Order in respect of Nu Pharmalogics Private Limited in the matter of Secunderabad Healthcare Ltd.

WTM/SM/IVD|MRD/ID5|DRMNP/20106/2022-23 SECURITIES AND EXCHANGE BOARD OF INDIA CORAM: S. K. MOHANTY, WHOLE TIME MEMBER ORDER UNDER SECTION 11(1), 11(4) AND 11B OF THE SECURITIES AND EXCHANGE BOARD OF INDIA ACT, 1992 IN THE MATTER OF SECUNDERABAD HEALTHCARE LIMITED In respect of Sr. No. Noticee No. Name of the Noticee PAN 1. 5. Nu Pharmalogics Private Limited AACCN2913J The above-mentioned entity is also referred to as the Noticee number as assigned in the Show Cause Notice dated July 19, 2019)

BACKGROUND 1. Securities and Exchange Board of India (hereinafter referred to as “SEBI”) passed an order dated April 30, 2021 (hereinafter referred to as “SEBI Order”) against 10 entities namely Secunderabad Healthcare Limited (hereinafter referred to as “SHL/Company”) and 9 other entities including Nu Pharmalogics Private Limited (hereinafter referred to as “Nu Pharmalogics”/Noticee no. 5 therein), alleging receipt of equity shares allotted to them by the Company post conversion of warrants for which full consideration was not paid and therefore observed to have got benefited by the Company and further caused loss to the other shareholders of the Company. Further, the proceeding against one allottee i.e., Anvita Trading Co. Private Limited (Noticee no. 9 therein) was disposed of without any direction. The following directions were issued vide the above mentioned SEBI Order: “37) In view of the facts and circumstances of the case and the aforesaid discussions and findings, I, in exercise of the powers conferred upon me under Section 19 read with Sections 11(1), 11(4), 11B of the SEBI Act, 1992 hereby pass following directions: i. The Noticee no. 1 is directed not to access the securities market, directly or indirectly, by issuing prospectus, offer document or advertisement soliciting money from the public for a period of 02 years and is further restrained and prohibited from buying, selling or otherwise dealing in the securities market, directly or indirectly in whatsoever manner, for a period of 02 years.

Order in respect of Nu Pharmalogics Private Limited in the matter of Secunderabad Healthcare Ltd.

ii. The Noticee no. 2 to 8 and 10 are restrained from accessing the securities market and further prohibited from buying, selling or otherwise dealing in securities, directly or indirectly in any manner whatsoever for a period of 02 years from the date of this order. iii. The Noticee no. 1 is directed to collect the balance consideration from the Noticee no. 2 to 8 and 10 and the Noticee no. 2 to 8 and 10 are directed to pay the balance consideration to the Noticee no. 1 in terms of amount shown to be recovered in Table no.-5 of the order. The above collection and payment shall be completed within a period of 60 (sixty) days from the date of this order. iv. The Noticee no. 2 and 3 shall disgorge the wrongful gain of INR 6,85,98,216/- and INR 3,71,22,625/-, respectively with simple interest @ 6% per annum till the date of actual payment. For the purpose calculation of interest, the period shall commence from December 2012 for the Noticee no. 2 and August 2013 for the Noticee no.3, respectively and continue till the date of actual payment made. The wrongful gain of INR 6,85,98,216/- and INR 3,71,22,625/- along with interest shall be remitted by them to Investor Protection and Education Fund (IPEF) as referred to in Section 11(5) of the SEBI Act, 1992, and intimation, if any may be forwarded to “Division Chief, Enforcement Department-1, DRA-4, Securities and Exchange Board of India SEBI Bhavan II, Plot no. C-7, "G" Block, Bandra Kurla Complex, Bandra (E), Mumbai-400 051”.

In case, the Noticee nos. 2 and 3 fail to comply with the said direction, they shall be restrained from accessing the securities market and prohibited from buying, selling or otherwise dealing in the securities market, till the actual payment of disgorgement amount or till the completion of the debarment directed at sub-paragraph (ii) above, whichever is later. v. The Banks, with whom the Noticee no. 2 and 3’s accounts are maintained, are directed that no debit shall be made, without permission of SEBI, in respect of the bank accounts held by them except for the purposes of compliance of this order. vi. The Noticee no. 2 and 3 are directed to furnish details of assets, properties owned directly or indirectly by it respectively and further directed not to dispose of or alienate any of his assets/ properties/ securities, till such time the direction of this order is complied with. vii. The Noticee no. 1 having received the balance consideration as directed in terms of sub-paragraph (iii) above is directed to furnish to SEBI, a Certificate from a Chartered Accountant along with necessary documentary evidencing certifying the compliance of this direction and said Certificate will be furnished within a period of 03 months from the date of this order. viii.

This direction is without prejudice to any other action including action for recovery of such amounts from these Noticees which may be initiated by SEBI. ix. It is further clarified that during the period of restraint, the existing holding of securities including the holding of units of mutual funds of the Noticee nos. 1 to 8 and 10 shall remain under freeze.

Order in respect of Nu Pharmalogics Private Limited in the matter of Secunderabad Healthcare Ltd.

x. Obligation of the aforesaid the Noticee nos. 1 to 8 and 10, in respect of settlement of securities, if any, purchased or sold in the cash segment of the recognized stock exchange (s), as existing on the date of this Order, can take place irrespective of the restraint/prohibition imposed by this Order, only in respect of pending unsettled transactions, if any. Further, all open positions, if any, of the aforesaid Noticees in the F & O segment of the stock exchange, are permitted to be squared off, irrespective of the restraint/prohibition imposed by this Order. xi. In light of my observations noted at paragraph 26 of this Order, proceeding against the Noticee no. 9 is disposed of without any direction.” 2. Aggrieved by the above SEBI Order, the Noticee no. 5 filed Appeal no. 811 of 2021 before the Hon’ble Securities Appellate Tribunal (hereinafter referred to as “SAT/Tribunal”). The Hon’ble SAT vide its order dated August 03, 2022 allowed the aforesaid appeal and remitted the matter to SEBI for reconsideration. The Hon’ble SAT further directed the Noticee no. 5 to appear before SEBI on September 05, 2022. 3. In this regard, I note that SEBI had issued a Show Cause Notice dated July 19, 2019 (hereinafter referred to as “SCN”) to the Noticees (including the Noticee no. 5) asking them to show cause as to why appropriate directions should not be issued against them under Sections 11(1), 11B and 11(4) of the Securities and Exchange Board of India Act, 1992 ( hereinafter referred to as “SEBI Act, 1992”) for allegedly violating Section 12A(a),(b),(c) of the SEBI Act, 1992, regulation 3(a),(b),(c),(d) and 4(1) of the SEBI (Prohibition of Fraudulent and Unfair Trade Practices Relating to Securities Market) Regulations, 2003 (hereinafter referred to as “PFUTP Regulations”) and regulations 77(1) and 77(3) of the SEBI (Issue of Capital and Disclosure Requirements) Regulations, 2009 (hereinafter referred to as “ICDR Regulations”).

4. The brief facts pertaining to the Noticee no. 5 that are necessary for the disposal of the matter at hand, as contained in the SCN, are as under: 4.1 On October 14, 2010, SHL had allotted 8,00,00,000 warrants convertible into 8,00,00,000 equity shares of INR 10 each for cash at a premium of INR 8.60 per share on preferential basis to 27 non-promoter entities on the following terms of payment: (a) At least 25% shall be payable before the allotment of warrants and balance on or before 18 months from the date of allotment or else the money received for the allotment of warrants shall be forfeited by the Company. (b) In the event convertible warrants are issued, the same shall at the option of the allottee, be converted into equivalent number of equity shares in one or more tranches but before expiry of 18 months from the date of allotment.

Order in respect of Nu Pharmalogics Private Limited in the matter of Secunderabad Healthcare Ltd.

4.2 Upon first tranche of conversion of warrants to shares, SHL allotted 4,00,96,000 equity shares to 13 entities on March 02, 2011 and the said shares were under lock-in till March 01, 2012. Pursuant to second tranche of conversion of warrants into shares on March 31, 2012, SHL allotted 3,99,04,000 equity shares to 16 entities (including the Noticee no. 5) and the said shares were also under lock-in till March 30, 2013. 4.3 From the analysis of the information gathered during the investigation including the information provided by SHL vide its email dated September 10, 2018 regarding the funds received from 15 out of the 27 allottees, it was observed that there were variations (i.e. either excess or shortage of amounts due to refunds of money by the Company to allottees) in the funds received from certain allottees. Therefore, SHL was asked to furnish detailed information in this regard, however, no proper information was provided regarding such variations despite reminders sent advising SHL to provide information regarding such variations. 4.4 In view of the above, it has been alleged in the SCN that the Noticee no. 5 had received equity shares allotted to it by the Company post conversion of warrants, without paying the full consideration.

Since, the documents furnished in the course of investigation do not show with sufficient evidences that the Noticee no. 5 had paid full consideration for the conversion of warrants into equity shares, the Noticee no. 5 was alleged to have been unduly benefited by the Company and by its act of non-payment of full consideration has caused loss to the other shareholders of the Company. 4.5 It is further noticed that the Noticees (including the Noticee no. 5) were enjoying connection to the Company i.e., SHL/promoters of SHL through a network of common directors. 4.6 It has also been noticed that although the Company at that time gave a public impression of capital infusion through preferential allotment, but in reality, the Company, inter-alia, allotted shares to the Noticee no. 5 without receiving full consideration from it thereby providing huge amount of monetary benefit to it. Therefore, SHL and other allottees including the Noticee no. 5 are alleged to have perpetrated a fraud on the shareholders and the ordinary investing public who had transacted in the shares of the Company post preferential allotment.

REPLY, PERSONAL HEARING AND SUBMISSIONS 5. SEBI vide email dated August 30, 2022 informed the Noticee no. 5 that an opportunity of personal hearing has been granted to it on September 05, 2022 in terms of the aforesaid SAT order. In response to the said email, the Noticee no. 5 vide email dated September 05, 2022 has stated that it wants to engage a lawyer who is specialized in the securities markets laws to deal with the SCN dated July 19, 2019 and thus needs 7 days’ further time to file the reply in this Order in respect of Nu Pharmalogics Private Limited in the matter of Secunderabad Healthcare Ltd.

regard. The said request was acceded to. Accordingly, the Noticee no. 5 has filed reply vide letter dated September 12, 2022 wherein it has also requested that an opportunity of personal hearing be granted to it. After receipt of the aforesaid written reply and in compliance with the principle of natural justice, an opportunity of personal hearing was granted to the Noticee no. 5 on September 20, 2022 which was communicated to the Noticee no. 5 vide email dated September 14, 2022. On the scheduled date of personal hearing held through video conferencing, the Noticee no. 5 appeared through its AR and made oral submission on the lines of its aforesaid written reply already filed before me. 6. The submissions of the Noticee no. 5 made through written reply as well as oral arguments advanced before me are summarized as under: a) The SCN is issued with a delay of over 9 years from the date of the transactions and on this ground of delay alone the SCN is liable to be set aside. Section 11B of the SEBI Act is a drastic power and the same cannot be exercised with such a delay. b) Learned Adjudicating Officer has issued show cause notice dated December 31, 2019 on the same cause of action and for similar violations.

Thus, the Noticee is a victim of multiple proceedings and on this ground also the SCN needs to be quashed. c) It appears that the SCN was issued to the Noticee no. 5 on account of non-furnishing of information by the SHI, w.r.t. to the considerations received by it from the allottees including the Noticee no. 5. Pertinently, the fact remains that the amount/consideration which is alleged to have not been paid by the Noticee no. 5 to SHL has actually been paid well before the due dates. d) The Noticee no. 5 has paid full consideration towards its respective subscription of the equity shares of the Company at the relevant time and the Noticee no. 5 reiterates that there is nothing due and payable to SHL on part of the Noticee no. 5 w.r.t. the shares allotted to it or otherwise. Therefore, it cannot be said that SHL has issued the shares on preferential basis to the Noticee no. 5 without receiving full consideration from it and it cannot be said that the Noticee no. 5 has received the equity shares without paying full consideration. e) As per the Annual Reports of the Company for the years 2010 and 2011 which are available in the public domain (published on the BSE Ltd.) the auditors of the Company had recorded, receipts of the entire consideration by the Company towards issue and conversion of convertible warrants issued by SHL.

Moreover, no qualification has been given by the auditor in the Annual Report w.r.t. conversion of warrants and consideration received by the Company towards the same. f) While issuing the SCN, SEBI has not considered that there was substantial compliance of applicable provisions of laws on the part of the Noticee no. 5 and all payments were Order in respect of Nu Pharmalogics Private Limited in the matter of Secunderabad Healthcare Ltd.

made by the Noticee no. 5 to SHL before the due dates. Hence, there are no violations on the part of the Noticee no. 5 under the ICDR Regulations. g) Since the full consideration has been paid to the Company, the Noticee no. 5 denies that it has received any undue benefit at the cost of other shareholders of the Company and therefore, it is also wrong to allege that the Noticee no. 5 was part of a fraudulent arrangement through which it had perpetuated fraud on the other allottees, shareholders and also on the ordinary investing public who had transacted in the shares of the SHL post issuance of the aforesaid preferential allotment and thereby has violated the provisions of Section 12A(a),(b),(c) of the SEBI Act, 1992, regulation 3(a),(b),(c),(d) and 4(1) of the PFUTP Regulations, 2003 h) The allegation made in the SCN showing how the connection, led to an alleged violation of the PFUTP Regulations by the Noticee no. 5, is entirely baseless and without any evidence on record or otherwise. Insofar as linkage through common directors is concerned, SEBI has failed to demonstrate as to how the Noticee no. 5 has acted in concert with such other Noticees for the purpose of non-payment of consideration towards conversion of warrants issued on preferential basis.

Thus, the allegations of the violation of the PFUTP Regulations against the Noticee no. 5 as set out in the SCN, do not hold any ground and therefore SCN may be set aside. i) When the amount of consideration for the issue of warrants is already paid to SHL by the Noticee no. 5 the present SCN does not stand the test of the trite law and has to be disposed of accordingly. j) Without prejudice to the aforesaid, the alleged violations in the SCN if any, are mere lacuna on the part of the Company and no wrong doing can be attributed to the Noticee no. 5. k) The Company vide its disclosure dated April 03, 2012 made on the BSE Ltd. regarding outcome of the Board meeting held on March 31, 2012 has disclosed as under: “Secunderabad Healthcare Ltd has informed BSE that the Board of Directors of the Company at its meeting held on March 31, 2012, has decided to issue and allot equity shares in lieu of Convertible Equity Warrants to the allottees consequent to their exercising option to convert warrants by paying balance 75% consideration towards the same.” CONSIDERATION 7. I have perused the allegations and facts recorded in the SCN, the submissions made on behalf of the Noticee no. 5 and the other materials available on record.

In my view, the only issue that needs adjudication in the present proceedings is whether or not, the Noticee no. 5 has received Order in respect of Nu Pharmalogics Private Limited in the matter of Secunderabad Healthcare Ltd.

equity shares allotted to it by the Company post conversion of the warrants, after paying the full consideration for the said shares allotted to it, to the Company? 8. Before adverting to the factual conspectus of the case, I note that the Noticee no. 5 has been alleged to have violated applicable provisions of SEBI Act, 1992, the PFUTP Regulations and the ICDR Regulations. Therefore, the said provisions are reproduced hereunder for ease of reference and better appreciation: The SEBI Act, 1992 Prohibition of manipulative and deceptive devices, insider trading and substantial acquisition of securities or control. 12A. No person shall directly or indirectly— (a) use or employ, in connection with the issue, purchase or sale of any securities listed or proposed to be listed on a recognized stock exchange, any manipulative or deceptive device or contrivance in contravention of the provisions of this Act or the rules or the regulations made thereunder; (b) employ any device, scheme or artifice to defraud in connection with issue or dealing in securities which are listed or proposed to be listed on a recognized stock exchange; (c) engage in any act, practice, course of business which operates or would operate as fraud or deceit upon any person, in connection with the issue, dealing in securities which are listed or proposed to be listed on a recognized stock exchange, in contravention of the provisions of this Act or the rules or the regulations made thereunder; The PFUTP Regulations, 2003 3. Prohibition of certain dealings in securities No person shall directly or indirectly – (a) buy, sell or otherwise deal in securities in a fraudulent manner; (b) use or employ, in connection with issue, purchase or sale of any security listed or proposed to be listed in a recognized stock exchange, any manipulative or deceptive device or contrivance in contravention of the provisions of the Act or the rules or the regulations made there under; (c) employ any device, scheme or artifice to defraud in connection with dealing in or issue of securities which are listed or proposed to be listed on a recognized stock exchange; (d) engage in any act, practice, course of business which operates or would operate as fraud or deceit upon any person in connection with any dealing in or issue of securities which are listed or proposed to be listed on a recognized stock exchange in contravention of the provisions of the Act or the rules and the regulations made there under.

4. Prohibition of manipulative, fraudulent and unfair trade practices (1) Without prejudice to the provisions of regulation 3, no person shall indulge in a manipulative, fraudulent or an unfair trade practice in securities markets. Explanation.–For the removal of doubts, it is clarified that any act of diversion, misutilization or siphoning off of assets or earnings of a company whose securities are listed or any concealment of such act or any device, Order in respect of Nu Pharmalogics Private Limited in the matter of Secunderabad Healthcare Ltd.

scheme or artifice to manipulate the books of accounts or financial statement of such a company that would directly or indirectly manipulate the price of securities of that company shall be and shall always be deemed to have been considered as manipulative, fraudulent and an unfair trade practice in the securities market. The SEBI(ICDR) Regulations, 2009 Payment of consideration. 77. (1) Full consideration of specified securities other than warrants issued under this Chapter shall be paid by the allottees at the time of allotment of such specified securities: Provided that in case of a preferential issue of specified securities pursuant to a scheme of corporate debt restructuring as per the corporate debt restructuring framework specified by the Reserve Bank of India, the allottee may pay the consideration in terms of such scheme. (2) An amount equivalent to at least twenty-five per cent. of the consideration determined in terms of regulation 76 shall be paid against each warrant on the date of allotment of warrants. (3) The balance seventy-five per cent of the consideration shall be paid at the time of allotment of equity shares pursuant to exercise of option against each such warrant by the warrant holder.

9. I note from the SCN that the allegation against the Noticee no. 5 is that it had received equity shares allotted to it by the Company post conversion of warrants for which adequate consideration was not paid to the Company and thus the Noticee no. 5 was benefited by the Company at the cost of other shareholders of the Company. The aforesaid acts of the Noticee no. 5 have been alleged to be in violation of Section 12A(a), (b), (c) of the SEBI Act, 1992, regulation 3(a), (b), (c), (d) and 4(1) of the PFUTP Regulations and regulations 77(1) and 77(3) of the ICDR Regulations. 10. In this respect, I find that the SCN provides the details of preferential allotment of warrants, conversions of warrants into equity shares, allotment of equity shares to the Noticee no. 5, total consideration that the Noticee no. 5 was required to pay to the Company and the actual payment made by the Noticee no. 5 to the Company (against the warrants/ equity shares pursuant to conversion of warrants), which for the sake of reference and understanding are summarised here under: Table no.-1 Noticee Preferrential Warrant Total Date of Amount Amount to No. Allotees/ / Shares consideration Conversion to paid by the be paid or Noticee no. allotted to be paid Equity Shares allottees recovered March March (in INR) from the 02, 2011 31, allottees.

(in 2012 INR) 5 Nu Pharmalogics 36,00,000 6,69,60,000 √ 1,67,50,000 5,02,10,000 Private Limited Order in respect of Nu Pharmalogics Private Limited in the matter of Secunderabad Healthcare Ltd.

11. From the perusal of the material on records, more specifically the details of payments so made by the Noticee no. 5, in the bank accounts of the Company i.e. A/c no. 000684000002574 with Yes Bank and A/c no. 3230011029725 with Kotak Mahindra Bank (in which funds towards preferential allotment were received by the Company from the allottees including the Noticee no. 5) and from the detail of funds transactions/transfers submitted by the Company, I note that the SCN narrates the details of payments received by the Company from the Noticee no. 5 as under: i. Nu Pharmalogics Private Limited-Noticee no.5: The Noticee no. 5 was required to pay INR 6,69,60,000 for subscription of 36,00,000 shares @ INR 18.60 per share. The Company has provided details regarding the receipt of only 25% of the total consideration from the Noticee no. 5. This was supported by the transactions noticed in the bank account statements of the Company, it was noticed that the Noticee no. 5 had transferred INR 1,67,50,000 (from account 07220100013031-Development Credit Bank) to the bank account of the Company through multiple transactions between August 12, 2010 and October 06, 2010 which is equivalent to only 25% of the subscription amount. 12. I note that the Noticee no. 5 has now filed reply in rebuttal to the aforesaid allegations made in the SCN stating that the allegation pertaining to allotment of shares pursuant to conversion of warrants without payment of consideration is wrong. It has further submitted that it has already paid remaining consideration of 75% to the Company much before the due date set out for the payment of consideration as per terms of payment mandated by the Company. The Noticee no. 5 has now furnished the details of the total payment which it had made to the Company against the allotment of shares to it, which are detailed as under: Table no.-2

Nu Pharmalogics Private Limited -Noticee no.5 Date Amount (in INR) Due Date Remarks August 26, 2010 90,00,000 October 14, 2010 25 percent paid August 26, 2010 76,50,000 October 14, 2010 October 07,2010 1,00,000 October 14, 2010 March 15, 2012 69,00,000 March 31, 2012 75 percent paid March 19, 2012 75,00,000 March 31, 2012 March 20, 2012 60,00,000 March 31, 2012 March 21, 2012 63,50,000 March 31, 2012 March 22, 2012 1,75,00,000 March 31, 2012 March 23, 2012 50,00,000 March 31, 2012 March 26, 2012 10,00,000 March 31, 2012 Total 6,70,00,000

Order in respect of Nu Pharmalogics Private Limited in the matter of Secunderabad Healthcare Ltd.

From a perusal of the copy of the bank statements of DCB Bank and Yes Bank furnished by the Noticee no. 5 in support of its afore-stated claims of having paid full consideration including the remaining 75% of total consideration against the allotment of warrants and equity share, I find that different sums of money on different dates aggregating to total consideration required to be paid by the Noticee no. 5 as indicated in Table no.-2 above have indeed been transferred from the respective bank accounts of the Noticee no. 5 to the bank account of the Company (as indicated in paragraph 10 above) during the period from August 26, 2010 to March 26, 2012. The said receipt of funds gets corroboration from the amounts paid in tranches by the Noticee no. 5 as shown in the above table from its respective bank accounts on the respective dates. I therefore find that the Noticee no. 5 has furnished sufficient evidence in supports of its claims that it had paid full consideration to the bank account of the Company. 13. The Noticee no. 5 has also brought attention to the statement made in the 20th Annual Report of the Company for the year 2010-11 in support of its claim which shows that the auditors have in fact recorded about the receipts of the entire consideration by the Company towards issue and conversion of convertible warrants issued by SHL.

Further, it has also been brought to my notice that the Company vide its disclosure dated April 03, 2012 made on the BSE Ltd., (while disclosing the outcome of the Board meeting held on March 31, 2012) had duly disclosed that the Company has decided to issue and allot equity shares in lieu of Convertible Equity Warrants to the allottees consequent to its exercising of option to convert warrants against the receipt of balance 75% consideration towards the same. Therefore, having considered the materials on record, I am of the view that the Noticee no. 5 is successful in rebutting the allegations made against it in the SCN by establishing that it had indeed paid full consideration towards the allotment of warrants as well as the equity shares post the conversion of those warrants. I am therefore, in the absence of any evidence to the contrary on record, inclined to grant exoneration to the Noticee no. 5 by accepting its submission that it has actually paid the remaining 75% of the consideration to the Company and thus in effect, has paid the full consideration to the Company towards this purpose.

14. In view of the facts and circumstances of this case and aforesaid discussions, I hold that the Noticee no. 5 has paid full and adequate consideration to the Company towards allotment of equity shares of SHL as mentioned in Table-1 above as per the terms of payment mandated by the Company. In view of the aforesaid finding, I do not find it necessary to deal with other submissions of the Noticee no. 5 made vide it aforesaid reply. DIRECTION 15. In view of the facts and circumstances of the case and the aforesaid discussions and findings, I, in exercise of the powers conferred upon me under Section 19 read with Sections 11(1), 11(4), 11B of the SEBI Act, 1992 hereby pass following direction: Order in respect of Nu Pharmalogics Private Limited in the matter of Secunderabad Healthcare Ltd.

i. The Show Cause Notice dated July 19, 2019 issued against the Noticee no. 5 i.e., Nu Pharmalogics Private Limited (PAN No.: AACCN2913J) is disposed of without any direction. 16. This Order shall come into force with immediate effect. 17. A copy of this Order shall be served upon the recognized Stock Exchanges, Depositories, Registrar and Transfer Agents and all the banks for necessary compliance.

Sd/- DATE: OCTOBER 03, 2022 S. K. MOHANTY PLACE: MUMBAI WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA

Order in respect of Nu Pharmalogics Private Limited in the matter of Secunderabad Healthcare Ltd.