North End Foods Marketing Pvt. Ltd. & ... vs Sebi

Date of Hearing : 07.03.2019 Date of Decision : 12.03.2019

Appeal No. 80 of 2019 1.

North End Foods Marketing Pvt. Ltd.

615-618, DLF Towers, 6th Floor, 15, Shivaji Marg, Moti Nagar, New Delhi - 110015.

2. Sandeep Sabharwal Office : 615-618, DLF Towers, 6th Floor, 15, Shivaji Marg, Moti Nagar, New Delhi - 110015. ...Appellants

Versus

Securities and Exchange Board of India SEBI Bhavan, Plot No. C-4A, G Block, Bandra Kurla Complex, Bandra (East), Mumbai - 400 051. ...Respondent

Mr. Janak Dwarkadas, Senior Advocate with Mr. Somasekhar Sundaresan, Mr. Vikram Raghani, Mr. Pulkit Sukhramani, Ms. Stuti Shah, Advocates i/b J. Sagar Associates for Appellants. Mr. J. P. Sen, Senior Advocate with Mr. Anubhav Ghosh, Ms. Vidhi Jhawar, Advocates i/b The Law Point for the Respondent.

With Appeal No. 81 of 2019 Mr. Abhishek Aggarwal A-158, Minto Road Complex, Minto Road, New Delhi - 110002. ...Appellant

Versus 2

Securities and Exchange Board of India SEBI Bhavan, Plot No. C-4A, G Block, Bandra Kurla Complex, Bandra (East), Mumbai - 400 051. ...Respondent

Mr. Gaurav Joshi, Senior Advocate with Mr. Saurabh Bachhawat, Mr. Nirmal Chopda, Advocates i/b Vraj Legal for the Appellant. Mr. J. P. Sen, Senior Advocate with Mr. Anubhav Ghosh, Ms. Vidhi Jhawar, Advocates i/b The Law Point for the Respondent.

With Appeal No. 82 of 2019

Ms. Neetu Gupta B-266, S-2, IInd Floor, Ramprastha Colony, Chander Nagar, Ghaziabad, U. P. - 201011. ...Appellant

Versus

Securities and Exchange Board of India SEBI Bhavan, Plot No. C-4A, G Block, Bandra Kurla Complex, Bandra (East), Mumbai - 400 051. ...Respondent

Mr. Gaurav Joshi, Senior Advocate with Mr. Saurabh Bachhawat, Mr. Nirmal Chopda, Advocates i/b Vraj Legal for the Appellant. Mr. J. P. Sen, Senior Advocate with Mr. Anubhav Ghosh, Ms. Vidhi Jhawar, Advocates i/b The Law Point for the Respondent.

With Appeal No. 83 of 2019

Mr. Yash Gupta Flat No. 37, Ajanta Aprtment, Plot No. 36, IP Extens Pataparganj, Delhi - 110 092. ...Appellant 3

Versus

Securities and Exchange Board of India SEBI Bhavan, Plot No. C-4A, G Block, Bandra Kurla Complex, Bandra (East), Mumbai - 400 051. ...Respondent

Mr. Gaurav Joshi, Senior Advocate with Mr. Saurabh Bachhawat, Mr. Nirmal Chopda, Advocates i/b Vraj Legal for the Appellant. Mr. J. P. Sen, Senior Advocate with Mr. Anubhav Ghosh, Ms. Vidhi Jhawar, Advocates i/b The Law Point for the Respondent.

With Appeal No. 84 of 2019

1. R. K. Commodities Services Pvt. Ltd.

A-7, Block B-1, Mohan Co-operative Industrial Estate, Mathura Road, Delhi - 110044.

2. Mr. Rajendra Gupta A-7, Block B-1, Mohan Co-operative Industrial Estate, Mathura Road, Delhi - 110044.

3. Mr. Navdeep Varshneya A-7, Block B-1, Mohan Co-operative Industrial Estate, Mathura Road, Delhi - 110044.

4. Mr. Sundeep Chadha A-7, Block B-1, Mohan Co-operative Industrial Estate, Mathura Road, Delhi - 110044. ...Appellants

Versus

Securities and Exchange Board of India SEBI Bhavan, Plot No. C-4A, G Block, Bandra Kurla Complex, Bandra (East), Mumbai - 400 051. ...Respondent 4

Mr. Mustafa Doctor, Senior Advocate with Mr. Prakash Shah, Mr. Chinmay Paradkar, Advocates i/b Prakash Shah & Associates for the Appellants.

Mr. J. P. Sen, Senior Advocate with Mr. Anubhav Ghosh, Ms. Vidhi Jhawar, Advocates i/b The Law Point for the Respondent.

With Appeal No. 85 of 2019 Rapid Credit & Holdings Pvt. Ltd.

A-12, Mohan Co-operative Industrial Estate, Mathura Road, Delhi - 110044. ...Appellant

Versus

Securities and Exchange Board of India SEBI Bhavan, Plot No. C-4A, G Block, Bandra Kurla Complex, Bandra (East), Mumbai - 400 051. ...Respondent

Mr. Prakash Shah, Advocate with Mr. Chinmay Paradkar, Advocate i/b Prakash Shah & Associates for the Appellant. Mr. J. P. Sen, Senior Advocate with Mr. Anubhav Ghosh, Ms. Vidhi Jhawar, Advocates i/b The Law Point for the Respondent.

With Appeal No. 86 of 2019

Neeru Gupta 5

Neel Kanth Marg, Near Lal Singh Advocate, Civil Lines, Moradabad, Uttar Pradesh - 244001. ...Appellant

Versus

Securities and Exchange Board of India SEBI Bhavan, Plot No. C-4A, G Block, Bandra Kurla Complex, Bandra (East), Mumbai - 400 051. ...Respondent

Mr. Prakash Shah, Advocate with Mr. Chinmay Paradkar, Advocate i/b Prakash Shah & Associates for the Appellant.

Mr. J. P. Sen, Senior Advocate with Mr. Anubhav Ghosh, Ms. Vidhi Jhawar, Advocates i/b The Law Point for the Respondent.

CORAM : Justice Tarun Agarwala, Presiding Officer Dr. C. K. G. Nair, Member

Per : Justice Tarun Agarwala, Presiding Officer

1. On the basis of urgency, this batch of appeals has been posted

today for admission and for an interim order. These appeals arises

against an ex-parte interim order dated February 28, 2019 passed by

the Whole Time Member (hereinafter referred to as, 'WTM') of

Securities and Exchange Board of India (hereinafter referred to as,

'SEBI') exercising the powers conferred under Section 11(1), 11(4)

and 11B read with Section 19 of the Securities and Exchange Board

of India Act, 1992 (hereinafter referred to as, 'SEBI Act') restraining 6

the appellants and other entities from buying, selling or dealing in the

securities market either directly or indirectly or being associated with

the securities market, in any manner, whatsoever, pending

investigation. The operative portion of the ex-parte interim order is

extracted hereunder:-

"41. Therefore, in order to protect the interest of investors and the integrity of the securities market, I, in exercise of the powers conferred upon me section 11(1), 11(4) and 11B read with under Sections 19 of the SEBI Act, pending Investigation, by way of this ad-interim ex-parte order, restrain the following entities/ Noticees from buying, selling or dealing in the securities market, either directly or indirectly, or being associated with securities market, in any manner, whatsoever, till further directions:

SL. Name of the Entity / Noticee PAN

North End Foods Marketing Pvt. Ltd. 1. AABCN9927F ("NEFM") 2. Sandeep Sabharwal AABPS4647J 3. Neetu Gupta AJOPG5806B 4. Yash Gupta BTKPG6004J 5. Abhishek Agarwal AIDPA1545K 6. Vikram Gupta AAOPGI467H 7. Abhishek Mishra APHPM6773J Shamugpriya International Pvt. Ltd. 8. AAYCS6149K ("Shamugpriya") 9. Sita Ram (HUF) ("Sita Ram") ABCHS8882F 10. Reindus Tradeway Private Ltd. ("Reindus") AAICR9376D 11. Alok Kumar Singh ACQPS1889K 12. Fancos Trademart Private Ltd. ("Fancos") AACCF8546P Invictus Stock Research Private Ltd. 13. AACCI4638M ("Invictus") 14. Virendra Kumar Jain ABPPJ9524Q APMV Stocks & Commodities Private Ltd. 15. AAIC19644F ("APMV") 16. Neeru Gupta ADTPG9314M

Shivrudra Infotech Solutions Private Ltd.

17. AAXCS5373G ("Shivrudra")

18. A G Agri Mart Private Ltd. ("A G Agri") AAJCA9398M

19. Gaurav Gupta ARLPG4012E

20. Saurabh Kumar Vaish AEHPV0866L

21. Vimukh Enterprises ("Vimuk") AANFV4919L 7

22. Rapid Credit & Holdings Pvt. Ltd. ("Rapid") AAACR0021K

23. R. K. Commodities Services Pvt. Ltd. ("RCS") AADCR3305H

24. Rajendra Kumar Gupta ADTPG0459K

25. Navdeep Varshneya ADFPV9839A

26. Sundeep Chadha AAHPC9809N

42. It is further clarified that the existing holding of securities of the Noticees, including the units of mutual funds, shall remain frozen during the period of restraint.

43. The Order shall come into force with the immediate effect. The open positions, if any, of the above entities in derivatives shall be permitted to be squared off within a day of this order. Further, RCS, being a commodity broker, is permitted to square off its existing client open positions in commodity derivatives within a period of 15 days from this order."

2. The fact leading to the issuance of the ex-parte interim order in

a nutshell is, that SEBI received an e-mail from Multi Commodity

Exchange of India Ltd. (hereinafter referred to as 'MCX') intimating

that three entities, namely, Mr. Abhishek Aggarwal, Ms. Neetu

Gupta and Mr. Yash Gupta (hereinafter referred to as 'Group A

entities') were holding more than 75% of the total exchange

deliverable stock of Mentha Oil. MCX further informed that Group

A entities were clubbed in accordance with MCX's circular dated

August 23, 2017 with regard to monitoring of position limits as it

was found to be receiving funds from the appellant, i.e. North End

Foods Marketing Pvt. Ltd. & Anr. (hereinafter referred to as NEFM).

On perusal of the details submitted by MCX, it was observed that

Group A entities acquired Mentha Oil through transactions in

Mentha Oil futures contracts on the exchange platform as well as by 8

way of "off-market" transfers. Further Group A entities acquired

off-market transfers from Group B entities. These allegations were

examined in detail and it was, prima-facie, found that Group A and

Group B entities had taken large deliveries of Mentha Oil between

December 2017 to August 2018 amounting to 1339.2 MT, and that

Group B entities made off-market transfers of 490.74 MT of Mentha

Oil to Group A entities during March 2018 to September 2018,

which was in violation of position limits as prescribed by SEBI vide

its circular dated September 27, 2016 and July 25, 2017. Further

examination revealed that Group A and Group B entities received the

funds from one common entity, namely, 'NEFM'. Investigation

revealed that NEFM was found to have either directly transferred

funds to Group A and Group B entities or through the accounts of

proxy entities. Further examination revealed that majority of the

Group B entities traded in Mentha Oil through a common commodity

trading member, namely, R. K. Commodities Services Pvt. Ltd.

(hereinafter referred to as, 'RCS'). The investigation revealed that

the funds transferred by NEFM to Group A and Group B entities

were for the purpose of taking positions in Mentha Oil futures

contracts and for taking subsequent delivery of 177.12 MT of

Mentha Oil worth Rs. 28.04 crore on the MCX platform. Prima-

facie, the investigation revealed that NEFM was the beneficial owner

of the Mentha Oil stock and Group A and Group B entities were 9

acting as front entities of NEFM to hold the stock in their names and

were thus, proxy entities assisting in the entire process.

3. On the basis of the aforesaid investigation, a prima-facie

conclusion was drawn that the appellants had violated the position

limits on several trading days in violation of SEBI's circulars dated

September 27, 2016 and July 25, 2017. Presumption was drawn that

NEFM indirectly traded and took delivery of significant amount of

Mentha Oil from the exchange platform by way of transfer of funds

to Group A and Group B entities and thereby accumulated / cornered

substantial percentage of specified stocks of Mentha Oil from the

exchange platform. A prima-facie conclusion was drawn that such

cornering of dominant / large / substantial percentage or specified

stocks of Mentha Oil was fraudulent within the meaning of the term

'fraud' as defined under Regulation 2(1)(c) of Securities and

Exchange Board of India (Prohibition of Fraudulent and Unfair

Trade Practices relating to the Securities Market) Regulations, 2003

(hereinafter referred to as, ' PFUTP Regulations') and was also in

violation of Section 12A of the SEBI Act read with Regulations 3

and 4 of the PFUTP Regulations. A presumption was drawn that this

accumulated / cornered stocks of Mentha Oil was predominantly

done with the purpose of manipulating the Mentha Oil market on the

exchange platform and on the physical stocks of Mentha Oil through 10

Group A and Group B entities. A prima-facie opinion was formed

that concentration of large stocks with a single entity was detrimental

to the price discovery and that a single entity was in a position to

dictate the Mentha Oil Future Contracts on exchange platform during

the lean season. On this bonafide apprehension that a single entity

could dominate or dictate the price of Mentha Oil on future contracts

on the exchange platform led the WTM to adopt urgent measures by

passing an ex-parte interim order with a view to prevent the

appellants from indulging in such activities or taking positions in

Mentha Oil or for that matter in other commodities in violation of

prescribed positions limits.

4. The appellant, NEFM, has filed Appeal No. 80 of 2019

contending that it is actively involved in the business of procurement

of commodities and warehousing of commodities for which it

receives orders from its clients and, in turn, placed orders for such

commodities with its agents. These agents procure such

commodities and delivered those commodities to the appellant who,

in turn, delivered such commodities to its clients. It was contended

that the appellant is not engaged in funding of loans to entities of

Group A or Group B entities. It was further contended that all the

trading on the exchange resulted in physical delivery of the

commodities. It was denied that the appellant did not trade in other 11

commodities on the exchange platform. Apart from Mentha Oil, the

appellant had also placed orders on other commodities such as Castor

oil, Guar seeds, Paddy, etc.

5. The appellant, Ms. Neetu Gupta, in Appeal No. 82 of 2019

(Group A entities) contends that she is the proprietor of M/s. JMD

Traders and is in the business of trading and dealing in the

commodities market and has adequate infrastructure/arrangement for

dealing in the commodities. The appellant contended that she

received an e-mail from MCX indicating that the appellant's open

positions was clubbed with certain entities. The appellant replied

intimating the exchange that the purported clubbing was erroneous.

6. Mr. Abhishek Aggarwal, appellant in Appeal No. 81 of 2019,

also clubbed in Group A entities, contends that he is a trader in the

commodities market. Apart from trading in Mentha Oil, the said

appellant is also trading in other commodities like, Chana, R M Seed,

Paddy, Maize, Mentha Oil, etc.

7. Mr. Yash Gupta, appellant in Appeal No. 83 of 2019, another

entity in Group A contends that he is a general trader in the

commodities market and has adequate infrastructure for dealing in

the physical commodities and dematerialized commodities for

settlement of trades. The appellant, apart from trading in Mentha 12

Oil, is also trading in Castor seed, Chana, Mustard Seed, Soya Bean

etc. both on the exchange as well as in the physical market.

8. Rapid Credit & Holdings Pvt. Ltd., appellant in Appeal No. 85

of 2019 who has been categorized as a proxy entity in Group B

contends that they are a non-banking finance company duly

registered with the Reserve Bank of India and is not linked with any

entities with regard to execution of trades especially Mentha Oil

contracts. This appellant has contended that they are in the business

of providing finance / loans and are not in the business of

commodities trading on the exchange platform.

9. The Appellant, Neeru Gupta in Appeal No. 86 of 2019 has been

categorized in Group B entity and contends that she has not done any

trading since 2018 and had resigned as a director in the companies

indicated in Group B prior to the relevant period. She categorically

submitted that she has no dealings in Mentha Oil and, therefore, the

ex-parte ad-interim order is patently erroneous.

10. R. K. Commodities, appellant in Appeal No. 84 of 2019 is a

broker and is a trading member and contends that it has wrongly been

connected with the entities in Group B. It was contended that the

Code of Conduct for stockbrokers has not been violated and that

MCX had issued an order dated November 30, 2018 restraining the 13

appellant from trading in Mentha Oil and, therefore, there was no

further occasion for the WTM to pass the impugned ex-parte interim

order restraining it from dealing in all commodities on the exchange

platform.

11. In the light of the aforesaid, we have heard at length Shri Janak

Dwarkadas, learned senior counsel, Shri Gaurav Joshi, learned senior

counsel, Shri Mustafa Doctor, learned senior counsel alongwith Shri

Somasekhar Sundaresan, and Shri Prakash Shah, the learned counsel

for the appellants and Shri J. P. Sen, the learned senior counsel for

the respondent. The basic contention raised is, that the period of

execution of the trades was 2017-2018. The delivery of the futures

contracts had already been executed and if the appellants were

dictating the prices of the future trades, some evidence to that effect

could have been indicated in the impugned order, but no such

evidence has come to light in the investigation. It was further urged

that the finding that the appellants have dominated the market was

based on surmises and conjectures in as much as the respondent has

not taken into consideration the total volume of trades in the market

as compared to the delivery of Mentha Oil taken by the appellants. It

was contended that if the total volume of trades is taken into

consideration, the delivery even if it is clubbed together as a single

entity was minuscule and was less than 2% of the total volume of 14

trade. Such minuscule level cannot be a dominative factor to

manipulate the price of Mentha Oil in the open market. It was

further contended that had an opportunity been given, the appellants

would have explained that there was no nexus between the appellants

and that there was no working in unison either to corner the market

or to manipulate the price of Mentha Oil. It was further contended

that an ex-parte interim order has restrained the appellants not only

from trading in Mentha Oil but in all commodities on the exchange

platform, in the absence of any alleged violation of trading in any

other commodities other than Mentha Oil. It was also contended that

the appellants are trading in other perishable commodities and the

blanket freezing of their demat accounts will put the appellants to

irreparable loss which cannot be compensated in terms of money. It

was contended that the appellants have to meet the deadlines to give

deliveries pursuant to the contract and if the commodities are not

delivered the said commodity which has a short shelf life would

perish. It was also contended that merely on a presumption that

buying large quantities of Mentha Oil was for the purpose of

manipulating the price is not based on any evidence, but is based on

surmises and conjectures. It was contended that appellant was doing

a legitimate business for several years and had earned a goodwill and

by the impugned ex-parte interim order, it has virtually put a death

knell on their business and has undoubtedly stopped their business 15

which is otherwise guaranteed under the Constitution. It was

contended that freezing of the mutual funds had no relation with the

trading activities and, therefore, the ex-parte order was wholly

arbitrary and, in any case, was harsh and punitive and not remedial in

nature, which is envisaged under Section 11 of the SEBI Act.

12. On the other hand, the learned senior counsel for the respondent

contended that the allegations of dominating the market and

cornering the stocks with a view to manipulate the price will only

come out after the enquiry. It was further contended that, admittedly,

the securities market in trading of these commodities are small as

compared to the trading in the open physical market, and, therefore,

the restraint order was only confined to the trading on the exchange

platform and, therefore, it was open for the appellants to continue

dealing with the commodities in the open market. It was submitted

that considering the gravity of the violations and the fraudulent

intention under the PFUTP Regulations, SEBI with a view to act

diligently has taken immediate preventive measures to prevent

manipulation in the future price of Mentha Oil on the exchange

platform. It was urged that urgent measures were required against

the appellants from indulging in such activities by taking position not

only in Mentha Oil contracts but in other commodities as well, as it

was done with an intention to dominate futures trading. The learned 16

senior counsel contended that by adopting a balancing act, the

impugned order was passed which was reasonable and was done with

a view to protect the interest of the investors and integrity of

securities market. The learned senior counsel, thus, contended that

the interim order required no modification and, in any case, was open

for the appellants to approach the WTM for modification of the

order.

13. Having heard the learned senior counsel at length, we find that

it is no more res integra that SEBI has power to pass ex-parte interim

orders, pending investigation, which power flows from Section 11

and 11B of the SEBI Act. A plain reading of Section 11 and 11B

shows that SEBI has to protect the interests of the investors in

securities and to regulate the securities market by such measures as it

thinks fit and such measures may be for any or all of the matters

provided in sub-section 2 of Section 11 of the Act. SEBI has power

to pass interim orders and such interim orders can also be passed ex-

parte. Interim orders are passed in order to prevent further possible

mischief of tampering with the securities market. If during a

preliminary enquiry, it is found prima-facie, that the person is

indulging in manipulation of the securities market, it would be

obligatory for SEBI to pass an interim order or for that matter an ex- 17

parte interim order in order to safeguard the interests of the investors

and to maintain the integrity of the market. Normally, while passing

an interim order, the principles of natural justice has to be adhered to,

namely, that an opportunity of hearing is required to be given.

Procedural fairness embodying natural justice is to be applied

whenever action is taken affecting the rights of the parties. At times,

an opportunity of hearing may not be pre-decisional and may

necessarily have to be post-decisional especially where the act to be

prevented is imminent or where action to be taken brooks no delay.

Thus, pre-decisional hearing is not always necessary when ex-parte

ad-interim orders are made pending investigation or enquiry unless

provided by the statute. In such cases, rules of natural justice would

be satisfied, if the affected party is given a post-decisional hearing.

14. However, it does not mean that in every case, an ex-parte

interim order should be passed on the pretext that it was imminent to

pass such interim order in order to protect the interest of the investor

or the securities market. An interim order, however, temporary it

may be, restraining an entity/person from pursuing his

profession/trade may have substantial and serious consequences

which cannot be compensated in terms of money.

15. Thus, ex-parte interim order may be made when there is an

urgency. As held in Liberty Oil Mills & Ors. vs. Union of India & 18

Ors. [AIR (1984) SC 1271] decided on May 1, 1984, the urgency

must be infused by a host of circumstances, viz. large scale misuse

and attempts to monopolise or corner the market. In the said

decision, the Supreme Court further held that the regulatory agency

must move quickly in order to curb further mischief and to take

action immediately in order to instill and restore confidence in the

capital market.

16. In the light of the above, we find that on the basis of the

enquiry, the rationale for taking urgent preventive actions is based on

the fact that appellant, NEFM had accumulated/cornered stocks of

Mentha Oil through entities in Group A and Group B by misusing the

exchange platform. Such large accumulation of Mentha Oil was with

the intention of acquiring a dominant position in the market in order

to manipulate the future price of Mentha Oil during the lean season

on the strength of the physical stock of Mentha Oil it held on the

exchange platform.

17. In our opinion, the impugned order is harsh and unwarranted.

We are of the opinion that there was no real urgency at this late stage

in passing an ex-parte restraint order which virtually amounts to

passing a final order. The period of trades is 2017-2018. At the time

when the impugned order was passed the future contracts had been

executed. The lean season was over. There is nothing on record to 19

indicate that the sales made by the appellants was on a higher side

indicating manipulation in the price nor there is any prima-facie,

finding that by accumulating large stocks of Mentha Oil, the

appellant had dominated the market without making any comparison

with the total volume of trades in the physical market. In our

opinion, the basis of urgency was purely on account of presumption

and was not based on any piece of evidence. There should be some

shred of evidence to come to a prima-facie conclusion that the

appellants are indulging in unfair trade practices in cornering the

market with a manipulative intent to manipulate the price. Passing a

restraint order which virtually puts a stoppage on the appellants right

to trade based on a needle of suspicion, in our opinion, is harsh and

unwarranted.

18. In the absence of in depth analysis based on evidence, we are of

the opinion that in the facts and circumstances of the present case, it

was not such an urgent case where the WTM should have exercised

its powers. In our opinion, the respondent is empowered to pass an

ex-parte interim order only in extreme urgent cases and that such

power should be exercised sparingly. In the instant case, we do not

find that any extreme urgent situation existed which warranted the

respondent to pass an ex-parte interim order. We are, thus, of the

opinion that the impugned order is not sustainable in the eyes of law 20

as it has been passed in gross violation of the principles of natural

justice as embodied in Article 14 of the Constitution of India.

Accordingly, the appellants are entitled to the reliefs claimed.

19. At this stage, we can stay the operation of the impugned order.

We, however, find that no useful purpose would be served in keeping

the appeals pending and directing the respondent to file a reply.

Thus, we are deciding the appeals itself, without calling for a reply at

the admission stage itself.

20. Accordingly, the impugned order cannot be sustained and is

quashed in so far as it relates to the appellants. The appellants will

file their objections before the WTM on or before March 25, 2019.

The respondent will provide the appellants an opportunity of hearing

and thereafter if the respondent finds that an interim order is required

to be passed in order to protect the securities market, it will pass such

orders in accordance with law. We further make it clear that any

finding or observation made by us is only tentative and will not

influence the authority while deciding the matter. 21

21. The appeals are allowed. In the circumstances of the case,

there shall be no order as to costs.

Sd/-

Justice Tarun Agarwala Presiding Officer

Sd/-

Dr. C. K. G. Nair Member 12.03.2019 Prepared & Compared by PTM