Chandrakanta Laddha vs Sebi

This order disposes of four appeals filed by three appellants,

namely, Badri Lal Birla (Appeal Nos. 524 of 2019 and 605 of

2019), Chandrakanta Laddha (Appeal No. 601 of 2019) and

Arihant Capital Markets Limited (Appeal No. 334 of 2020).

Appeal No. 605 of 2019 has been filed challenging the order of

the Whole Time Member („WTM‟ for short) of Securities and

Exchange Board of India („SEBI) dated March 19, 2019 whereby

Badri Lal Birla and Chandrakanta Laddha, among others, had

been restrained from dealing in the securities market for a period

of five years. However, only Badri Lal Birla has filed appeal

against this order. Three other appeals are filed against the orders

of Adjudicating Officer („AO‟ for short) of SEBI dated September 4

24, 2019 (Appeal No. 601 of 2019); August 30, 2019 (Appeal No.

524 of 2019 and May 29, 2020 (Appeal No. 334 of 2020). By

these adjudication orders penalty of respectively Rs. 6 lakh, Rs.

10 lakh and Rs. 5 lakh has been imposed on appellants

Chandrakanta Laddha, Badri Lal Birla and Arihant Capital

Markets Limited („Arihant‟ for short). Though, the dates of the

AO orders are different all 3 AO orders and the WTM order are

passed in respect of trading in the scrip of Moryo Industries Ltd.

(„Moryo‟ for short) during the year 2013-14 held to be violative of

provisions of SEBI (Prohibition of Fraudulent and Unfair Trade

Practices relating to Securities Market) Regulations, 2003

(„PFUTP Regulations‟ for short). Accordingly, by consent of the

parties all appeals have been heard together and are disposed of by

this common decision.

2. Facts relating to two appeals are similar; SEBI investigation

found that appellants Birla and Laddha and some other noticees

were instrumental in raising the price of the scrip of Moryo and in

contributing to positive Last Traded Price (LTP). These appellants

had placed miniscule buy and sell orders which resulted in

artificially raising the price of the scrip of Moryo. The allegation

against Arihant is violation of Code of Conduct of Stock Brokers

since it did not exercise due care and diligence while executing 5

the trades of Birla who was its client. Accordingly a show cause

notice was issued on December 5, 2017 and WTM passed the

order on March 19, 2019. Thereafter, after issuing SCNs on

different dates AO passed other three separate orders imposing

monetary penalty as given in paragraph1of this Order.

3. Dr. S.K. Jain, Authorised Representative appearing for the

appellant in Appeal No. 605 of 2019 made an attempt to

demonstrate that the appellant was not in receipt of the show

cause notice. However, we note from the reply filed by respondent

SEBI that the show cause notice issued by SEBI through speed

post returned "unclaimed" and thereafter it was served by

affixture. Moreover, the appeal has been filed with a delay of 254

days; even subsequent to filing the appeal against the AO order

which was issued five months after the WTM order. Therefore, we

are of the view that the appellant has filed this appeal belatedly.

Further, while the WTM order was issued against five entities

only Badri Lal Birla has appealed against the same; even

Chandrakanta Laddha who is appealing against the AO order has

not appealed against the WTM order.

4. In Appeal No. 524 of 2019 (Badri Lal Birla), Dr. S.K. Jain,

Authorized Representative contended that the appellant is a 78 6

years old senior citizen; did not violate any securities laws; SEBI

cherry-picked 18 buy orders for 23 shares and 14 sell orders for 23

shares in an arbitrary manner and concluded that the appellant

contributed to positive LTP, ignoring other trades which had

negative or no LTP; even during the pre-investigation period price

of the scrip was rising but was not investigated; there were

fluctuations in prices during the investigation period and therefore

the conclusion relating to LTP is not correct; appellant is a small

investor and resorted to the same trading pattern in 30 scrips; total

investment is that of 2-3 lakh, however, the penalty is Rs. 10 lakh

which is highly disproportionate; no connection between buyer

and seller or to the company was established and no synchronized,

reversal or circular trades have been alleged. The Authorized

Representative has placed reliance on a number of orders as

follows (i) Order of this Tribunal in the matter of Vikas

Ganeshmal Bengani vs Securities and Exchange Board of India

(Appeal No. 225 of 2009 decided on February 25, 2010), (ii)

Order of this Tribunal in the matter of M/s. Nishith M. Shah

(HUF) vs Securities and Exchange Board of India (Appeal No.

97 of 2019 decided on January 16, 2020), (iii) Order of WTM,

SEBI in the matter of Mr. Amit H. Tilala dated May 31, 2019,

(iv) Order of WTM, SEBI in the matter of Mr. Jayendra 7

Chandulal Sheth dated February 27, 2019, (v) Order of WTM,

SEBI in the matter of Moryo Industries Limited dated September

21, 2017, (vi) Order of AO, SEBI in the matter of Ever Bright

Trading Private Limited (earlier known as Mould Trading

Private Limited) dated September 30, 2019, (vii) Order of AO,

SEBI in the matter of Radford Global Ltd. dated March 6, 2020

and (viii) Order of AO, SEBI in the matter of Winsome Yarns

Limited dated February 24, 2020 in support of his contention

and, particularly, emphasized the order in respect of M/s. Nishith

M. Shah HUF(supra).

5. We further note the following from the impugned Order in

appeal No. 524 of 2019 Badri Lal Birla that total buy trades were

22, out of which 18 were positive LTP contributing trades; there

were 12 trades wherein the buy order was placed for less than or

equal to 6 shares while the disclosed quantity of sell order was

more than or equal to 100 shares. These 12 trades were executed

on 12 different days resulted in positive LTP contribution of Rs.

56.65 (19.97% of total market positive LTP) during Patch 1.

Details of these 12 positive LTP contributing buy trades are given

below:-

Sl. Batch Buyer Seller Trade Buy Sell Trade LTP Buy Sell Trade Sell Buy No Date Name Name Time Order Order Price Diff Order Orde d Order Order 8

. Time Time Price r Quant Disclo Origin Price ity se al Volum Quanti e ty 1 31.01. Badri Rakesh 09:54:43. 09:54:43. 09:44:49. 113.6 2020 113.6 113. 6 100 6 2013 Lal Kumar 5050340 4767400 7451510 0 0 60 Birla Modi 2 16.04. Badri Vinod 14:15:33. 13:58:34. 13:5 760.0 3.60 76.00 76.0 1 300 1 2013 Lal Banwari 5017690 4683990 7:34.4912 0 0 230 Birla lal Sharma 3 06.05. Badri Rakesh 15:15:26. 15:09:40. 15:03:58. 104.0 4.40 104.0 104. 1 500 1 3704090 7919310 9738280 0 0 00 2013 Lal Kumar Birla Modi 4 07.05. Badri Sunil Kr 15:15:21. 15:01:15. 15:01:52. 109.2 5.20 109.2 109. 1 1000 1 2013 Lal Bagaria 8107230 8389440 1442820 0 0 20 Birla Huf 5 15.05. Badri Insight 14:15:23. 14:02:44. 13:43:02. 132.0 5.00 132.0 132. 1 500 1 2013 Lal Multitra 8931650 4628580 6466090 0 0 00 Birla ding Private Ltd 6 20.05. Badri Prem 11:1529. 10:35:2 11:09:29. 138.5 6.50 138.6 138. 1 100 1 2013 Lal Ratan 3936290 3.40131 4392630 0 0 50 Birla Bhaiya 20 7 22.05. Badri Sunil Kr 15:15:24. 14:49:4 14:50:46. 5.00 138. 137.0 1 400 1 2013 Lal Bagaria 6336290 4.46993 2692270 00 0 Birla Huf 00 8 06.06. Badri Vivekan 15:15:21. 15:3:43. 15:06:28. 108.0 7.45 111.0 108. 1 170 1 2013 Lal and 6561930 808939 3626280 0 5 00 Birla Bagadia 0 Huf 9 11.06. Badri Narendr 15:15:23. 15:09:1 14:55:04. 107.2 4.60 107.2 107. 1 250 1 2013 Lal aG 5523810 1.94841 5389920 5 5 25 Birla Navalak 30 ha 10 12.06. Badri Narendr 15:15:29. 15:08:2 14:30:04. 114.4 4..15 111.4 111. 1 250 1 2013 Lal aG 9985050 5.74401 8607650 0 0 40 Birla Navalak 70 ha 11 15.07. Badri Coline 15:15:30. 15:00:19. 14:37:34. 112.0 4.80 112.0 112. 1 100 1 2013 Lal Comput 3478120 3921620 3355630 0 0 00 Birla er Private Ltd.

12 18.07. Badri Vinubh 15:15:29. 14:56:55. 14:32:21. 100.0 3.75 106.0 100. 1 122 1 2013 Lal ai 1054690 3713750 4881380 0 0 00 Birla Khushal bhai Patel

6. In respect of trades at sl.no.4, 6 and 7 (i.e., where buy order

was placed before the sell order), the buy order was placed for 1

share at prices significantly above LTP, which were subsequently

matched by sell orders. In the remaining trades (i.e., where buy

order was placed after the sell order), while the disclosed volume 9

of the sell orders was large, buy orders were placed for small

quantities, for which quantity the above trades were executed.

These trades for small quantity were executed on 12 days and

contributed to significant positive LTP. Further, out of these 12

days, on 7 days the trade of the Noticee was the only trade of the

day.

7. Thus, it was alleged that the Noticee was not acting as

genuine buyer and had no bona fide intention to buy but to mark

the price higher because despite availability of large disclosed

quantity of sell orders, he was placing small quantity buy orders

by either matching or placing orders at prices higher than sell

order price which were already above LTP or by placing buy

orders at prices above LTP which were subsequently matched by

sell orders thereby contributing to significant positive LTP.

8. It was also observed that the Noticee was one of the entities

who contributed more than 5% to market positive LTP during

patch 1 as seller as well . Upon analysis of his LTP contribution,

it was observed that the Noticee contributed Rs.68.65 of positive

LTP (24.20% of market positive LTP) through 14 trades for 23

shares. The details of the trades of the Noticee as seller is as

follows:

10

No. of Buy Sell Trad Seller Buy shares Buy Sell Trad Sl. Batch Buyer Seller Trade LTP Orde Orde e Order Order held Order Order e No. Date Name Name Time Diff. r r Qua Volu Volu before Time Time Price Price Price ntity me me these trades 1 10.04. Chandra Badri 15:15:12 15:09:2 15:11:5 66.0 5.00 66.0 66.0 1 1 5 700 2013 kant Lal 8.01978 5.35118 1.87883 0 0 0 Laddha Birla 30 50 70 2 11.04. Chandra Badri 15:15:2 14:30:3 14:32:1 69.0 3.00 69.0 69.0 1 1 10 699 2013 kant Lal 0.96096 9.55645 9.90570 0 0 0 Laddha Birla 80 40 80 3 17.04. Shyam Badri 11.15:3 10:30:0 10:32:2 79.8 3.80 79.8 79.8 1 1 500 700 2013 Kanheyl Lal 6.57076 5.09604 7.20759 0 0 0 al Vyas Birla 50 30 50 4 17.04. Badri Badri 15:15:3 14:51:1 14:34:0 79.8 7.30 79.8 79.8 1 1 1 699 2013 Lal Lal 2.78751 6.12987 9.01993 0 0 0 Birla Birla 70 50 40 5 18.04. Badri Badri 15:15:2 14:35:5 15:04:1 83.7 3.95 83.7 83.7 1 1 1 699 2013 Lal Lal 1.55698 2.06683 4.62302 5 5 5 Birla Birla 10 8 20 60 6 13.05. Chandra Badri 15:15:2 14:31:4 14:32:4 121. 5.20 121. 121. 3 3 5 703 2013 kant Lal 9.09312 3.93797 7.96920 20 20 20 Laddha Birla 30 30 90 7 17.05. Chandra Badri 15:15:3 14:30:3 14:31:1 132. 5.50 132. 132. 2 2 10 702 2013 kant Lal 1.55132 4.67341 5.34542 00 00 00 Laddha Birla 70 80 40 8 21.05. Chandra Badri 15:15:3 15:06:0 15:04:1 132. 6.00 132. 132. 1 1 2 701 2013 kant Lal 0.78556 1.15232 4.9676 00 00 00 Laddha Birla 00 90 00 9 24.06. Amritlal Badri 10:15:2 09:59:5 10:04:2 100. 4.75 100. 100. 1 1 1 704 2013 Kanji Lal 7.01513 5.63608 8.81002 35 35 35 Haria Birla 50 40 30 10 27.06. Chandra Badri 15:15:2 14:33:1 15:13:3 108. 2.65 109. 107. 1 1 2 703 2013 kant Lal 6.55241 0.32731 5.99567 00 35 95 Laddha Birla 20 00 50 11 01.07. Chandra Badri 15:15:3 14:53:0 14:59:5 106. 4.15 106. 106. 2 2 5 704 2013 kant Lal 0.35493 6.63273 5.91482 80 80 75 Laddha Birla 10 80 70

12 02.07. Chandra Badri 15:15:3 14:39:3 14:48:1 109. 3.10 109. 109. 1 1 3 702 2013 kant Lal 5.18184 6.14664 6.24153 90 90 85 Laddha Birla 70 30 70 13 04.07. Chandra Badri 10:15:4 10:03:3 10:04:3 114. 4.90 114. 114. 5 5 5 701 2013 kant Lal 6.28640 6.64946 5.08060 80 85 80 Laddha Birla 50 30 30 14 19.07. Chandra Badri 15:15:3 14:48:2 15:04:4 104. 9.35 105. 104. 2 2 2 705 2013 kant Lal 6.14181 1.95496 7.15317 45 00 45 Laddha Birla 60 90 70

9. In Appeal No. 601 of 2019 filed by Chandrakanta Laddha,

the learned counsel for the appellant, Shri Saurabh

Bachhawat contended that the appellant is a senior citizen

and has been trading in the securities market for 40 years as 11

a small investor in similar fashion; traded in the normal

manner and made a profit of about one lakh rupees during

the relevant time; did not challenge the WTM order due to

financial constraint and therefore the penalty of Rs. 6 lakh

imposed is disproportionate and harsh. It was also contended

that the appellant conducted 10 trades and the quantity

traded was 23 shares with positive LTP impact. Details of

these 10 trades along with their LTP contribution is given

below:-

Sell Buy Trade Order Order Sl. Buy Sell Buy Sell Batch Buyer Seller Trade Trade LTP d Disclo Origin No Order Order Order Order Date Name Name Time Price Diff Quant se al . Time Time Price Price ity Volum Quanti e ty 1 10.04. Chandr- Badri 15:15: 15:09: 15:11:5 66.00 5.00 66.00 66.00 1 1 5 2013 akanta Lal 28.01 25.351 1.87883 70 Laddha Birla 97830 1850 2 11.04. Chandr- Badri 15:15: 14:30: 14:32:1 69.00 3.00 69.00 69.00 1 1 10 2013 akanta Lal 20.96 39.556 9.90570 80 Laddha Birla 09680 4540 3 13.05. Chandr- Badri 15:15: 14:31: 14:32:4 121.20 5.20 121.20 121. 3 3 5 2013 akanta Lal 29.09 43.937 7.96920 20 90 Laddha Birla 31230 9730 4 17.05. Chandr- Badri 15:15: 4:30:3 14:31:1 132.00 5.50 132.00 132. 2 2 10 2013 akanta Lal 31.55 4.6734 5.34542 00 1 40 Laddha Birla 13270 80 5 27.06. Chandr- Badri 15:15: 14:33:1 15:13:3 108.00 2.65 109.35 107. 1 1 2 2013 akanta Lal 26.55 0.3273 5.99567 95 1 50 Laddha Birla 24120 00 6 01.07. Chandr- Badri 15:15: 14:53:0 14:59:5 106.80 4.15 106.80 106. 2 2 5 2013 akanta Lal 30.35 6.6327 5.91482 75 380 70 Laddha Birla 49310 7 02.07. Chandr- Badri 15:15: 14:39:3 14:48:1 109.90 3.10 109.90 109. 1 1 3 2013 akanta Lal 35.18 6.1466 6.24153 85 4 70 Laddha Birla 18470 30 8 04.07. Chandr- Badri 10:15: 10:03:3 10:04:3 114.80 4.90 114.85 114. 5 5 5 2013 akanta Lal 46.28 6.6494 5.08060 80 6 30 Laddha Birla 64050 30 9 08.07. Chandr- Badri 15:15: 14:43:0 15:13:0 118.70 3.70 120.65 118. 5 5 10 2013 akanta Lal 32.67 7.8061 6.92536 65 160 30 Laddha Birla 66650 10 19.07. Chandr- Badri 15:15: 14:48:2 15:04:4 104.45 9.35 105.00 104. 2 2 2 12

2013 akanta Lal 36.14 1.9549 7.15317 45 Laddha Birla 18160 690 70

10. It is observed from these trades of the Noticee that the

Noticee placed buy orders before the sell orders at prices

significantly above LTP, which were subsequently matched by

sell orders. Further, 5 trades took place between June 27, 2013 to

July 08, 2013 i.e. during 7 trading days. Moreover, out of the

above 10 trading days, on 3 days the trades of Noticee were the

only trades of the day. Appellant Laddha also had executed sell

trades also in similar fashion.

11. Thus, it was alleged that the Noticee was not acting as

genuine buyer and had no bona fide intention to buy but to mark

the price higher because she was placing small quantity buy orders

at prices significantly above LTP which were subsequently

matched by sell orders thereby contributing to significant positive

LTP. The Noticee, by trading in the aforesaid manner,

manipulated the scrip price and created a misleading appearance

of trading in the scrip by such trades and thereby allegedly

violated Regulations 3(a), (b), (c), (d), 4(1), 4(2)(a), and (e) of

PFUTP Regulations.

13

12. The appeal filed by Arihant Capital Markets Limited

(Appeal No. 334 of 2020) who is a stock broker and the broker of

appellant Badri Lal Birla. The charge against the appellant broker

is that it failed to exercise due skill, care and diligence and thereby

violated Clause A(2) of the Code of Conduct for stock brokers as

specified under Schedule II read with Regulation 7 of the Stock

Broker Regulations. It is the contention of the learned counsel

appearing for the appellant that the concerned transactions were

carried out in the year 2013 and the show cause notice was issued

on April 24, 2018 with the delay of 5 years and the said

transactions were executed through Bhilwara office and it is not

possible at this stage to recollect or recall the documents,

particularly, when the appellant has more than 1.65 lakh

customers including 75 active institutional clients with operations

spread in 200 cities. Further, it was contended that the impugned

order itself states that the appellant has not derived any benefit

from the same. Moreover, the appellant had no connection with

Badri Lal Birla except a client-broker relationship for share

trading activities during 2005-18 and in these 13 years there was

no other adverse finding against the appellant vis-à-vis Badri Lal

Birla. It was further submitted that during his 25 years of

functioning as a broker, the appellant never faced any punitive or 14

other action in any manner relating to price manipulation, exercise

of inadequate care and negligence.

13. The learned counsel Shri Kumar Desai representing

respondent SEBI, on the other hand, submitted that the two

appellants Badri Lal Birla and Chandrakanta Laddha had

manipulated the market as held in the impugned order since

they had indulged in trading in miniscule quantity on the buy

and sell side when larger quantity of counter party orders

were available in the system. Such trade orders were at

prices substantially different from the LTP. Thus it is clearly

non-genuine trading and violative of the stated provisions of

PFUTP Regulations. Appellant Arihant Capital Markets

Limited did not exercise due skill, care and diligence when

its client was trading in a manipulative manner. Therefore,

the finding in the impugned order that, both the investors

and the broker of one of them are liable for the violations

and hence the monetary penalty which are not harsh and

hence need no interference. In support of his contentions the

learned counsel for the respondent SEBI relied on a number

of judgments as follows- (i) Securities and Exchange Board

of India vs. Rakhi Trading Private Limited, (2018) 13 SCC

753, (ii) Securities and Exchange Board of India vs. 15

Kishore R. Ajmera, (2016) 6 SCC 368, (iii) Securities and

Exchange Board of India vs. Kanaiyalal Baldevbhai Patel

and other connected cases, (2017) 15 SCC 1, (iv) N.

Narayanan vs. Adjudicating Officer, Securities and

Exchange Board of India, (2013) 12 SCC 152, (v)

Systematix Shares & Stocks (India) Limited vs. Securities

and Exchange Board of India, 2012 SCC OnLine SAT 69:

[2012] SAT 69, (vi) Shailesh Jain vs Securities and

Exchange Board of India, 2012 SCC OnLine SAT 76 :

[2012) SAT 76, (vii) Order of this Tribunal in the matter of

Shri Lakhi Prasad Kheradi vs. Securities and Exchange

Board of India (Appeal No. 232 of 2017 decided on June

21 2018), (viii) Saumil Bhavnagari vs. Securities and

Exchange Board of India, 2014 SCC OnLine SAT 54, (ix)

Kalpana Dharmesh Chheda & Anr. vs. Securities and

Exchange Board of India, 2020 SCC OnLine SAT 52, (x)

Jayprakash Bohra vs. Securities and Exchange Board of

India, 2019 SCC OnLine SAT 368 and (xi) Giriraj Kumar

Gupta HUF vs. Securities and Exchange Board of India,

2020 SCC OnLine SAT 111.

16

14. Having heard the learned counsel for the parties and

having perused the documents, we are of the considered

view that the period of restraint and amount of penalties

imposed on the appellants are harsh and disproportionate.

The impugned order elaborates the trades done by the

appellants in terms of various parameters which reveals the

fact that a few miniscule orders have been placed by the

appellants Badri Lal Birla and Chandrakanta Laddha which

looks manipulative in nature. It is also true that they are

counter parties to the some of the trades. It is also the fact

that through some of their trading the LTP has been

impacted. Thus there is merit in the findings in the impugned

orders that the pattern of appellants‟ trading had been of a

market manipulating nature. Hence the reliance placed by

the appellants in various orders is misplaced as they are

distinguishable on facts.

15. However, at the same time, we also note that the

number of trades which are found to be manipulative and

hence falling foul of the charging provisions as in the

impugned order is not too large; 18, 14 and 10 etc and the

volumes and are also too small, 36, 23, 24 shares etc. and

cannot impact the market in any significant manner and only 17

a limited impact on the price has happened. It is also a fact

that some of their trades also resulted in no impact on LTP

or impacted LTP negatively. Further on some of these days

prices were fluctuating thereby raising difficulty in

calculating the LTP in a market impacting manner. No

connection between the buyers and sellers, except some of

their trades matching, nor between Moryo and the appellants

has been established. Given these reasons and juxtaposing

the same with limited magnitude of the violation we

consider that the penalty imposed on the appellants is too

harsh. As far as appeal by the broker Arihant Capital

Markets Limited is concerned we are of the considered view

that there is merit in its contention that while a large number

of miniscule orders must warrant the attention of the broker,

a few trades, that too occasionally, may skip the attention

particularly when the broker has large number of clients

running into several thousands. Moreover, the broker of only

one of the appellants (Birla) has been found to be violative

of the Code of Conduct, not the broker of Chandrakanta

Laddha, though the nature of violation by both Birla and

Laddha is the same. Further, the impugned order itself states

that the broker was not a beneficiary in the said trades in any 18

way other than the broker fee and no link has been

established with Badri Lal Birla in any other manner.

16. In the light of the aforesaid facts: limited number and

volume of trades, limited impact on LTP, no connection

between the parties or with the company and other given

reasons we are of the considered view that 5 year restraint

imposed on appellant Badri Lal Birla is too harsh. We,

therefore condone the delay in filing appeal No 605/2019

and consider the appeal. For the same reasons we are also of

the considered view that penalty of Rs. 10 lakh and Rs. 6 lac

imposed on appellants Birla and Laddha respectively is also

harsh and deserve mitigation. In the case of Arihant Capital

Markets Limited the alleged lack of due care, skill, and

diligence in a few trades done by one appellant we are of the

considered view that the alleged lack of care and due

diligence in this matter is not sufficiently established and

therefore cannot be sustained.

17. Given the aforestated reasons, Appeal No. 334 of 2020

filed by Arihant Capital Markets Limited, is allowed and the

impugned order is quashed. Appeal No 605/2019 filed by

Badri Lal Birla is partly allowed by reducing the period of 5 19

years restraint imposed on the appellant to that of the period

already undergone by the appellant. Appeal Nos. 524 of

2019 and 601 of 2019 filed by Badri Lal Birla and

Chandrakanta Laddha respectively are partly allowed.

Penalty imposed is reduced from Rs.10 lac and Rs.6 lac to

Rs. 1 lakh each. Appellants are directed to pay the penalty to

SEBI within 30 days from the date of this Order.

18. The present matter was heard through video

conference due to Covid-19 pandemic. At this stage it is not

possible to sign a copy of this order nor a certified copy of

this order could be issued by the registry. In these

circumstances, this order will be digitally signed by the

Private Secretary on behalf of the bench and all concerned

parties are directed to act on the digitally signed copy of this

order. Parties will act on production of a digitally signed

copy sent by fax and/or email.

Justice Tarun Agarwala Presiding Officer

Dr. C.K.G. Nair Member

Justice M T Joshi Judicial Member 24.03.2021 RAJALA Digitally signed by

msb KSHMI RAJALAKSHMI H NAIR

H NAIR Date: 2021.03.25 15:46:51 +05'30'