Order in the matter of M/s Sheen Agro & Plantations Ltd.

WTM/RKA/NRO/CIS/135/2014 BEFORE THE SECURITIES AND EXCHANGE BOARD OF INDIA ORDER Under sections 11 and 11B of the Securities and Exchange Board of India Act, 1992 read with regulations 65 of the Securities and Exchange Board of India (Collective Investment Schemes) Regulations, 1999 in the matter of Sheen Agro & Plantations Ltd. In respect of (1) Sheen Agro & Plantations Ltd. and its directors, namely (2) Mr. Ajeet Lal Sharma), (3) Mr. Angrez Singh Bhadwal, (4) Mr. Surinder Kr. Trilokia, (5) Mr. Nasib Singh Pawar, (6) Mr. R. S. Bhau, (7) Mr. Brita Singh Bhau, (8) Mr. Kamal Singh Bhau, (9) Mr. Yograj Singh Bhau, (10) Mr. Tej Pal Singh, (11) Mr. Shyam Lal Pahwa, (12) Mr. Sohan Singh, (13) Ms. Renu Bala, (14) Mr. Pawan Kumar Khajuria, (15) Ms. Anita Sharma, (16) Mr. Kirpal Singh, (17) Mr. Sudershan Singh Jamwal and (18) Mr. Gurpreet Singh (hereinafter collectively referred to as "the noticees" or by their respective names).

1. Sheen Agro & Plantations Ltd (hereinafter referred to as 'Sheen Agro' or 'the Company'), on October 16, 2003 had filed a Winding up and Repayment Report (WRR) under the provisions of the SEBI (Collective Investment Schemes) Regulations, 1999 (hereinafter referred to as 'CIS Regulations'). As per the WRR, on May 01, 2003, out of 3,076 investors to whom the Information Memorandum was circulated by the Company, 2,958 investors had given positive consent to continue with the schemes and the remaining 118 investors were refunded the amount mobilized from them. It was observed from the WRR that against an amount of ₹2.34 crores mobilized from 3,076 investors, an amount of ₹22.42 lakhs was repaid to 118 investors. 2. Securities and Exchange Board of India (hereinafter referred to as "SEBI") received several complaints in 2006 alleging that Sheen Agro has not repaid the amount due to its investors on maturity of their investments made in the scheme/s of the Company, during the period 2002-2004. Further, letters were also sent to the investors seeking additional information. It was observed that in year 2004, Sheen Agro had accepted investments from the public even after furnishing WRR report to SEBI. 3. During the period 2008-10, SEBI had sent many letters and reminders to Sheen Agro inquiring about the status of repayment and redressal of investor complaints. As the Company failed to submit the information sought by SEBI despite repeated extension of time, a Show Cause Notice dated February 24, 2010 (SCN) under section 11B of the SEBI Act, 1992 read with regulation 65 of the CIS Regulations was issued to the noticees. Order in the matter of Sheen Agro & Plantations Ltd.

4. Mr. Nasib Singh Pawar, Mr. Surinder Kumar Trilokia and Mr. Angrez Singh Bhadwal, who were directors of the Company, vide their letter dated March 12, 2010 replied to the SCN and inter alia made submissions that: i. In May 2004, the then directors of the Company were asked by its promoters, viz., Mr. Brita Singh Bhau and his family members, to resign from the Company. ii. Therefore, the then directors signed a Memorandum of Understanding on May 15, 2004 and ceased to be directors of Sheen Agro with effect from May 29, 2004. 5. Mr. Brita Singh Bhau, Mr. R. S. Bhau and Mr. Yograj Singh Bhau vide their letters dated March 13, 2010 replying to the SCN issued to them submitted that they had resigned from the post of director of Sheen Agro with effect from September 22, 1998, June 16, 1998, and November 26, 2005, respectively, and have no affairs with the Company from the date of their respective resignations. Further, Mr. Baldev Singh Bhau informed that his father, Mr. Brita Singh Bhau ceased to be director of the Company from June 23, 1998 and had passed away in December 2000. However, Mr. Baldev Singh Bhau has failed to submit any documentary proof in support of this.

6. In response to the SCN, the Company replied vide letter dated March 15, 2010 and made submissions as under: i. The Company has started redressing the complaints and has deposited a sum of ₹3 lakhs with the appropriate authority as directed by the Court. ii. Company is in the process of repaying its other depositors and has paid a sum of ₹50 lakhs during 2009. 7. Opportunities of personal hearing were given to the noticees on July 31, 2010, September 03, 2010, February 15, 2011 and November 23, 2012. It was observed that the hearing notices issued to some of the noticees returned undelivered. Accordingly, a public notice to this effect that SCN was issued to the noticees and personal hearings were scheduled, was published in newspapers. 8. Mr. Nasib Singh Pawar, Mr. Angrez Singh and Mr. Sureinder Kr Trilokia appeared for personal hearing on July 31, 2010 and informed that they were directors of the Company till May 2004 and subsequently, the promoters of the Company had taken over the functioning of the Company. 9. SEBI received a letter dated August 12, 2010 from Mr. Sohan Singh, who informed that he has left the services of the Company on April 24, 2000. 10. Vide letter dated September 01, 2010, the Company made further submissions as under:

i. The following three persons are directors in the Company viz., Mr. Ajeet Lal Sharma, Mr. Yog Raj Singh Bhau and Mr. Sham Lal Pahwa. Mr. Ajeet lal Sharma was appointed as director on March 19, 2005. Mr. Sham Lal Pahwa was first appointed as director on May 29, 2004. ii. Mr. Yograj Singh Bhau is the director who represents promoters of the Company and took over from the old directors of the Company on May 29, 2004. However, Mr. Yograj Singh is not co-operating and evading SEBI proceedings. iii. Company has not mobilized fresh funds after filing the WRR. However, with the concurrence of the members, some of the accounts were renewed due to financial strains on the Company. iv. The Company is in the process of redressing complaints of all such investors. Out of the ten complaints forwarded by SEBI, the Company has redressed eight complaints and made part payment to the ninth complainant. The Company is pursuing the tenth complainant for out of court settlement. 11. During the course of hearing on September 03, 2010, the Company’s directors (who were present for the hearing) were directed to submit a tentative schedule of repayments to the investors of the Company and a bi-monthly status report of repayments made by the Company to its investors.

12. Vide letter dated September 06, 2010, the Managing director of the Company, Mr. Ajeet Lal Sharma, submitted the following: i. Repayments of ₹50 lakhs were made during FY 2008-2009; ii. Repayments of ₹ 42 lakhs were made during FY 2009-2010; iii. Repayments of ₹ 14 lakhs were made during 1st Quarter of FY2010-2011; iv. Tentative outstanding liability to the investors as on June 30, 2010 was ₹432 lakhs; v. The Company undertook to wind up the complete scheme and make payments to all the investors in the time stipulated by SEBI. 13. Vide letter dated September 11, 2010, the Company submitted that the tentative outstanding liability of ₹432 lakhs and the interest accrued on this liability would be repaid from the fixed assets, i.e., lands and from recovering loans and advance from the debtors. The Company has submitted that it is having fixed assets worth ₹120 lakhs and loans and advances worth ₹530 lakhs. It was also informed that the directors of the Company are going to put equity in the Company. 14. Vide letter dated October 09, 2010 and letter dated December 08, 2010, the Company made submissions with respect to the repayment plan as under:

i. Half yearly tentative repayment plan: Particulars Amount (in ₹lakh) Total outstanding liability to the investors as on June 30, 2010 432 Amount repaid during October to November 30, 2010 23 Balance as on March 31, 2011 347 Interest accrued upto March 31, 2011 128 Total Liabilities as on March 31, 2011 575 ii. Source of Funds Particulars Upto Upto Upto Upto Sep 30, 2011 Mar 31, 2012 Sep 30, 2012 Mar 31, 2013 Recoveries from 80 90 100 150 Loans Sale of Fixed Assets 60 50 10 - Fresh induction of 40 40 50 35 capital by director Total 180 180 160 185

Application of Funds Particulars Upto Upto Upto Upto Sep 30, 2011 Mar 31, 2012 Sep 30, 2012 Mar 31, 2013 Recurring and Operational 15 15 15 15 Expenses Repayment to 140 145 130 160 Depositors Payment of Interest 25 20 15 10 Total 180 180 160 185

Balance Liabilities As on Sep 30, 2011 As on March As on Sep 30, As on March 31, 2013 31, 2012 2012 435 290 180 Nil iii. As regards cooperation of main promoter-director vis-à-vis requisite authority to manage the affairs of the Company, it was confirmed that the management had the requisite authority to manage the affairs since they were in majority.

iv. Though the promoter Mr. Brita Singh Bhau had resigned from the post of director of the Company, he was controlling the affairs of the Company through his proxy director Mr. Yograj Singh, who is his son. Vide Memorandum of Understanding (MoU) entered into between the present management and erstwhile management, Mr. Brita Singh Bhau took control of the Company through Mr. Yograj Singh. Mr. Brita Singh Bhau has signed the MoU as identifier of Mr. Yograj Singh. 15. It was noted that the Company had submitted only part information and had not submitted information pertaining to investors whose original investments were renewed and details of repayments to be made to investors whose original investments were not renewed as on September 30, 2011. Meanwhile, SEBI received another complaint dated November 27, 2010 from persons who deposited money in the Reasi Branch of Sheen Agro at the time when Mr. Nasib Singh Jamwal was the Branch manager. It was alleged in the complaint that Mr. Nasib Singh Jamwal had assured them that their money would be paid back at the time of maturity, but Mr. Nasib Singh was absconding for the past six months. The complaint was forwarded to the Company vide letter dated December 08, 2010 and the Company was advised to redress the grievance of the investors. 16. Mr. Ajeet Lal Sharma, Mr. Nasib Singh Pawar and Mr. Angrez Singh Bhadwal had appeared for personal hearing in the matter on February 15, 2011 and the Company and its directors were advised to submit a comprehensive list of investors along with the dues (principal and interest) payable to them by April 30, 2011. Further, it was informed by SEBI that the submissions of the Company regarding payment to investors would be audited by independent auditors.

17. The Company informed that it has repaid an amount of ₹28 lakhs during December 01, 2010 to January 31, 2011. In this way, the Company had made a total payment of ₹51 lakhs during October 2010 to January 2011. The Company also made the following submissions: i. Amount of renewed deposits due for repayment upto Sep 30, 2010 shall be repaid upto Sep 30, 2011. ii. Amount of renewed deposits due for repayment after Sep 30, 2010 shall be repaid upto March 2012. iii. The amount due for repayment upto Sep 30, 2010 and has not been renewed is being paid along with renewed deposits and that whose deposit has matured first shall be repaid first.

Particulars Amount (in ₹lakh) Total amount of liability as on September 30, 2010 407.00 Interest Accrued 228.00

Total 635.00 Amount of renewal deposit, due for repayment upto Sep 30, 112.00 2010 Amount of renewed deposit, due for repayment after Sep 30, 86.78 2010 Amount of deposit not renewed, but due for repayment upto 114.36 Sep 30, 2010

18. Further, the Company vide letter dated April 12, 2011 informed that it needs more time to prepare details about the complete list of investors and sought for extension of time of 15 days. 19. Meanwhile, SEBI received two complaints dated May 09, 2011 wherein the complainants have stated that Sheen Agro has failed to repay the amounts due against certain investments made by the complainant. The complaint was forwarded to the Company, but returned undelivered. 20. Vide letter dated May 14, 2011, the Company submitted part information about the list of its investors and sought further time to submit complete information. Subsequently, vide letter dated June 09, 2011 the Company submitted copy of Application form, brochure and receipt. SEBI vide letter dated August 26, 2011 forwarded the various complaints received by SEBI and advised the Company to redress the same and also submit the information sought by SEBI. In response, the Company sought further time vide letters dated September 05, 2011 and vide letter dated September 19, 2011 submitted part information about list of depositors. Further, the Company also informed that some of the deposit ledgers have been retained by CBI in connection with complaints of depositors and hence complete information could not be submitted. Even after a substantial lapse of time, the Company did not submit the complete information sought by SEBI. 21. Since the instant proceedings had commenced and continued before the then Whole Time Member who demitted office, in observance of principles of natural justice further opportunity was provided to the noticees before me. However, the hearing notices issued to some of the noticees were returned undelivered. Mr. Pawan Kumar Khajuria, Mr. Tejpal Singh, Mr. Kamal Singh, Mr. Sudershan Singh, Mr. Surinder Kr. Trilokia, and Mr. Ajeeet Lal Sharma had appeared before me on November 23, 2012 and made oral submissions. 22. Mr. Kamal Singh made submissions as under: i. He was a peon in the Company, and did not know to read and write.

ii. He was asked to sign on some documents by Mr. Brita Singh Bhau, and was not aware that he was made director of the Company until he was asked to resign in May 2004. iii. He has not attended any meetings of the Company as a director. iv. He has not collected any money from the public. 23. Mr. Tejpal Singh submitted that he and his father Mr. Sudershan Singh Jamwal were asked to sign some documents by Mr. A. S. Bhadwal, who is their relative. Further, they also made deposits of around ₹30-40 lakhs in the Company. However, when they approached Mr. Brita Singh Bhau or Mr. A. S. Bhadwal for their money, they were assured that the money will be refunded later. Only when they were asked to resign from the Company did they realize that they were directors of the Company. 24. Mr. Ajeet Lal Sharma made the following submissions: i. He worked as a Manager in the Company from 1996 to 2005. As a Manager, he used to collect Deposits from the public, and the money was deposited in the Head Office. ii. On March 19, 2005 he was made director, and subsequently Managing Director of the Company. iii.

From 2004 to 2008, no fresh deposits were collected, but only old deposits were renewed. Further, after 2008, no deposits were renewed. iv. During January 2011, Company has repaid ₹51 lakhs, and subsequently, upto September 2012, Company has repaid upto ₹36.74 lakhs. v. The Hon'ble Jammu and Kashmir High Court stayed the disposal of the properties of the Company. When the stay by the Hon'ble High Court would be vacated, repayments would be made as per the earlier schedule submitted to SEBI. 25. Mr. Surinder Kr. Trilokia submitted that he was made the director of the Company in 1999 and upto May 29, 2004. However, he has informed that during that period the money that was collected from public were handled by Mr. Brita Singh Bhau, Mr. A. S. Bhadwal and Mr. Nasib Singh. 26. Further, on November 20, 2012 Mr. Naseeb Singh visited SEBI New Delhi office, marked his attendance in the visitor register but did not appear for the scheduled hearing. Therefore, further opportunities were granted to Mr. Naseeb Singh on January 30, 2014, February 14, 2014 and March 04, 2014. However, Mr. Naseeb Singh did not avail the opportunities provided to him.

Considering the facts and circumstances that the noticees have been provided with sufficient opportunities in this case, I deem it appropriate to proceed in this matter. I have considered the oral and written submissions of Sheen Agro and its past and present directors, the documents furnished by Sheen Agro, material received from RoC, Jammu and Kashmir and the material available on record.

27. In this case, admittedly, the scheme of the Company was a 'collective investment scheme'. It is for this reason that the WRR in this case was filed by it under regulation 73 of the CIS Regulations, which reads as under:- “73(1) An existing collective investment scheme which: (a) has failed to make an application for registration to the Board; or (b) has not been granted provisional registration by the Board; or (c) having obtained provisional registration fails to comply with the provisions of regulation 71;shall wind up the existing [collective investment scheme. (2) The existing Collective Investment Scheme to be wound up under sub-regulation (1) shall send an information memorandum to the investors who have subscribed to the [collective investment scheme]s, within two months from the date of receipt of intimation from the Board, detailing the state of affairs of the [collective investment scheme], the amount repayable to each investor and the manner in which such amount is determined. (3) The information memorandum referred to in sub-regulation (2) shall be dated and signed by all the directors of the [collective investment scheme].

(4) The Board may specify such other disclosures to be made in the information memorandum, as it deems fit. (5) The information memorandum shall be sent to the investors within one week from the date of the information memorandum. (6) The information memorandum shall explicitly state that investors desirous of continuing with the [collective investment scheme] shall have to give a positive consent within one month from the date of the information memorandum to continue with the [collective investment scheme]. (7) The investors who give positive consent under sub-regulation (6), shall continue with the [collective investment scheme] at their risk and responsibility: Provided that if the positive consent to continue with the [collective investment scheme], is received from only twenty-five per cent or less of the total number of existing investors, the [collective investment scheme] shall be wound up. (8) The payment to the investors, shall be made within three months of the date of the information memorandum. (9) On completion of the winding up, the existing collective investment scheme shall file with the Board such reports, as may be specified by the Board 28. I note that the purpose of regulation 73 of the CIS Regulations which gave an option to the investors of the existing CIS entities to continue with the schemes was only to enable a gradual phasing out of operations of the unregistered CIS entity, without harming the interest of investors.

It is noted that pursuant to receiving the minimum stipulated positive consent from investors to continue with its existing CIS, the Company had filed an application seeking registration with SEBI which was subsequently rejected by SEBI on February 28, 2003. After such rejection the Company filed the WRR in October 2003. 29. In this context, the issue for determination in the instant matter is whether the mobilization of fresh funds by the Company after submitting the WRR to SEBI constitutes a violation of CIS Regulations and SEBI Act. It is evident from the submission of the Company that on maturity of investments contributed by investors from whom positive consent had been obtained, the Company renewed some of the investments for an additional term. In this regard, it is relevant to mention that regulation 73 of the CIS Regulations is not meant to enable an unregistered CIS entity to perpetuate its operations even after the expiry of the original term for which investments had been accepted from the consenting investors. In my view, since the application of Company seeking registration as 'collective investment scheme' was rejected by SEBI it could not continue such activity.

In this regard, reference may be drawn to section 12 (1B) of the SEBI Act, 1992 in terms of which “no person shall sponsor or cause to be sponsored or carry on or cause to be carried on Collective Investment Scheme including mutual funds unless he obtains a certificate of registration from the Board in accordance with the Regulations”. Further, in terms of regulation 3 of the CIS Regulations, “no person other than a Collective Investment Management Company which has obtained a certificate under the Regulations shall carry on or sponsor or launch a collective investment scheme.” Hence, renewal of investments post submission of the WRR and after the expiry of the original term of such investments, and mobilization of fresh funds by Sheen Agro after submission of WRR is in violation of the provisions of the CIS Regulations and the SEBI Act. 30. According to the Company, as on March 31, 2011 its total liability for refund to investors was ₹575 lakhs out of which it had paid only ₹51 lakhs. From the Balance Sheet of the Company for the year ending March 31, 2003, (the latest financial statements have not been submitted by the Company) it is observed that the Company had given loan to ‘members and others’ to the tune of ₹2 crore.

From the Annexure to the Audit Report of the Accounts of the Company, it is noted that most of the borrowers have defaulted in repaying the principal and interest to the Company. However, the Company has not taken any steps to recover the money. The Company has pleaded its inability citing reason that its land assets are under stay order by the Hon'ble High Court of Jammu & Kashmir. Be whatever it may, the Company has defaulted in repaying to the investors despite repeated assurances given by it and substantial portion of investments are outstanding for refund to the investors. . 31. In view of the above, I find that the Company has been engaged in mobilizing contributions from public in the nature of 'collective investment scheme' without obtaining certificate of registration from SEBI and, it has thus contravened provisions of section 12(1B) of the SEBI Act and regulation 3 of the CIS Regulations. I further note that the activities of the noticees were not only in contravention of the provisions of the SEBI Act and CIS Regulations for which the noticees are liable for appropriate action as contemplated in the SCN; they were harmful and detrimental to the interest of the investors since the Company has failed to refund/repay to them.

32. I note that Mr. Brita Singh Bhau has submitted that he resigned from the Company in 1998 and had no dealings with the Company. However, from the MoU signed between the erstwhile directors of the Company and the promoters it is observed that Mr. Brita Singh Bhau has signed as the identifier of Mr. Yograj Singh Bhau as the director of the Company. Further, from the depositions of Mr. Surinder Kr. Trilokia, Mr. Tejpal Singh and Mr. Kamal Singh made before me on November 23, 2012, I note that Mr. Brita Singh Bhau played a significant role in managing the affairs of the Company even after 1998. Though Mr. Baldev Singh Bhau has informed that his father, Mr. Brita Singh Bhau had passed away in December 2000, he has failed to submit any documentary evidence to corroborate this submission. I, therefore, do not find reason to drop the proceedings against Mr. Brita Singh Bhau at this stage. 33. Mr. R. S. Bhau and Mr. Yograj Singh also submitted that they resigned from the Company, and are not associated with the Company in any manner. However, being the promoters and also directors of the Company, their role in the affairs of the Company cannot be negated.

34. I note that Mr. Angrez Singh Bhadwal, Mr. Nasib Singh Pawar, Mr. Suriender Kr. Trilokia, Mr. Tejpal Singh, Mr. Kamal Singh and Mr. Sudershan Singh Jamwal have submitted that they ceased to be directors with effect from May 29, 2004. They have also submitted copies of Form 32 in support of their claims. I note that during the tenure of the aforesaid noticees as director of the Company, it renewed the investments which were due for maturity.

35. Mr. Kamal Singh, Mr. Tejpal Singh and Mr. Sudershan Singh Jamwal have further submitted that they were appointed directors of Sheen Agro without their consent by deceptively taking their signatures on several documents. I note that Mr. Kamal Singh, Mr. Tejpal Singh and Mr. Sudershan Singh Jamwal were directors of the Company for nearly four to five years. Also, none of them took any legal action against Sheen Agro for alleged illegal use of their identity card and documents even when they became aware that they were made directors of the Company without their consent. 36. I note that despite significant lapse of time, and numerous opportunities having been granted to Sheen Agro it has failed to furnish information sought by SEBI and has also failed to redress the grievance of the investors.

37. Considering the facts and circumstances of the case, I, in exercise of the powers conferred upon me by virtue of section 19 of the Securities and Exchange Board of India Act, 1992 hereby issue following directions under section 11 and 11B of the said Act read with regulations 65 and 73 of Securities and Exchange Board of India (Collective Investment Schemes) Regulations, 1999:- i. Sheen Agro and Plantations Ltd. and its present promoters/directors, namely, Mr. Ajeet Lal Sharma, Mr. Brita Singh Bhau, Mr. R. S. Bhau, Mr. Yograj Singh Bhau, Mr. Shyam Lal Pahwa, Ms. Renu Bala, Mr. Pawan Kumar Khajuria, Ms. Anita Sharma, Mr. Kirpal Singh, and Mr. Gurpreet Singh to wind up its scheme and refund the money collected by it under the scheme with returns which are due to the investors as per the terms of offer within a period of three months from the date of this order and submit a winding up and repayment report to SEBI in accordance with the SEBI (Collective Investment Schemes) Regulations, 1999, including trail of funds claimed to be refunded, bank account statements indicating refund to the investors and receipt from the investors acknowledging such refund, failing which the following actions shall follow: (a) A reference would be made to the State Government/ local police to register a civil/ criminal case against them for apparent offences of fraud, cheating, criminal breach of trust and misappropriation of public funds, and (b) Making a reference to the Ministry of Corporate Affairs, to initiate the process of winding up of Sheen Agro & Plantations Ltd. (c) SEBI shall also initiate attachment and recovery proceedings under section 28A of the SEBI Act. ii. Sheen Agro & Plantations Ltd. and following persons who are/were directors/prompters/managers/persons responsible for its actions at the relevant time are directed to not to access the securities market and are further restrained and prohibited from buying, selling or otherwise dealing in the securities market till all collective investment schemes launched by Sheen Agro & Plantations Ltd. are wound up and all the monies mobilised through it are refunded to the investors.

Sl. No. Name PAN 1 Mr. Angrez Singh Bhadwal ACBPB5282C 2 Mr. Surinder Kumar Trilokia ACXPT9782D 3 Mr. Naseeb Singh Pawar APOPS9255C 4 Mr. Kamal Singh Bhau BJKPS4811H 5 Mr. Sham Lal Pahwa APQPP5268L 6 Mr. Sudershan Singh Jamwal AAPPJ8220N

Sl. No. Name PAN 7 Mr. R. S. Bhau Not Available 8 Mr. Brita Singh Bhau Not Available 9 Mr. Ajeet Lal Sharma Not Available 10 Mr. Sohan Singh Not Available 11 Ms. Renu Bala Not Available 12 Mr. Pawan Kumar Khajuria Not Available 13 Ms. Anita Sharma Not Available 14 Mr. Kirpal Singh Not Available 15 Mr. Yograj Singh Bhau Not Available 16 Mr. Tej Pal Singh Not Available 17 Mr. Gurpreet Singh Not Available

38. Without prejudice to the above, SEBI would examine the feasibility of initiation of prosecution proceedings under section 24 and adjudication proceedings under Chapter VI of the SEBI Act against them. 39. The above directions shall come into force with immediate effect. Copy of this Order shall be forwarded to the stock exchanges and depositories for necessary action.

Date: November 14th, 2014 RAJEEV KUMAR AGARWAL Place: Mumbai WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA