and preferece share capital.

b) Alteration of MOA & AOA

c) Issue of Preference shares.

As the company has increased the authorised share capital, the resultant is allotment of preference shares and increase of subscribed share capital, so my query is if this falls under section 81(1A) of the Companies Act, 1956. Moreover the company is also not alloting the prefreence shares to already existing shareholders.

Section 81 says further issue of shares, does the word "further issue of shares" also includes preference shares ??

Please provide ur guidance.

Thanks in advance.

Regards