Order in respect of (1) Spearhead Metal & Alloys Limited and its directors, namely, (2) Mr. Ashwin Kumar Suresh Kumar Sharma, (3) Mr. Akhilesh Kumar Singh, (4) Mr. Jayaprasad Ramakrishna Pillai, (5) Mr. Sumesh Bharat Aggarwal and (6) Mr. Bharat Bhushan Shyamlal Aggarwal

WTM/RKA/EFD/DRA II/88/2016 BEFORE THE SECURITIES AND EXCHANGE BOARD OF INDIA ORDER UNDER SECTION 11B OF THE SECURITIES AND EXCHANGE BOARD OF INDIA ACT, 1992 In respect of (1) Spearhead Metal & Alloys Limited and its directors, namely, (2) Mr. Ashwin Kumar Suresh Kumar Sharma, (3) Mr. Akhilesh Kumar Singh, (4) Mr. Jayaprasad Ramakrishna Pillai, (5) Mr. Sumesh Bharat Aggarwal and (6) Mr. Bharat Bhushan Shyamlal Aggarwal 1. Spearhead Metal & Alloys Limited (hereinafter referred to as ‘the company’) is a listed company having its office address at Ladam House, Opp. I.T.I. M Road, W.I.E., Thane 400 604. SEBI vide its circular no. CIR/OIAE/1/2012 dated August 13, 2012 directed all listed companies to obtain SEBI Complaints Redress System (SCORES) authentication by September 14, 2012 and to take appropriate necessary steps within seven days of receipt of complaints through SCORES, so as to resolve the complaint within thirty days of its receipt. 2. Thought, Spearhead Metal & Alloys Limited did obtain SCORES authentication it failed to resolve twelve pending investor complaints. SEBI issued Show Cause Notices (SCNs) dated March 28, 2013, April 17, 2013 and October 13, 2014 to the company and its directors, namely, Mr. Ashwin Kumar Suresh Kumar Sharma, Mr. Akhilesh Kumar Singh, Mr. Jayaprasad Ramakrishna Pillai, Mr. Sumesh Bharat Aggarwal and Mr. Bharat Bhushan Shyamlal Aggarwal (hereinafter collectively referred to as "the noticees"), calling upon them to show cause as to why suitable directions including direction to restrain them from accessing the securities market for a specified period should not be passed under section 11B of the SEBI Act. The company vide its letter dated April 15, 2013 submitted its reply to the SCNs. 3. Opportunity of personal hearing was granted to the noticees on June 14, 2016. Ms. Neha Gada, authorised representative and Ms. Sugandha Rane, Compliance Officer of the company appeared on behalf of the noticees and submitted that now all the pending investor grievances have been redressed. Ms. Gada also filed the noticees' submissions vide letter dated June 09, 2016.

In the matter of Shearhead Metals & Alloys Ltd.

4. SEBI has also verified and confirmed that all the said twelve investor grievances have been resolved. Considering the above facts and circumstances of the case, I am of the view that there is no need to pass any direction under section 11B of the SEBI Act, 1992 against Spearhead Metal & Alloys Limited and its directors as contemplated in the SCNs issued to them. The SCNs are accordingly disposed of.

Sd/- Date: July 28th, 2016 RAJEEV KUMAR AGARWAL Place: Mumbai WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA