The Debt listed firms come beneath Chapter IV of SEBI (LODR) Regulations, 2015. Hence the Debt listed public firms do not come beneath Rule 9A of the firms (Prospectus and Allotment of Securities) Rules, 2014, and comes beneath Regulation 40 of SEBI (LODR) Regulations, 2015, upon the debt listed companies (public or private) there is no limitation to provide the equity shares in physical form.
But the applicant to urge the change under section 2(52) of the companies act 2013, (as elaborated in Q6 and Q7 above) there must be the need to follow the compliances.