A company secretary qualifies its report because a company is not maintaining register of proxies. Is he right in doing so?

There are certain registers which are mandatory for the company to make. Some of these are: Register of contracts or Arrangements in which Directors are interested under section 189 of Companies Act, 2013 as per form MBP 4 as prescribed under Companies (Meetings of Board and its Powers) Rules, 2014. Register of investments under section 187 of Companies Act, 2013 as per form MBP 3 as prescribed under Companies (Meetings of Board and its Powers) Rules, 2014. Register of proxy is not statutory but statistical in nature and PCS is advised to comment about the maintenance of these registers though he need not to qualify his report in case of non-compliance. So, he is not right in qualifying its report for not maintaining the Register of Proxies.