Prabhat Dairy Limited & Ors. vs Sebi

3. Vivek Sarangdhar Nirmal Nirmalnagar, At Post Ranjankhol, Taluka - Rahata, Shrirampur District, Ahmednagar - 413 720. ...Appellants

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. Janak Dwarkadas, Senior Advocate with Mr. Feroze Patel, Mrs. Manik Joshi, Mr. Mantul Bajpai and Mr. Gaurav Gangal, Advocates i/b M/s. Crawford Bayley & Co. for Appellants.

Mr. Rafique Dada, Senior Advocate with Mr. Anubhav Ghosh and Mr. Ravishekhar Pandey, Advocates i/b The Law Point for the Respondent.

Mr. P.N. Modi, Senior Advocate with Ms. Kalpana Desai, Mr. Melvyn Fernandes, Mr. Shrinivas Sankaran and Mr. Mihir Gupte, Advocates i/b Vaish Associates for Interveners in Misc. Application No. 437 of 2020.

CORAM: Justice Tarun Agarwala, Presiding Officer Dr. C.K.G. Nair, Member Justice M.T. Joshi, Judicial Member

Per: Justice Tarun Agarwala, Presiding Officer

1. The present appeal has been filed against an ex-parte ad-

interim order dated October 20, 2020 passed by the Whole Time

Member ('WTM' for short) of Securities and Exchange Board

of India ('SEBI' for short) under Section 11 and 11B of the

Securities and Exchange Board of India Act, 1992.

2. The facts leading to the filing of the present appeal is, that

on January 21, 2019 the Board of Directors of the appellant no. 3

1 Company approved the sale of its shareholding in its

subsidiary called Sunfresh Agro Industries Private Limited

('Sunfresh' for short) to Tirumala Milk Products Private

Limited ('Tirumala' for short) on terms and conditions

contained in the share purchase agreement and business transfer

agreement. This fact was disclosed by the Company to the

National Stock Exchange of India Limited ('NSE' for short) and

BSE Limited ('BSE' for short) under Regulation 30 of the

LODR Regulations. The Company also informed the stock

exchange on the same date that a substantial portion of the sale

consideration would be distributed to the shareholders after

meeting the tax liability, indemnity, transaction cost, payments

to advisors, etc.

3. The resolution of the board of directors was subsequently

approved by the 92% of the shareholders of the company

present and voting in its extraordinary general meeting held on

March 26, 2019, based on which, the sale was concluded on

April 10, 2019 for total consideration of Rs. 1880.85 crore, the

breakup of which is Rs. 1700 crore towards sale consideration

and Rs. 180.85 towards debit repayment. This fact was also

disclosed to the stock exchange on April 11, 2019. 4

4. Various options for distribution of the sale proceeds to the

shareholders were alleged to be evaluated by the appellant no. 1

Company such as dividend and buy-back of equity shares. It is

alleged that these options were not tax efficient and

consequently the promoter and the promoter group, namely,

appellant nos. 2 and 3 showed their intention to buy the 49%

shares of the minority shareholders in order to provide an exit

opportunity to the minority shareholders of appellant no. 1

Company. It may be stated here that the promoter and promoter

group of the appellant no. 1 Company hold 51% of the total

shareholding of the Company and 49% of the shares are held by

the public shareholders.

5. This intention of the promoters to buyout the shares of the

minority shareholders was also indicated to the stock exchange

on September 4, 2019 and subsequently the board of directors

passed a resolution on September 10, 2019 indicating that the

Company would be delisted and that 49% of the shares of the

public would be bought by the promoters, namely, appellant

nos. 2 and 3. The floor price of Rs. 63.77 paise was also

determined in accordance with Regulation 15(2) of the SEBI

(Delisting of Equity Shares) Regulations, 2009 ('Delisting

Regulations' for short).

5

6. Subsequently, a resolution of the board of directors was

approved by 99.13% of the shareholders on October 16, 2019.

In the explanatory statement published and distributed to the

shareholders under Section 102 of the Companies Act, 2013 it

was made known to the shareholders that the dairy business of

the Company had been sold off to Tirumala and that the

Company was no longer operating its core business, namely, the

dairy business. It was also indicated that the acquirers

understood and recognized that a majority of the public

shareholders would have invested in a Company with the

intention of investing in a Company engaged in a dairy business

and therefore keeping that in mind the acquirers have provided

an exit opportunity to the shareholders through this delisting

process.

7. Based on the approval granted by the majority

shareholders of the Company for delisting, a formal application

dated December 23, 2019 was filed for approval of the delisting

of the Company under Regulation 8(1) of the Delisting

Regulations.

8. In the meanwhile, based on certain news items, the

respondent asked for certain information from the Company 6

regarding the sale consideration of its subsidiary and the

distribution of the sale consideration to its shareholders. It is

submitted that the appellants provided all the requisite

information but SEBI not being satisfied directed the stock

exchanges to independently conduct a critical analysis of the

disclosures made by the appellant no. 1 Company. On this basis,

BSE submitted a report on December 12, 2019 indicating that

no serious effort was being made by the appellant no. 1

Company to distribute the proceeds to its shareholders and that

the delisting offer of Rs. 310.81 crore calculated on the basis of

floor price of Rs. 63.77 per share is far lower than Rs. 872 crore

parked by the appellant no. 1 Company in the escrow account.

NSE in its report dated January 3, 2020 advised SEBI to

conduct a forensic audit of the Company and further stated that

the delisting application should be considered after the audit

report. The appellant contended that as and when the

information was sought by the stock exchange necessary

information was provided. However, SEBI prima-facie came to

a conclusion that there was lack of proper trail utilization of

funds received from the transaction and non distribution of the

consideration to the shareholders appears to be suspicious and

that the floor price offered under the Delisting Regulations does 7

not commensurate with the funds available with the Company.

Accordingly, SEBI by an order dated July 17, 2020 appointed

Grant Thornton Bharat LLP (erstwhile Grant Thornton India

LLP) as the forensic auditor for financial years ending March

31, 2019 and March 31, 2020. The appellants were accordingly

directed to cooperate with the forensic auditor and supply the

necessary information.

9. It transpires that the forensic auditor requested the

appellant company to supply various documents some of which

were supplied but majority of the documents were not supplied.

It was contended that the business transfer agreement, share

purchase agreement and other documents relating to the sale

consideration were not readily available and the same was

sought from the purchaser. Further, on account of Covid

pandemic, the appellant was unable to provide the requisite

documents to the forensic auditor. It was further contended that

the appellant had not refused to cooperate with the forensic

auditor but only sought time to locate and procure the

documents so that the same could be provided to the forensic

auditor.

8

10. It seems that on the basis of some report submitted by the

forensic auditor for not supplying the requisite documents and

on the basis of certain complaints given by the investors had led

to the passing of the impugned ex-parte ad-interim order on

October 20, 2020 wherein the following directions were issued,

viz.-

"45. In view of the foregoing, in order to protect the interest of the investors and the integrity of the securities market, I, in exercise of the powers conferred upon me in terms of Section 19 read with Sections 11(1), 11(4) and 11B of the SEBI Act, hereby issue the following directions-

(i) Noticee no. 1 i.e. PDL is directed to deposit within seven working days from the date of receipt of this Order, the amount of Rs. 1292.46 Crore to an interest bearing Special Escrow Account ["Escrow Account in Compliance with SEBI Order dated October 20, 2020 -

A/c (in the name of the Company)"] in a Nationalized Bank. The Audit Committee of PDL shall directly monitor the process of creation of this Special Escrow Account and its funding as directed by this Order and furnish a Compliance Report to SEBI by October 30, 2020.

(ii) The subsequent operations in the above mentioned Special Escrow Account shall be monitored by JM Financial as its manager till the completion of the forensic audit. Further, JM Financial shall allow debits from the Special Escrow Account only for the purposes of administrative expenses of PDL. The 9

funds in the Special Escrow Account shall not be used by PDL for any other lines of business (including for deployment towards its residual business i.e. animal nutrition and cattle feed business), as committed in its disclosure to the stock exchanges on March 25, 2019.

(iii) PDL shall furnish a weekly statement of debits / credits/balance in the above mentioned Special Escrow Account commencing from October 30, 2020, to JM Financial till the completion of the forensic audit.

(iv) In case of failure to comply with the above directions, Noticee nos. 2 and 3 i.e. Sarangdhar Ramchandra Nirmal and Vivek Sarangdhar Nirmal, shall be restrained from disposing, selling or alienating, in any other manner, their assets or diver funds, except for the purpose of compliance with the direction at paragraph 45(i).

(v) Noticee nos. 1, 2 and 3 are directed to cooperate with the forensic auditor appointed as per the SEBI letter dated July 17, 2020 and shall furnish all information / documents to the forensic auditor / SEBI within seven working days. The Audit Committee of PDL is directed to ensure that all date / information may be provided to the forensic auditor / SEBI within seven working days."

11. The appellant being aggrieved by the aforesaid ex-parte

ad-interim directions has filed the present appeal which has

been taken up today on an urgent application being made. Since 10

direction no. 1 was not complied within the stipulated period as

directed in the impugned order the respondent has attached the

demat accounts and bank accounts of respondent nos. 2 and 3 in

furtherance of direction no. 4 of the impugned order, for which

purpose an additional affidavit was filed during the course of

hearing of this appeal.

12. We have heard Shri Janak Dwarkadas, the learned senior

counsel for appellants and Shri Rafique Dada, the learned senior

counsel for the respondent including Shri P.N. Modi, the learned

senior counsel appearing for interveners through video

conference.

13. An intervention application has been filed on behalf of

TVS Capital Funds Private Limited and Anr. seeking to

intervene in the present proceedings and prayed that they should

be made a respondent in the appeal or should be heard as an

intervener as they are necessary parties. On this application we

have also heard Mr. P.N. Modi, the learned senior counsel.

14. The contention of the intervener is, that the impugned

order has been passed on the basis of complaint made by them.

It was also submitted that they are holding 30.7% of the shares

of the Company and that they are vitally interested in 11

distribution of the sale consideration which has not been given

to the shareholders till date. It was, thus, urged that the

intervener should be impleaded as a necessary party.

15. On this issue, after hearing Mr. P.N. Modi, the learned

senior counsel at some length we are of the opinion that the

present dispute is between the directions issued by SEBI and

the appellants. The lis is between the appellants and the

respondent and therefore the applicant intervener is not a

necessary party nor is required to be impleaded as a respondent

in the appeal. Further, we are of the opinion that the interest of

the intervener is protected as, on their own showing, the

impugned order has been passed pursuant to the complaint filed

by them. However, even though the applicant intervener cannot

be impleaded as a respondent, nonetheless, we allow the

intervener to be heard. Accordingly, the intervention application

is allowed with the limited purpose that the intervener would be

heard. In this regard we have heard Shri P.N. Modi, the learned

senior counsel at some length.

16. The contention of Shri Janak Dwarkadas, the learned

senior counsel for appellants is, that the impugned order has

been passed without any application of mind. The direction to 12

deposit 1292.46 crore in a special escrow account and further

restraining the appellant no.1 Company from making any

expenditure in its subsidiary business is certainly not in the

interest of Company or its shareholders. It was urged that the

order is wholly arbitrary and is aimed to kill a running Company

which has 150 employees and 10,000 farmers.

17. The learned senior counsel urged that necessary

information was being supplied from time to time and as and

when respondent asked for information. It was urged that the

finding in the impugned order that the appellants gave hazy

reply with regard to the sale consideration is patently erroneous.

It was submitted that after meeting the tax liability, indemnity,

transaction cost and debt outstanding, the appellant had parked a

sum of Rs. 854.41 crore in a fixed deposit which fact was made

known to the stock exchanges and which is admitted by BSE in

its report. It was submitted that the account number was

mentioned in the report of BSE but the report observed that the

name of the bank has not been mentioned and therefore the

transaction appears to be suspicious. The contention that

evasive replies were supplied was totally erroneous and that full

particulars were provided. It was also submitted that on October

20, 2020 full particulars of an amount of Rs. 701.27 crore kept 13

in the fixed deposits were duly supplied to the respondent which

fact has not been considered while passing the impugned order.

It was, thus, contended that the finding that the whereabouts of

the sale consideration was not known or that there was a

possibility for diversion of funds is patently erroneous and is

based on surmises and conjectures.

18. The contention that requisite documents were not being

supplied to the forensic auditor is again incorrect. It was urged

that the appellants are always willing to cooperate with the

forensic auditor and supply the necessary documents. It was

submitted that necessary information could not be supplied on

account of non-availability of the requisite documents and on

account of restrictions because of the pandemic. Further, the

statutory audit was going on which was required to be

completed within the deadline and therefore this also led to the

delay in the supply of the requisite documents to the forensic

auditor. It was also submitted that the report of BSE which led

to the passing of the impugned order for deposit of 1292.46

crore was based on non application of mind and non

consideration of a vital fact. It was contended that SEBI is only

interested in protecting the interest of the minority shareholders

holding 49% of the shares of the Company. On the other hand, 14

the promoters and the promoter group of the Company holds

51% of the shares of the Company. It was, thus, contended that

according to the Company Rs. 854.41 crore was required to be

distributed to the shareholders towards share consideration. 50%

of the amount would go to the promoters which comprises of

51% and 49% would go to the minority shareholders. It was,

thus, submitted that 50% of Rs. 854 crore would come to Rs.

427 crore for which SEBI at best could have passed an order to

protect their interest but under no circumstances the order

directing the appellant to deposit Rs. 1292.46 crore could be

passed.

19. It was also contended that the respondent are only

considering the floor price of Rs. 63.77 paise which is not the

final price and was only determined in accordance with

Regulation 15(2) of the Delisting Regulations. It was submitted

that the discovered price in the delisting will be based on the

price at which the bids are placed by the public shareholders as

part of the reverse book building mechanism specified in the

Delisting Regulations. It was submitted that the acquirers in

their discretion may accept the discovered price or offer a higher

price than the discovered price or make a counter offer to the

public shareholders of the appellant no. 1 Company in 15

accordance with the Delisting Regulations. It was urged that as

part of the reverse book building mechanism, public

shareholders were free to submit bids for tendering the equity

shareholders held by them at any price offer over and above the

floor price which may deemed to be the fair exit price. After the

determination of the discovered price, the acquirer at their

discretion may accept the discovered price or offer a higher

price or make a counter offer through appellant no. 1 Company

in accordance with the Delisting Regulations. On this basis, it

was urged by the learned senior counsel that BSE in its report

committed an error in holding that the delisting offer was only

310.81 crore. Further, the respondent have not considered the

offer of the acquirers which an unconditional offer of Rs. 100

per share and thus total amount which would be distributed to

the minority shareholders would work out to approximately

Rs. 490 crore.

20. It was, thus, urged that if the distribution of the sale

consideration is given to the minority shareholders it would be

approximately Rs. 427 crore and the price offered under the

Delisting Regulations would come to Rs. 492 crore by the

acquirers. On this basis, it was urged that the direction of the 16

WTM directing the appellants to deposit Rs. 1292 crore was

based on non application of mind and was liable to be set aside.

21. It was also urged that the delisting application ought to

have been decided at the earliest as it was in the interest of the

shareholders which had approved the proposal and that SEBI

had nothing to do with the determination of the price of the

shares which is fixed and determined on the basis of reverse

book building mechanism specified in the Delisting

Regulations. It was, thus, contended that dehors the forensic

audit, the delisting application should be considered and decided

by the respondent without waiting for the forensic audit report.

22. In the light of the aforesaid, it was urged that the

impugned order is wholly arbitrary and if it is allowed to

continue it will kill the Company and close the business of the

Company and therefore prayed that the impugned order should

be set aside.

23. Shri Rafique Dada, the learned senior counsel for the

respondent contended that the intention of the respondent in

passing the impugned order was solely to protect the interest of

the shareholders of the Company. It was contended that

Company itself had indicated that substantial portion of the 17

proceeds of the sale consideration would be distributed to the

shareholders which till date has not been done. Further, the

appellant was required to declare the financial audited results

for the fourth quarter before July 31, 2020 which they have

failed to do so and therefore an irresistible inference was drawn

that there is something suspicious going on in the affairs of the

Company and therefore in order to protect the interest of the

investors, it was necessary to pass urgent orders.

24. Shri. Rafique Dada, the learned senior counsel for the

respondent further contended that the distribution of the sale

consideration to the shareholders should not be mixed with the

consideration of payment to be made under the delisting

application. It was urged that the sale consideration is required

to be paid by the appellant no. 1 Company and if the delisting

application if allowed, then it would be the acquirer who would

be required to pay to the shareholders. It was also contended

that complete details of utilization towards tax liability,

indemnity, etc has not been furnished and therefore considering

these factors and the interest of the investors and the security

market, the respondent directed the appointment of a forensic

auditor to basically scrutinize the transfer agreement and the

share purchase agreement as well as find out the veracity of the 18

utilization of funds received from the sale proceeds such as

payments made to advisors, provisions relating to indemnity

obligations, tax liability and their appropriateness. Since the said

information was not supplied to the forensic auditor the

impugned order was passed. In the written submissions, the

respondent contended that evasie replies were given by the

appellant relating to the deposits in the escrow account/fixed

deposits. It was further stated that after the passing of the

impugned order there has been a diversion of funds to various

entities and accounts. The respondent however submitted that

there is approximately Rs 1002 crore in fixed deposits with Yes

Bank and IndusInd Bank.

25. Shri P.N. Modi, the learned senior counsel for the

intervener, on the other hand, contended that the interveners

hold 30.70% of the shareholding in the Company and even

though they voted in favour of the delisting they are equally

open to the distribution of the said sale proceeds by way of buy

back or by way of distribution of dividend or a combination

thereof. It was, thus, urged that it was necessary for the

Company to park some amount in an escrow account in order to

safeguard the interest of the minority shareholders. It was urged

that the forensic audit will indicate the inflow of funds, its usage 19

and the actual amount that would be available for distribution to

the shareholders. It was contented that the direction of SEBI to

deposit 1292.46 crore is valid and should not be modified.

26. Having heard the learned counsel for the parties at some

length we find that the direction of the WTM to deposit a sum

of Rs. 1292.46 crore is wholly arbitrary and has been passed

without any application of mind. Admittedly, the sale

consideration has to be distributed to the shareholders of the

Company after meeting the tax liability, indemnity, transaction

cost, debt outstanding etc. According to the Company which is

recorded in the impugned order, the total amount comes to Rs.

1026.44 crore and the balance left for distribution of the

shareholders is Rs. 854.40 crore which amount is also reflected

in the annual report 2018-19 as well as in the report of BSE

dated December 12, 2019. It may be stated here that 50% of Rs.

854.41 crore which comes to Rs. 427 crore will go the

promoters and promoters group and approximately Rs. 427

crore would go to the minority shareholders comprising 49%.

Thus, the direction to deposit the entire sale consideration of Rs.

1292 is neither appropriate nor beneficial to the survival of the

Company at this stage. The fact that 50% of the sale 20

consideration is also required to be distributed to the promoters

and promoters group has not been disputed by the respondent.

27. We also find that the reason for the respondent to be

suspicious is, that they are taking into consideration the floor

price of Rs. 63.77 per share which works out to Rs. 310.81 crore

and compared it to the total amount of Rs. 854.40 crore lying in

the escrow account. The conclusion drawn by taking the floor

price is patently erroneous and against the Delisting

Regulations. It may be stated here that the discovered price in

the delisting will be based on the price at which bids are placed

by the public shareholders as part of the reverse book building

mechanism specified in the Delisting Regulations. The public

shareholders is free to submit bids for tendering the equity

shares held by them at any price above the floor price which

they may deemed to be a fair exit price. The amount, thus, has

to be calculated only after determination of the discovered price

and not on the basis of offer price. In any case, the appellants

have offered to its shareholders Rs.100/ per share which comes

to Rs.490/ crore which fact has not been taken into

consideration by the respondents. Thus, in our view the

direction to deposit a sum of Rs. 1292.46 crore is patently

erroneous and cannot be sustained.

21

28. We are also of the opinion that the determination of price

of the shares of the Company is the domain of the shareholders

and SEBI has no say in it. Further, the submission of the

forensic report also has nothing to do so far as the application of

the appellant for delisting approval is concerned in as much as

the person / entity who has to pay to the shareholders in the

event the delisting application is allowed is the acquirer and, on

the other hand, the distribution of the sale consideration has to

be done by the Company. To that extent the learned senior

counsel Shri Rafique Dada's contention on this aspect is correct

and justified but, at the same time, the respondent cannot blow

hot and cold and this can be seen from the fact that the

respondent is not proceessing the delisting application and are

awaiting the result of the forensic report which is only confined

to the sale transactions and the distribution of the tax liability,

indemnity, transaction cost etc.

29. Considering the aforesaid, we are further of the opinion

that the respondent knowing fully well that a substantial amount

was parked in fixed deposits, the direction to the appellant to

deposit Rs. 1292. 46 crore in an escrow account is neither just

nor proper especially when there is no specific finding on 22

diversion of funds. The written note submitted by SEBI further

indicates that a sum of Rs1002 crore is lying in fixed deposits..

Therefore the direction to deposit further amount would cripple

the Company and bring it to down to its knees which is neither

in the interest of the Company nor in the interest of its

shareholders.

30. We are further of the opinion that the appellant is required

to cooperate and supply all the requisite documents asked for in

terms of the reference made by SEBI and should cooperate in

the submission of the forensic report. This is essential in order

to find out as to what is the inflow pursuant to the sale and what

amount is left after meeting the tax liabilities, indemnity,

transaction cost, etc. We also find that the distribution of the

sale consideration and / or the distribution of the share price of

the shareholders pursuant to the delisting application are

required to be done at the earliest as it is necessary in the

interest of the minority shareholders. In this regard Shri Janak

Dwarkadas fairly conceded that the Company will cooperate

and provide all the requisite papers asked by the forensic

auditor. Shri Dwarkadas further submitted that under the sale

consideration an amount of Rs. 427 crore is liable to be

distributed to the shareholders and if the offer of the acquirer is 23

accepted then the acquirer are liable to pay approximately Rs.

490 crore.

31. Be that as it may. The forensic audit will determine the

inflow of funds, its usage and the actual amount that would be

available for distribution to the shareholders. It is thus necessary

for the forensic auditor to submit a report on this as aspect at the

earliest. The learned senior counsel for the appellant has clearly

submitted that the appellants will provide the necessary

documents and fully cooperate with the forensic auditor.

32. Considering the urgency, we have proceeded to decide the

matter finally since no factual controversy is involved at this

stage.

33. In view of the aforesaid, the impugned order cannot be

sustained and is quashed. The appeal is allowed with the

following directions:-

(i) The appellant no. 1 Company shall deposit a sum of

Rs. 500 crore in a separate escrow account within

10 days from today, the details of which would be

supplied to SEBI and to the stock exchanges.

24 (ii) The amount so deposited shall not be utilized by the

appellants till the submission of the forensic report

and the decision taken by the respondent on the

distribution of the amount to the shareholders

and/or the delisting application.

(iii) The appellants shall provide all the necessary

information and documents relating to the sale, etc

and as asked by the forensic auditor in this regard

which is depicted in the impugned order within ten

days from today. SEBI will direct the forensic

auditor to furnish the forensic report within four

weeks from the date of the submission of the

documents supplied by the appellants ascertaining

the amount received from the sale and the amount

distributable to the shareholders after meeting tax

liability, indemnity, transaction cost, payment to

advisors, etc.

(iv) Simultaneously, the respondent shall process the

delisting application under the Delisting

Regulations and SEBI (Substantial Acquisition of 25

Shares and Takeover) Regulations 2011and pass

appropriate orders within six weeks from today.

(v) Upon deposit of Rs. 500 crore, the demat accounts

and bank accounts of appellant nos. 2 and 3 shall be

defreezed.

(vi) In the circumstances, there shall be no order as to

costs. The urgency and other misc. applications are

accordingly disposed of.

34. The present matter was heard through video conference

due to Covid-19 pandemic. At this stage it is not possible to sign

a copy of this order nor a certified copy of this order could be

issued by the registry. In these circumstances, this order will be

digitally signed by the Presiding Officer on behalf of the bench

and all concerned parties are directed to act on the digitally

signed copy of this order. Parties will act on production of a

digitally signed copy sent by fax and/or email.

Justice Tarun Agarwala Presiding Officer

Dr. C.K.G. Nair Member 26

TARUN Digitally signed by TARUN AGARWAL DN: c=IN, o=PUBLIC WORKS DEPARTMENT UTTAR PRADESH, postalCode=221505, st=Uttar Pradesh, 2.5.4.20=30fcf68685192bbc53e6ff1608a83fb3881de7ac2ab79

AGARWAL 54d509c85ed6e0f7c41, serialNumber=095f8b286bb0b1cd07ff676611f4f5e7999727d4 04aa38ca422f9d3529bdb8a3, cn=TARUN AGARWAL Date: 2020.11.09 11:14:34 +05'30'

Justice M.T. Joshi Judicial Member 09.11.2020 msb