BEFORE THE ADJUDICATING OFFICER
SECURITIES AND EXCHANGE BOARD OF INDIA
[ADJUDICATION ORDER NO.CFD/SIL/AO/DRK-CS/EAD-3/548-551/92-95-14]
UNDER SECTION 15-I OF SECURITES AND EXCHANGE BOARD OF INDIA ACT,
1992 READ WITH RULE 5 OF SEBI (PROCEDURE FOR HOLDING INQUIRY AND
IMPOSING PENALTIES BY ADJUDICATING OFFICER) RULES 1995
In respect of:
Name of the entity PAN Number
1. Kautilya Mutual Benefit Fund Ltd.
H.No. 10-4-1/ A/8, Flat no. G-3, Ramakrishna Nagar, Boga
House, Masab Tank, Hyderabad- 500 028, Telangana
AABCK0286E
2. Mr. Boga Surender
H No. 8-4-23/1, Maruti Agencies, Near Peddammagudi, Karim
Nagar- 505001, Telangana
AGTPB6844N
3. Mr. Boga Prabhakar
Flat No. 101, Rama Krishna Nagar, 10-4-1/A/8, Lower Masab
tank, Hyderabad 500060, Telangana
ACEPB2703K
4. Kautilya Laboratories Pvt. Ltd.
H.No. 10-4-1/ A/8, Flat no. G-3, Ramakrishna Nagar, Boga
House, Masab Tank, Hyderabad- 500 028, Telangana
AACCK9426F
FACTS OF THE CASE IN BRIEF
1. Securities and Exchange Board of India (hereinafter referred to as “SEBI”) while
examining the draft Letter of Offer filed by Mrs. Somaraju Lakshmi Kalyani to
acquire 26% shares of Swagruha Infrastructure Ltd. (hereinafter referred to as
"Swagruha"/ "the company") observed certain non-compliances of SAST
Regulations by its promoters namely, Kautilya Mutual Benefit Fund Ltd.
(hereinafter referred to as "Kautilya"/ "Noticee 1"), Mr. Boga Surender
(hereinafter referred to as "Surender"/ "Noticee 2"), Mr. Boga Prabhakar
(hereinafter referred to as "Prabhakar"/ "Noticee 3") and Kautilya Laboratories
Pvt. Ltd. (hereinafter referred to as "Kautilya Lab"/ "Noticee 4") and are
collectively referred to as Noticees. The shares of Swagruha were listed at
Bombay Stock Exchange Ltd. (hereinafter referred to as "BSE").
Page 1 of 7
APPOINTMENT OF ADJUDICATING OFFICER
2. The undersigned was appointed as Adjudicating Officer under Section 15-I of the
Securities and Exchange Board of India Act, 1992 (hereinafter referred to as the
"SEBI Act") read with Rule 3 of the Securities and Exchange Board of India
(Procedure for Holding Inquiry and Imposing Penalties by Adjudicating Officer)
Rules, 1995 (hereinafter referred to as the "Rules") and the same was
communicated vide proceedings of Whole Time Member appointing Adjudicating
Officer dated March 18, 2013, to inquire into and adjudge under Section 15A(b)
of the SEBI Act, for the alleged violation of the provisions of regulation 8(1) and
8(2) of the Securities and Exchange Board of India (Substantial Acquisition of
Shares and Takeovers) Regulation, 1997 (hereinafter referred to as "SAST
Regulations").
SHOW CAUSE NOTICE, REPLY AND PERSONAL HEARING
3. A common show Cause Notice no.
A&E/EAD/DRK/CS/14446/2014 dated May
20, 2014 (hereinafter referred to as "SCN") was served on the Noticees by
“SPAD” requiring the Noticees to show cause as to why an inquiry should not be
held against the Noticees and why penalty, if any, should not be imposed on the
Noticees under Section 15A(b) of the SEBI Act. In the said common SCN it was
alleged that the Noticees had failed to comply with regulation 8(1) and 8(2) of
SAST Regulations. The details in this regard are as follows:
Regulation Due date of compliance Actual date of Compliance Delay, if any,(No. of days)
8(1)/ 8(2) 21.04.2004 26.04.2004 5
8(1)/ 8(2) 21.04.2005 27.04.2005 6
8(1)/ 8(2) 21.04.2006 28.04.2006 7
8(1)/ 8(2) 21.04.2007 24.04.2007 3
8(1)/ 8(2) 21.04.2008 25.04.2008 4
8(1)/ 8(2) 21.04.2009 28.04.2009 7
8(1)/ 8(2) 21.04.2010 23.04.2010 2
8(1)/ 8(2) 21.04.2011 Not complied
4. In response to the SCN, Noticees submitted their common reply dated June 4,
2014 stating that:
Page 2 of 7
"there has been inadvertent delay ranging between 2 to 7 days in respect of filing
disclosures to the company under Regulation 8(2) of SEBI Takeover Regulations.
However, there has been no change in the shareholding in respect of shares held by us
during the said period as disclosed in the shareholding pattern under clause 35 filed
regularly with BSE Ltd.
As per the record, we have filed all the required information assuming that the said
information is required to be filed within 30 days from the closure of 31st March every
year. Whereas now it is understood that it is to be filed by the promoters within 21 days
from the close of 31st March of every year. It is further submitted that no action has been
taken or proceeding initiated against us in the past for any non disclosure with respect to
take over regulations.
We humbly submit that it is only a technical lapse which is unintentional and not to
conceal anything which will misguide or cause loss to the investors at large. We further
respectfully submit that we have not made any gain or unfair advantage out of lapse or
due to delay in disclosure.
The delay in disclosure by us was an error of judgement and at best an error of
understanding of SEBI regulations. Hence it was an erroneous interpretation of
regulations coming from bonafide & inadvertent belief that the disclosure shall be made
within 1 month from the end of 31st March every year.
5. An opportunity of personal hearing was granted to the Noticees vide common
hearing notice dated June 26, 2014 to appear before the undersigned on July 15,
2014 at 15:30 pm at SEBI Bhavan, Mumbai. In response to the same, Noticees
vide email dated July 8, 2014 have stated that "We do not have any additional
information to present in person other than the one already submitted in writing. Hence
we request SEBI to kindly consider our written submissions and proceed further in our
absence".
6. In view of the reply of the Noticees, I am proceeding on the basis of documents/
material and evidence available on record.
CONSIDERATION OF ISSUES, EVIDENCE AND FINDINGS
7. I have taken into consideration the facts and circumstances of the case and the
material made available on record.
Page 3 of 7
8. Before moving forward, it would be pertinent to refer to the following provisions,
which reads as under-
8. (1) Every person, including a person mentioned in regulation 6 who holds more than
[fifteen] per cent shares or voting rights in any company, shall, within 21 days
from the financial year ending March 31, make yearly disclosures to the
company, in respect of his holdings as on 31st March.
(2) A promoter or every person having control over a company shall, within 21 days
from the financial year ending March 31, as well as the record date of the
company for the purposes of declaration of dividend, disclose the number and
percentage of shares or voting rights held by him and by persons acting in
concert with him, in that company to the company.
9. Upon perusal of the documents available on record, it is observed that the
Noticees have filed the requisite yearly disclosure on April 26, 2004 as against
the due date of compliance on April 21, 2004 i.e. with a delay of 5 days, on April
27, 2005 as against the due date of compliance on April 21, 2005 i.e. with a
delay of 6 days, on April 28, 2006 as against the due date of compliance on April
21, 2006 i.e. with a delay of 7 days, on April 24, 2007 as against the due date of
compliance on April 21, 2007 i.e. with a delay of 3 days, on April 25, 2008 as
against the due date of compliance on April 21, 2008 i.e. with a delay of 4 days,
on April 28, 2009 as against the due date of compliance on April 21, 2009 i.e.
with a delay of 7 days, on April 23, 2010 as against the due date of compliance
on April 21, 2010 i.e. with a delay of 2 days. As can be seen there was marginal
delay ranging from two to seven days only. And further Noticees had failed to file
the requisite yearly disclosure for the year 2011.
10.Regulation 8(1) of the SAST Regulations stipulates that every person who holds
more than fifteen percent shares or voting rights in a company shall make yearly
disclosures to the company within 21 days from the financial year ending March
31. Regulation 8(2) of the SAST Regulations stipulates that a promoter or every
person having control over the company has to disclose the number and
percentage of shares or voting rights held by him and by persons acting in
concert with him within twenty one days from the financial year ending March 31,
as well as the record date of the company for the purposes of declaration of
dividend.
Page 4 of 7
11.It is observed that as per the regulation 8(1) and 8(2) of the SAST Regulations,
Noticees being the promoters of SIL were required to file the yearly disclosure,
within the stipulated time as mentioned in pre-para no. 9.
12.Upon perusal of the reply dated June 4, 2014,
submitted by the Noticees, it is
observed that Noticees have admitted that there has been marginal delay
ranging between two to seven days in respect of filing disclosures to the
company till 2010.
13.Noticees have further stated that they have filed all the required information
assuming that the said information is required to be filed within 30 days from the
closure of 31st March every year. Further, Noticees themselves have agreed
their assumption was wrong and it was an error of understanding of SEBI
regulations. I agree with the submissions of the Noticees.
14.The Hon’ble Supreme Court of India in the matter of SEBI Vs. Shri Ram Mutual
Fund held that “once the violation of statutory regulations is established, imposition of
penalty becomes sine qua non of violation and the intention of parties committing such
violation becomes totally irrelevant. Once the contravention is established then the
penalty is to follow”.
15.The provisions of sections 15A(b) of SEBI Act are reproduced hereunder:
Penalty for failure to furnish, information, return etc.
15A.If any person, who is required under this Act or any rules or regulations made
thereunder, -
(b) to file any return or furnish any information, books or other documents within the
time specified therefore in the regulations, fails to file return or furnish the same
within the time specified therefore in the regulations, he shall be liable to a penalty
of one lakh rupees for each day during which such failure continues or one crore
rupees, whichever is less.
16.While determining the quantum of monetary penalty, it is important to consider
the factors stipulated in section 15J of SEBI Act, which reads as under:-
“15J -Factors to be taken into account by the adjudicating officer
While adjudging quantum of penalty under section 15-I, the adjudicating officer shall
have due regard to the following factors, namely:-
a. the amount of disproportionate gain or unfair advantage, wherever quantifiable,
made as a result of the default;
Page 5 of 7
b. the amount of loss caused to an investor or group of investors as a result of the
default;
c. the repetitive nature of the default.”
17.It is noted from the available records, that the quantum of penalty has not been
quantified. I observe that from the material available on record it is difficult to
quantify the amount of gain or unfair advantage accrued to the Noticees or the
extent of loss suffered by the investors as a result of the delay in complying with
the aforesaid provisions. Therefore, in view of the abovementioned conclusions
and after considering all the factors mentioned under Section 15J of the SEBI
Act, I hereby impose a penalty of ` 3,00,000/- (Rupees Three Lakh Only) on all
the Noticees for the non compliance of the provisions of regulations 8(1) and 8(2)
of the SAST Regulations within the stipulated time under Section 15A(b) of the
Securities and Exchange Board of India Act, 1992, which is appropriate in the
facts and circumstances of the case.
ORDER
18.In exercise of the powers conferred under Section 15-I of the Securities and
Exchange Board of India Act, 1992, and Rule 5 of Securities and Exchange
Board of India (Procedure for Holding Inquiry and Imposing Penalties by
Adjudicating Officer) Rules, 1995, I hereby impose a penalty of ` 3,00,000 /(
Rupees Three Lakh Only) on all the Noticees in terms of the provisions of
Section 15A (b) of the Securities and Exchange Board of India Act, 1992 for the
non compliance of the provisions of regulations 8(1) and 8(2) of the SAST
Regulations within the stipulated time. In the facts and circumstances of the
case, I am of the view that the said penalty is commensurate with the delayed
compliance for the years 2004-2010 and for non-compliance for the year 2011 by
the Noticees. The Noticees shall be jointly and severally liable to pay the said
monetary penalty.
19.The penalty shall be paid by way of Demand Draft drawn in favour of “SEBI–
Penalties Remittable to Government of India” payable at Mumbai within 45 days
of receipt of this order. The said demand draft shall be forwarded to General
Manager- CFD, Securities and Exchange Board of India, Plot No. C4-A, ‘G’
Block, Bandra Kurla Complex, Bandra (E), Mumbai – 400051.
Page 6 of 7
20.In terms of the provisions of Rule 6 of the Securities and Exchange Board of
India (Procedure for Holding Inquiry and Imposing Penalties by Adjudicating
Officer) Rules 1995, copy of this order is being sent to all the Noticees and also
to the Securities and Exchange Board of India Mumbai.
Place: Mumbai D. RAVI KUMAR
Date: July 18, 2014 CHIEF GENERAL MANAGER &
ADJUDICATING OFFICER
Page 7 of 7
SECURITIES AND EXCHANGE BOARD OF INDIA
[ADJUDICATION ORDER NO.CFD/SIL/AO/DRK-CS/EAD-3/548-551/92-95-14]
UNDER SECTION 15-I OF SECURITES AND EXCHANGE BOARD OF INDIA ACT,
1992 READ WITH RULE 5 OF SEBI (PROCEDURE FOR HOLDING INQUIRY AND
IMPOSING PENALTIES BY ADJUDICATING OFFICER) RULES 1995
In respect of:
Name of the entity PAN Number
1. Kautilya Mutual Benefit Fund Ltd.
H.No. 10-4-1/ A/8, Flat no. G-3, Ramakrishna Nagar, Boga
House, Masab Tank, Hyderabad- 500 028, Telangana
AABCK0286E
2. Mr. Boga Surender
H No. 8-4-23/1, Maruti Agencies, Near Peddammagudi, Karim
Nagar- 505001, Telangana
AGTPB6844N
3. Mr. Boga Prabhakar
Flat No. 101, Rama Krishna Nagar, 10-4-1/A/8, Lower Masab
tank, Hyderabad 500060, Telangana
ACEPB2703K
4. Kautilya Laboratories Pvt. Ltd.
H.No. 10-4-1/ A/8, Flat no. G-3, Ramakrishna Nagar, Boga
House, Masab Tank, Hyderabad- 500 028, Telangana
AACCK9426F
FACTS OF THE CASE IN BRIEF
1. Securities and Exchange Board of India (hereinafter referred to as “SEBI”) while
examining the draft Letter of Offer filed by Mrs. Somaraju Lakshmi Kalyani to
acquire 26% shares of Swagruha Infrastructure Ltd. (hereinafter referred to as
"Swagruha"/ "the company") observed certain non-compliances of SAST
Regulations by its promoters namely, Kautilya Mutual Benefit Fund Ltd.
(hereinafter referred to as "Kautilya"/ "Noticee 1"), Mr. Boga Surender
(hereinafter referred to as "Surender"/ "Noticee 2"), Mr. Boga Prabhakar
(hereinafter referred to as "Prabhakar"/ "Noticee 3") and Kautilya Laboratories
Pvt. Ltd. (hereinafter referred to as "Kautilya Lab"/ "Noticee 4") and are
collectively referred to as Noticees. The shares of Swagruha were listed at
Bombay Stock Exchange Ltd. (hereinafter referred to as "BSE").
Page 1 of 7
APPOINTMENT OF ADJUDICATING OFFICER
2. The undersigned was appointed as Adjudicating Officer under Section 15-I of the
Securities and Exchange Board of India Act, 1992 (hereinafter referred to as the
"SEBI Act") read with Rule 3 of the Securities and Exchange Board of India
(Procedure for Holding Inquiry and Imposing Penalties by Adjudicating Officer)
Rules, 1995 (hereinafter referred to as the "Rules") and the same was
communicated vide proceedings of Whole Time Member appointing Adjudicating
Officer dated March 18, 2013, to inquire into and adjudge under Section 15A(b)
of the SEBI Act, for the alleged violation of the provisions of regulation 8(1) and
8(2) of the Securities and Exchange Board of India (Substantial Acquisition of
Shares and Takeovers) Regulation, 1997 (hereinafter referred to as "SAST
Regulations").
SHOW CAUSE NOTICE, REPLY AND PERSONAL HEARING
3. A common show Cause Notice no.
A&E/EAD/DRK/CS/14446/2014 dated May
20, 2014 (hereinafter referred to as "SCN") was served on the Noticees by
“SPAD” requiring the Noticees to show cause as to why an inquiry should not be
held against the Noticees and why penalty, if any, should not be imposed on the
Noticees under Section 15A(b) of the SEBI Act. In the said common SCN it was
alleged that the Noticees had failed to comply with regulation 8(1) and 8(2) of
SAST Regulations. The details in this regard are as follows:
Regulation Due date of compliance Actual date of Compliance Delay, if any,(No. of days)
8(1)/ 8(2) 21.04.2004 26.04.2004 5
8(1)/ 8(2) 21.04.2005 27.04.2005 6
8(1)/ 8(2) 21.04.2006 28.04.2006 7
8(1)/ 8(2) 21.04.2007 24.04.2007 3
8(1)/ 8(2) 21.04.2008 25.04.2008 4
8(1)/ 8(2) 21.04.2009 28.04.2009 7
8(1)/ 8(2) 21.04.2010 23.04.2010 2
8(1)/ 8(2) 21.04.2011 Not complied
4. In response to the SCN, Noticees submitted their common reply dated June 4,
2014 stating that:
Page 2 of 7
"there has been inadvertent delay ranging between 2 to 7 days in respect of filing
disclosures to the company under Regulation 8(2) of SEBI Takeover Regulations.
However, there has been no change in the shareholding in respect of shares held by us
during the said period as disclosed in the shareholding pattern under clause 35 filed
regularly with BSE Ltd.
As per the record, we have filed all the required information assuming that the said
information is required to be filed within 30 days from the closure of 31st March every
year. Whereas now it is understood that it is to be filed by the promoters within 21 days
from the close of 31st March of every year. It is further submitted that no action has been
taken or proceeding initiated against us in the past for any non disclosure with respect to
take over regulations.
We humbly submit that it is only a technical lapse which is unintentional and not to
conceal anything which will misguide or cause loss to the investors at large. We further
respectfully submit that we have not made any gain or unfair advantage out of lapse or
due to delay in disclosure.
The delay in disclosure by us was an error of judgement and at best an error of
understanding of SEBI regulations. Hence it was an erroneous interpretation of
regulations coming from bonafide & inadvertent belief that the disclosure shall be made
within 1 month from the end of 31st March every year.
5. An opportunity of personal hearing was granted to the Noticees vide common
hearing notice dated June 26, 2014 to appear before the undersigned on July 15,
2014 at 15:30 pm at SEBI Bhavan, Mumbai. In response to the same, Noticees
vide email dated July 8, 2014 have stated that "We do not have any additional
information to present in person other than the one already submitted in writing. Hence
we request SEBI to kindly consider our written submissions and proceed further in our
absence".
6. In view of the reply of the Noticees, I am proceeding on the basis of documents/
material and evidence available on record.
CONSIDERATION OF ISSUES, EVIDENCE AND FINDINGS
7. I have taken into consideration the facts and circumstances of the case and the
material made available on record.
Page 3 of 7
8. Before moving forward, it would be pertinent to refer to the following provisions,
which reads as under-
8. (1) Every person, including a person mentioned in regulation 6 who holds more than
[fifteen] per cent shares or voting rights in any company, shall, within 21 days
from the financial year ending March 31, make yearly disclosures to the
company, in respect of his holdings as on 31st March.
(2) A promoter or every person having control over a company shall, within 21 days
from the financial year ending March 31, as well as the record date of the
company for the purposes of declaration of dividend, disclose the number and
percentage of shares or voting rights held by him and by persons acting in
concert with him, in that company to the company.
9. Upon perusal of the documents available on record, it is observed that the
Noticees have filed the requisite yearly disclosure on April 26, 2004 as against
the due date of compliance on April 21, 2004 i.e. with a delay of 5 days, on April
27, 2005 as against the due date of compliance on April 21, 2005 i.e. with a
delay of 6 days, on April 28, 2006 as against the due date of compliance on April
21, 2006 i.e. with a delay of 7 days, on April 24, 2007 as against the due date of
compliance on April 21, 2007 i.e. with a delay of 3 days, on April 25, 2008 as
against the due date of compliance on April 21, 2008 i.e. with a delay of 4 days,
on April 28, 2009 as against the due date of compliance on April 21, 2009 i.e.
with a delay of 7 days, on April 23, 2010 as against the due date of compliance
on April 21, 2010 i.e. with a delay of 2 days. As can be seen there was marginal
delay ranging from two to seven days only. And further Noticees had failed to file
the requisite yearly disclosure for the year 2011.
10.Regulation 8(1) of the SAST Regulations stipulates that every person who holds
more than fifteen percent shares or voting rights in a company shall make yearly
disclosures to the company within 21 days from the financial year ending March
31. Regulation 8(2) of the SAST Regulations stipulates that a promoter or every
person having control over the company has to disclose the number and
percentage of shares or voting rights held by him and by persons acting in
concert with him within twenty one days from the financial year ending March 31,
as well as the record date of the company for the purposes of declaration of
dividend.
Page 4 of 7
11.It is observed that as per the regulation 8(1) and 8(2) of the SAST Regulations,
Noticees being the promoters of SIL were required to file the yearly disclosure,
within the stipulated time as mentioned in pre-para no. 9.
12.Upon perusal of the reply dated June 4, 2014,
submitted by the Noticees, it is
observed that Noticees have admitted that there has been marginal delay
ranging between two to seven days in respect of filing disclosures to the
company till 2010.
13.Noticees have further stated that they have filed all the required information
assuming that the said information is required to be filed within 30 days from the
closure of 31st March every year. Further, Noticees themselves have agreed
their assumption was wrong and it was an error of understanding of SEBI
regulations. I agree with the submissions of the Noticees.
14.The Hon’ble Supreme Court of India in the matter of SEBI Vs. Shri Ram Mutual
Fund held that “once the violation of statutory regulations is established, imposition of
penalty becomes sine qua non of violation and the intention of parties committing such
violation becomes totally irrelevant. Once the contravention is established then the
penalty is to follow”.
15.The provisions of sections 15A(b) of SEBI Act are reproduced hereunder:
Penalty for failure to furnish, information, return etc.
15A.If any person, who is required under this Act or any rules or regulations made
thereunder, -
(b) to file any return or furnish any information, books or other documents within the
time specified therefore in the regulations, fails to file return or furnish the same
within the time specified therefore in the regulations, he shall be liable to a penalty
of one lakh rupees for each day during which such failure continues or one crore
rupees, whichever is less.
16.While determining the quantum of monetary penalty, it is important to consider
the factors stipulated in section 15J of SEBI Act, which reads as under:-
“15J -Factors to be taken into account by the adjudicating officer
While adjudging quantum of penalty under section 15-I, the adjudicating officer shall
have due regard to the following factors, namely:-
a. the amount of disproportionate gain or unfair advantage, wherever quantifiable,
made as a result of the default;
Page 5 of 7
b. the amount of loss caused to an investor or group of investors as a result of the
default;
c. the repetitive nature of the default.”
17.It is noted from the available records, that the quantum of penalty has not been
quantified. I observe that from the material available on record it is difficult to
quantify the amount of gain or unfair advantage accrued to the Noticees or the
extent of loss suffered by the investors as a result of the delay in complying with
the aforesaid provisions. Therefore, in view of the abovementioned conclusions
and after considering all the factors mentioned under Section 15J of the SEBI
Act, I hereby impose a penalty of ` 3,00,000/- (Rupees Three Lakh Only) on all
the Noticees for the non compliance of the provisions of regulations 8(1) and 8(2)
of the SAST Regulations within the stipulated time under Section 15A(b) of the
Securities and Exchange Board of India Act, 1992, which is appropriate in the
facts and circumstances of the case.
ORDER
18.In exercise of the powers conferred under Section 15-I of the Securities and
Exchange Board of India Act, 1992, and Rule 5 of Securities and Exchange
Board of India (Procedure for Holding Inquiry and Imposing Penalties by
Adjudicating Officer) Rules, 1995, I hereby impose a penalty of ` 3,00,000 /(
Rupees Three Lakh Only) on all the Noticees in terms of the provisions of
Section 15A (b) of the Securities and Exchange Board of India Act, 1992 for the
non compliance of the provisions of regulations 8(1) and 8(2) of the SAST
Regulations within the stipulated time. In the facts and circumstances of the
case, I am of the view that the said penalty is commensurate with the delayed
compliance for the years 2004-2010 and for non-compliance for the year 2011 by
the Noticees. The Noticees shall be jointly and severally liable to pay the said
monetary penalty.
19.The penalty shall be paid by way of Demand Draft drawn in favour of “SEBI–
Penalties Remittable to Government of India” payable at Mumbai within 45 days
of receipt of this order. The said demand draft shall be forwarded to General
Manager- CFD, Securities and Exchange Board of India, Plot No. C4-A, ‘G’
Block, Bandra Kurla Complex, Bandra (E), Mumbai – 400051.
Page 6 of 7
20.In terms of the provisions of Rule 6 of the Securities and Exchange Board of
India (Procedure for Holding Inquiry and Imposing Penalties by Adjudicating
Officer) Rules 1995, copy of this order is being sent to all the Noticees and also
to the Securities and Exchange Board of India Mumbai.
Place: Mumbai D. RAVI KUMAR
Date: July 18, 2014 CHIEF GENERAL MANAGER &
ADJUDICATING OFFICER
Page 7 of 7
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