Order -Multi Purpose Bios India Limited

WTM/PS/122/IMD-ERO/DEC/2015 BEFORE THE SECURITIES AND EXCHANGE BOARD OF INDIA CORAM: PRASHANT SARAN, WHOLE TIME MEMBER ORDER Under sections 11, 11(4), 11A and 11B of the Securities and Exchange Board of India Act, 1992

In respect of – 1. Multi Purpose Bios India Limited (CIN:U24240WB2006PLC108460) and its Directors, 2. Mr.Mridul Kanti Bhaumik (PAN: AJNPB0934C; DIN: 01203872), 3. Mr. Laxmi Kanta Das (PAN: AKQPD1001N; DIN: 01214783) and 4. Smt. MonalisaMitra (PAN: AGXPM6268P; DIN: 01324882)

I. Date of hearing: April 22, 2015 Appearance: Ms. Moumita Chakraborty and Ms. Rima Das, Advocates for noticee, Ms. MonalisaMitra. No representation from other noticees. For SEBI: Ms. Soma Majumder, General Manager, Mr. N. Murugan, Assistant General Manager, Mr. Sumit Saraf, Assistant Manager and Ms. Nikki Agarwal, Assistant Manager II. Date of hearing: July 29, 2015 No representation from Ms. MonalisaMitra on this date.

1. Securities and Exchange Board of India (“SEBI”), vide an ex-parte interim order dated August 14, 2014 (“the interim order”) prima facie observed that the company, Multi Purpose Bios India Limited (“the Company” or “MBIL”) is engaged in fund mobilization activity from the public through offer and issuance of Redeemable Preference Shares (”RPS”) and violated sections 56, 60 and 73 of the Companies Act, 1956 read with the Companies Act, 2013. In order to protect the interest of investors and to prevent the Company and its present/past directors Mr. Laxmi Kanta Das, Smt.

MonalisaMitra and Mr. Mridul Kanti Bhaumik, from continuing to mobilize public funds in contravention of law, SEBI issued the following directions:

“7. In view of the foregoing, I, in exercise of the powers conferred upon me under Sections 11, 11(4), 11A and 11B of the SEBI Act, hereby issue the following directions – i. MBIL shall not mobilize funds from investors through the Issue of RPS or through the issuance of equity shares or any other securities, to the public and/or invite subscription, in any manner whatsoever, either directly or indirectly till further directions; ii. MBIL and its Directors, viz. Shri Laxmi Kanta Das (DIN: 01214783) and Smt. MonalisaMitra (DIN: 01324882) including its past Director, Shri Mridul Kanti Bhaumik (DIN: 01203872), are prohibited from issuing prospectus or any offer document or issue advertisement for soliciting money from the public for the issue of securities, in any manner whatsoever, either directly or indirectly, till further orders; iii. MBIL and the abovementioned past and present Directors, are restrained from accessing the securities market and further prohibited from buying, selling or otherwise dealing in the securities market, either directly or indirectly, till further directions; iv. MBIL shall provide a full inventory of all its assets and properties; v. The abovementioned past and present Directors of MBIL shall provide a full inventory of all their assets and properties; vi. MBIL and its present Directors shall not dispose of any of the properties or alienate or encumber any of the assets owned/acquired by that company through the Issue of RPS, without prior permission from SEBI; vii. MBIL and its present Directors shall not divert any funds raised from public at large through the Issue of RPS, which are kept in bank account(s) and/or in the custody of MBIL. viii. MBIL and its present Directors shall, within 21 days from the date of receipt of this Order, provide SEBI with all relevant and necessary information, as sought vide SEBI letters dated April 24, 2014 and May 5, 2014.

8. The above directions shall take effect immediately and shall be in force until further orders.

9. The prima facie observations contained in this Order are made on the basis of the material available on record i.e. information obtained from the Ministry of Corporate Affairs' website i.e. 'MCA 21 Portal'. In this context, MBIL and its abovementioned past and present Directors may, within 21 days from the date of receipt of this Order, file their reply, if any, to this Order and may also indicate whether they desire to avail themselves an opportunity of personal hearing on a date and time to be fixed on a specific request made in that regard.

10. This Order is without prejudice to the right of SEBI to take any other action that may be initiated against MBIL and its abovementioned past and present Directors in accordance with law”.

2. The interim order was served on Mr. Laxmi Kanta Das, Smt. MonalisaMitraand Mr.Mridul Kanti Bhaumik. However, the interim order sent to the Company returned undelivered. Therefore, SEBI made a public noticein the newspapers (Times of Indiaand Ananda Bazar Patrika dated April 15, 2015) regarding the proceedings against the Company and its directors initiated vide the interim order and the personal hearing afforded to the noticees on April 22, 2015 in Kolkata. The noticees were advised that in case they fail to appear before SEBI on the aforesaid date, then the matter would be proceeded ex-parte on the basis of material on record. SEBI also sent notices informing the schedule of personal hearing.

3. On April 22, 2015, noticee, Ms. MonalisaMitra was represented by her advocates, Ms. Moumita Chakraborty and Ms. Rima Das. The advocates submitted that the noticee is in prison and undertook to receive notices for correspondence on behalf of the said noticee and requested for another opportunity of hearing. The request was allowed. There was no representation or appearance for the other noticees (i.e. Company, Laxmi Kanta Das and Mridul Kanti Bhaumik).

4. Another opportunity of personal hearing was afforded to Ms. MonalisaMitraon July 29, 2015. Though the notice dated July 08, 2015, informing the schedule of the personal hearing, was received by the noticee‟s counsel, none appeared for Ms. MonalisaMitra. As sufficient opportunities were already afforded to the noticees to make their submissions, I am of the view that further opportunities would only be a formality without achieving any purpose. If the noticees were serious about the instant proceeding they would have appeared/made submissions. Accordingly, the personal hearing was closed and matter is proceeded further.

5. I have considered the interim order passed in the matter and other material available on record. The interim order had observed/alleged the following:

(a) The Company was incorporated on March 03, 2006 with RoC, Kolkata.

(b) The Company had issued RPS during Financial Years 2007-2008, 2008-2009, 2009-2010, 2010- 2011 and 2011-2012 to a large number of public investors as per details below:

Year Type of Security No. of persons Total to whom RPS Amount were allotted ( ₹ in Crores) 2007 – 08 RPS## Details Not Available 0.31 RPS 2008 – 09 1460 **1.23 RPS 2009 – 10 Details Not Available **3.81 RPS 2010 – 11 Details Not Available **0.60 RPS 2011 – 12 Details Not Available **0.02 Total More than 1460^^ 5.97 ##Details inrespect of the Issue of RPSfor the Financial Year 2008–09 was obtained from Form 2 (as filed by MBIL with the ROC) and the Balance Sheet. **The details in respect of the Issue of RPS for the Financial Years 2007–08, 2009–10, 2010–11 and 2011–12 was obtained from either the Balance Sheet or Annual Return. ^^The total number of investors as indicated above is only in respect of the Financial Year 2008–09.

(c) The Company made a public issue under the first proviso to section 67(3) of the Companies Act, 1956. The Company is not stated to be non-banking financial company or a public financial institution.

(d) The Company did not comply with the public issue norms mandated under sections 56, 60 and 73 of the Companies Act, 1956.

(e) The interim order also observed: “From the information available on the 'MCA 21 Portal', it is observed that MBIL has not made any statutory filings i.e. filing of Form 2 with the ROC, Kolkata, in respect of the Issue of RPS for the Financial Years 2007–08, 2009–10, 2010–11 and 2011–12 and has only made statutory filings for the Financial Year 2008–09”.

6. In the background of such allegation, it first needs to be determined whether the Company made a public issue as alleged in the interim order and if the answer to such question was in the positive, then it needs to be determined whether the Company complied with the public issue norms. The liability of the directors of the Company also needs to be determined as they have also been alleged in the interim order.

7. In order to ascertain whether an issue of securities is a 'public issue' or done on 'private placement', a reference to section 67(3) of the Companies Act, 1956 needs to be made: 67. (1) Any reference in this Act or in the articles of a company to offering shares or debentures to the public shall, subject to any provision to the contrary contained in this Act and subject also to the provisions of sub-sections (3) and (4), be construed as including a reference to offering them to any section of the public, whether selected as members or debenture holders of the company concerned or as clients of the person issuing the prospectus or in any other manner. (2) ... (3) No offer or invitation shall be treated as made to the public by virtue of sub-section (1) or sub-section (2), as the case may be, if the offer or invitation can properly be regarded, in all the circumstances- (a) as not being calculated to result, directly or indirectly, in the shares or debentures becoming available for subscription or purchase by persons other than those receiving the offer or invitation; or (b) otherwise as being a domestic concern of the persons making and receiving the offer or invitation … Provided that nothing contained in this sub-section shall apply in a case where the offer or invitation to subscribe for shares or debentures is made to fifty persons or more: Provided further that nothing contained in the first proviso shall apply to non-banking financial companies or public financial institutions specified in section 4A of the Companies Act, 1956 (1 of 1956).

In terms of section 67(3), as amended by the Companies (Amendment) Act, 2000, with effect from December 13, 2000, no offer or invitation shall be treated as made to the public by virtue of sub-sections (1) or (2), as the case may be, if the offer or invitation can properly be regarded, in all circumstances – (a) as not being calculated to result, directly or indirectly, in the shares or debentures becoming available for subscription or purchase by persons other than those receiving the offer or invitation; or (b) otherwise as being a domestic concern of the persons making and receiving the offer or invitation. More importantly, in terms of the firstproviso to the aforesaid section, the provisions of section 67(3) shall not apply in a case where the offer or invitation to subscribe for shares or debentures is made to fifty persons or more. Therefore, the number of subscribers becomes relevant to judge whether an issue of shares are for public or on a private placement basis, in the light of the above said provision.

Therefore, if an offer of securities are made to fifty or more persons, it would be deemed to be a public issue. NBFCs or PFIs are exempted only from the first proviso to section 67(3). Therefore, NBFC or PFI do not have any restriction on the number of allottees as imposed on a company which is not an NBFC or PFI. However, such companies also need to prove that its offer falls either under clause (a) or (b) of section 67(3) to claim such issuance to be a private placement.

8. The Hon'ble Supreme Court of India in the matter of Sahara India Real Estate Corporation Limited & Others vs. SEBIand another(Civil Appeal Nos. 9813 and 9833 of 2011; decided on August 31, 2012) ("the Sahara case") had inter alia held that - "Section 67(1) deals with the offer of shares and debentures to the public and Section 67(2) deals with invitation to the public to subscribe for shares and debentures and how those expressions are to be understood, when reference is made to the Act or in the articles of a company. The emphasis in Section 67(1) and (2) is on the “section of the public”. Section 67(3) states that no offer or invitation shall be treated as made to the public, by virtue of subsections (1) and (2), that is to any section of the public, if the offer or invitation is not being calculated to result, directly or indirectly, in the shares or debentures becoming available for subscription or purchase by persons other than those receiving the offer or invitation or otherwise as being a domestic concern of the persons making and receiving the offer or invitations. Section 67(3) is, therefore, an exception to Sections 67(1) and (2). If the circumstances mentioned in clauses (1) and (b) of Section 67(3) are satisfied, then the offer/invitation would not be treated as being made to the public. The first proviso to Section 67(3) was inserted by the Companies (Amendment) Act, 2000 w.e.f. 13.12.2000, which clearly indicates, nothing contained in Sub-section (3) of Section 67 shall apply in a case where the offer or invitation to subscribe for shares or debentures is made to fifty persons or more. … Resultantly, if an offer of securities is made to fifty or more persons, it would be deemed to be a public issue, even if it is of domestic concern or proved that the shares or debentures are not available for subscription or purchase by persons other than those received the offer or invitation. … I may, therefore, indicate, subject to what has been stated above, in India that any share or debenture issue beyond forty nine persons, would be a public issue attracting all the relevant provisions of the SEBI Act, regulations framed thereunder, the Companies Act, pertaining to the public issue. …"

9. In the present case, the Company had mobilized a total of Rs.5.97 crore through its offer and issue of RPS during the financial years 2007-08 to 2011-12. During financial year 2008-09, the Company allotted RPS to 1460 persons and raised Rs.1.23 crore. However, the details regarding the number of investors for the other financial years are not available. The Company has also not provided such details. Notwithstanding the same, it can be inferred that the Company had made its offer and allotted RPS during the said financial years to more than 49 persons considering the huge mobilization of around Rs.4.74 crore. The interim order has also specifically stated that the Company refused to provide the complete and relevant information sought by SEBI. In view of the same, it is held that the Company made its offer and allotted RPS to more than 49 persons, thereby making a public issue of RPS (in terms of the first proviso to section 67(3) of the Companies Act, 1956) during the period alleged in the interim order.In this context, I refer and rely on the below mentioned observation made by the Hon'ble Supreme Court of India in the matter of Sahara India Real Estate Corporation Limited &Ors.Vs. SEBI (Civil Appeal no. 9813 and 9833 of 2011)(hereinafter referred to as the 'Sahara Case'): ... ... that any share or debenture issue beyond forty nine persons, would be a public issue attracting all the relevant provisions of the SEBI Act, regulations framed thereunder, the Companies Act, pertaining to the public issue. …".

10. By making a public issue of RPSs, the Company was mandated to comply with all the legal provisions that govern and regulate public issue of such securities, including the Companies Act, 1956 and the SEBI Act and regulations. In this regard, I note that in terms of section 55A of the Companies Act, 1956, SEBI shall administer various provisions (as mentioned therein) of the said Act with respect to issue and transfer of securities by listed companies, companies that intend to list and also those companies that are required to list its securities while making offer and issue of securities to the public. While examining the scope of Section 55A of the Companies Act, 1956, the Hon'ble Supreme Court of India in Sahara Case, had observed that: "We, therefore, hold that, so far as the provisions enumerated in the opening portion of Section 55A of the Companies Act, so far as they relate to issue and transfer of securities and non-payment of dividend is concerned, SEBI has the power to administer in the case of listed public companies and in the case of those public companies which intend to get their securities listed on a recognized stock exchange in India." " SEBI can exercise its jurisdiction under Sections 11(1), 11(4), 11A(1)(b) and 11B of SEBI Act and Regulation 107 of ICDR 2009 over public companies who have issued shares or debentures to fifty or more, but not complied with the provisions of Section 73(1) by not listing its securities on a recognized stock exchange".

Under section 11Aof the SEBI Act, SEBI is also empowered to regulate, by regulations/general or special orders, the matters pertaining to issue of capital, transfer of securities and matters related thereto. Accordingly, the Company, having made a public offer and issue of securities, as observed above, is under the jurisdiction of SEBI.

11. As alleged in the SEBI Order, the Company was mandated to comply with the provisions of sections 56, 60 and 73of the Companies Act, 1956 read with the Companies Act, 2013, in respect of its offer and issue of RPSs. In this regard, I note that - a. In terms of section 56(1) of the Companies Act, 1956, every prospectus issued by or on behalf of a company, shall state the matters specified in Part I and set out the reports specified in Part II of Schedule II of that Act. Further, as per section 56(3) of the Companies Act, 1956, no one shall issue any form of application for shares in a company, unless the form is accompanied by abridged prospectus, contain disclosures as specified. Section 2(36) of the Companies Act read with section 60 thereof, mandates a company to register its 'prospectus' with the RoC, before making a public offer/ issuing the 'prospectus'.

b. By making a public issue of RPS, as discussed above, the Company had to compulsorily list such securities in compliance with section 73(1) of the Companies Act, 1956. A Company making a public issue of securities cannot choose whether to list its securities or not as listing is a mandatory requirement under law. As per section 73(1) Companies Act, 1956, a company is required to make an application to one or more recognized stock exchanges for permission for the shares or debentures to be offered to be dealt with in the stock exchange. Further, there is no material to say that the Company has filed an application with a recognized stock exchange to enable the RPSs to be dealt with in such stock exchange. Therefore, the Company has failed to comply with this requirement.

Section 73(2) states that "Where the permission has not been applied under subsection (1) or such permission having been applied for, has not been granted as aforesaid, the company shall forthwith repay without interest all moneys received from applicants in pursuance of the prospectus, and, if any such money is not repaid within eight days after the company becomes liable to repay it, the company and every director of the company who is an officer in default shall, on and from the expiry of the eighth day, be jointly and severally liable to repay that money with interest at such rate, not less than four per cent and not more than fifteen per cent, as may be prescribed, having regard to the length of the period of delay in making the repayment of such money".

As the Company failed to make an application for listing such securities, the Company had to forthwith repay such money collected from investors. If such repayments are not made within 8 days after the Company becomes liable to repay, the Company and every director is liable to repay with interest at such rate. The liability of the Company to refund the public funds collected through offer and allotment of the impugned RPSs is continuing and such liability would continue till repayments are made. There is no record to suggest that the Company made the refunds as per law. The Hon'ble Supreme Court of India in the Sahara case has examined section 73 and made the following observations: "Section 73(1) of the Act casts an obligation on every company intending to offer shares or debentures to the public to apply on a stock exchange for listing of its securities. Such companies have no option or choice but to list their securities on a recognized stock exchange, once they invite subscription from over forty nine investors from the public. If an unlisted company expresses its intention, by conduct or otherwise, to offer its securities to the public by the issue of a prospectus, the legal obligation to make an application on a recognized stock exchange for listing starts. Sub-section (1A) of Section 73 gives indication of what are the particulars to be stated in such a prospectus. The consequences of not applying for the permission under sub-section (1) of Section 73 or not granting of permission is clearly stipulated in sub-section (3) of Section 73. Obligation to refund the amount collected from the public with interest is also mandatory as per Section 73(2) of the Act. Listing is, therefore, a legal responsibility of the company which offers securities to the public, provided offers are made to more than 50 persons."

The mobilization was done from FY 2007-2008 till 2011-2012The amounts mobilized through the issue of securities have not been refunded within the time period as mandated under law. It would therefore be appropriate to levy an interest @ 15% p.a. as provided for under section 73(2) of the Companies Act, 1956 read with rule 4D (which prescribes that the rates of interest, for the purposes of sub-sections (2) and (2A) of section 73, shall be 15 per cent per annum) of the Companies (Central Government‟s) General Rules and Forms, 1956, on Rs.5.97 crore due to be repaid by the Company. As stated above, the liability of the Company to refund the public funds collected through offer and allotment of the impugned RPSs is continuing and such liability would cease only if the repayments are made in accordance with the relevant provisions of law.

12. From the above observations, I conclude that the Company made a public issue of RPS and failed to comply with the provision of section 56, 60 and 73 of the Companies Act, 1956 read with the Companies Act, 2013 in respect of its offer and issue of RPS as alleged in the interim order.

13. The interim order has been issued againstthe Company‟s directors namely Laxmi KantaDas, MonalisaMitra and Mridul Kanti Bhaumik. None of these noticees filed any response to the interim order. With respect to their liability, I observe the following:

(a) As per MCA records (website accessed on 30.11.2015), the above said persons continue to be the directors of the Company. Laxmi Kanta Das and MonalisaMitra were appointed on February 20, 2007. Mridul Kanti Bhaumikwas appointed on November 30, 2007.

(b) Though Mr. Mridul Kanti Bhaumik submitted, vide letter dated May 12, 2014, that he ceased to be a director with effect from June 03, 2013, his name is still mentioned as a „director’ in the records of MCA. However, he may be at liberty to approach the concerned authority for necessary action in this regard. I also note that despite receiving the interim order, he failed to file any response or appeared in the personal hearing in the matter.

(c) Section 56(1) and 56(3) read with section 56(4) imposes the liability for the compliance of the said provisions, on the company, every director, and other persons responsible for the issuance of the prospectus. The liability for non-compliance of section 60 of the Companies Act is on the Company, and every person who is a party to the non-compliance of issuing the prospectus as per the said section.

(d) The liability of the company and directors to repay under section 73(2) of the Companies Act, 1956 and section 27 of the SEBI Act, is a continuing liability and the same continues till all the repayments are made. Therefore, the directors (irrespective of whether they continue or resign) who were present during the period when the Company made the offer and allotted RPSs shall be liable for violation of sections 56, 60 and 73 of the Companies Act, including the default in making refunds as mandated therein. As the liability to make repayments under sections 73(2) of the Companies Act read with section 27 of the SEBI Act is a continuing liability, the persons who join the Company‟s Board pursuant to the offer and allotment of RPSs shall also be liable if the Company and the concerned directors have failed to make refunds as mandated under law.

(e) As the three directors were there on the board of the Company during the impugned period (FY 2007-08 to 2011-12), they would be liable, as directors of the Company, for the violation of sections 56, 60 and 73 of the Companies Act, 1956 as found in this Order. These directors would also be liable to make refunds in terms of section 73(2) of the Companies Act read with section 27 of the SEBI Act.

14. In view of the foregoing, I, in exercise of the powers conferred upon me under section 19 of the Securities and Exchange Board of India Act, 1992 read with sections 11(1), 11(4), 11A and 11B thereof, hereby issue the following directions:

(a) The Company, Multi Purpose Bios India Limited(CIN:U24240WB2006PLC108460) and its directors/promoters includingMr. Laxmi Kanta Das (PAN: AKQPD1001N; DIN: 01214783), Ms. MonalisaMitra (PAN: AGXPM6268P; DIN: 01324882) and Mr. Mridul Kanti Bhaumik (PAN: AJNPB0934C; DIN: 01203872), jointly and severally, shall forthwith refund the money collected by the Company through the issuance of Redeemable Preference Shares (which have been found to be issued in contravention of the public issue norms stipulated under the Companies Act, 1956), to the investors including the money collected from investors, till date, pending allotment of securities, if any, with an interest of 15% per annum compounded at half yearly intervals, from the date when the repayments became due (in terms of Section 73(2) of the Companies Act, 1956) to the investors till the date of actual payment.

(b) The repayments to investors shall be effected only in cash through Bank Demand Draft or Pay Order.

(c) The Company/its present management are permitted to sell the assets of the Company only for the sole purpose of making the refunds as directed above and deposit the proceeds in an Escrow Account opened with a nationalised Bank.

(d) The Company, its directors and other persons named above, shall issue public notice, in all editions of two National Dailies (one English and one Hindi) and in one local daily (Bengali) with wide circulation, detailing the modalities for refund, including details of contact persons including names, addresses and contact details, within fifteen days of this Order coming into effect.

(e) After completing the aforesaid repayments, the Company shall file a certificate of such completion with SEBI, within a period of three months from the date of this Order, from two independent peer reviewed Chartered Accountants who are in the panel of any public authority or public institution. For the purpose of this Order, a peer reviewed Chartered Accountant shall mean a Chartered Accountant, who has been categorized so by the Institute of Chartered Accountants of India ("ICAI").

(f) Multi Purpose Bios India Limited, Mr. Laxmi Kanta Das, Ms. MonalisaMitra and Mr. Mridul Kanti Bhaumikare also directed to provide a full inventory of all their assets and properties and details of all their bank accounts, demat accounts and holdings of shares/securities, if held in physical form.

(g) In case of failure of Multi Purpose Bios India Limited, Mr. Laxmi Kanta Das, Ms. MonalisaMitra and Mr. Mridul Kanti Bhaumikin complying with the aforesaid directions, SEBI, on the expiry of the three months period from the date of this order, - a) shall recover such amounts in accordance with section 28A of the SEBI Act including such other provisions contained in securities laws. b) may initiate appropriate action against the Company, its promoters/ directors and the persons/ officers who are in default, including adjudication proceedings against them, in accordance with law. c) would make a reference to the State Government/ Local Police to register a civil/ criminal case against the Company, its promoters, directors and its managers/ persons in-charge of the business and its schemes, for offences of fraud, cheating, criminal breach of trust and misappropriation of public funds; and d) would also make a reference to the Ministry of Corporate Affairs, to initiate the process of winding up of the Company.

(h) Multi Purpose Bios India Limitedis directed not to, directly or indirectly, access the capital market by issuing prospectus, offer document or advertisement soliciting money from the public and are further restrained and prohibited from buying, selling or otherwise dealing in the securities market, directly or indirectly in whatsoever manner, from the date of this Order till the expiry of 4 yearsfrom the date of completion of refunds to investors as directed above.

(i) Mr. Laxmi Kanta Das, Ms. MonalisaMitra and Mr. Mridul Kanti Bhaumikare restrained from accessing the securities market and further prohibited from buying, selling or otherwise dealing in the securities market, directly or indirectly in whatsoever manner, with immediate effect. They are also restrained from issuing prospectus, offer document or advertisement soliciting money from the public and associating themselves with any listed public company and any public company which intends to raise money from the public, or any intermediary registered with SEBI. The above directions shall come into force with immediate effect and shall continue to be in force from the date of this Order till the expiry of 4 yearsfrom the date of completion of refunds to investors, as directed above.

(j) The above directions shall come into force with immediate effect.

15. This Order is without prejudice to any action, including adjudication and prosecution proceedings that might be taken by SEBI in respect of the above violations committed by the Company, its promoters, directors including former directors and other key persons.

16. Copy of this Order shall be forwarded to the recognised stock exchanges and depositories for information and necessary action.

17. A copy of this Order shall also be forwarded to the Ministry of Corporate Affairs/concerned Registrar of Companies, for their information and necessary action with respect to the directions/restraint imposed above against the Company and the individuals.

PRASHANT SARAN WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA Date: December 29th, 2015 Place: Mumbai