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Order against Shri Upendra C Shah and Smt. Nilam Shah

Nov 11, 2004
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Orders : Orders of AO

ORDER

 

 

UNDER RULE 5(1) OF THE SEBI (PROCEDURE FOR HOLDING ENQUIRY AND IMPOSING PENALTY BY THE ADJUDICATING OFFICER) RULES, 1995 READ WITH REGULATIONS 6(1) & (3) AND 8(1) & (2) OF THE SEBI (SUBSTANTIAL ACQUISITION OF SHARES & TAKEOVERS) REGULATIONS, 1997 AND SECTION 15A OF THE SEBI ACT, 1992.

 

AGAINST

 

SHRI UPENDRA C SHAH AND SMT. NILAM U SHAH 

BACKGROUND:

 

1. I was appointed as the Adjudicating Officer by the Chairman, SEBI, vide order dated September 30, 2004 to enquire into and adjudge the alleged contravention of sub-regulations (1) & (3) of Regulation 6 (for the year 1997) and sub-regulations (1) & (2) of Regulation 8 (for the years 1997, 1998, 1999 & 2000) of the SEBI (Substantial Acquisition Of Shares & Takeovers) Regulations, 1997 (for brevity’s sake referred to as the Regulations) read with sub-section (b) of Section 15A,  of the SEBI Act, 1992 (hereinafter referred to as the Act) by Shri Upendra C Shah and Smt Nilam C Shah  (collectively referred to as the “past promoters” of Star Leasing Ltd, (hereinafter referred to as SLL) whose shares are listed on the stock exchange, Mumbai in the matter of the non disclosure of their shareholding in the said company.

 

2. The Securities and Exchange Board of India (hereinafter referred to as the SEBI) received a draft letter of offer under cover of letter dated March 22, 2001 from M/s. Ashika Credit Capital Ltd, the merchant banker, acting on behalf of Mr. Mir Ahmed Ali Khan and Mr. Mir Hasnain Ali Khan, person acting in concert (together referred to as the “acquirers”) for an open offer made by them to the shareholders of SLL for the purchase of 48,000 fully paid equity shares of Rs.10 each at the price of Rs.15 per share representing 20% of the subscribed and paid-up share capital of SLL. Thereupon, SEBI vide its letter dated April 12, 2001 while advising the merchant banker to carry out certain changes in the said draft letter of offer also called upon them to confirm and disclose as to whether the applicable provisions of the Regulations had been complied with by the past promoters. In response thereto, the merchant banker vide their letter dated April 18, 2001 informed SEBI that the past promoters had not complied with the provisions of Chapter II of the said Regulations.

 

3. A disclosure to this effect is also mentioned in the letter of offer dated April 17, 2001 that was sent to the shareholders of SLL. The relevant portions of the disclosures made in this regard at page 6 point no.4.6 of the said letter of offer reads as follows:

 

 ‘……………….the sellers to the agreement have defaulted in compliances with the provisions of Chapter II of SEBI (SAST) Regulations, 1997.’

 

 SHOW CAUSE NOTICE/ REPLY/ PERSONAL HEARING:

4.                 In view of the alleged violation of the Regulations above mentioned, a notice dated July 10, 2001 was issued to the past promoters in terms of Rule 4 of the SEBI (Procedure for holding enquiry and imposing penalty by the Adjudicating Officer) Rules, 1995 wherein they were asked to show cause as to why enquiry proceedings should not held against them for the alleged violation of the provisions of sub regulations (1) and (3) of Regulation 6 (for the year 1997) and sub regulations (1) and [2] of Regulation 8 (for the years 1997,1998,1999 and 2000) of the Regulations. A copy of the letter of offer dated April 17, 2001 along with the copy of the letter of the merchant banker dated April 18, 2001 was enclosed along with the said notice. The past promoters were advised to make their submissions, if any, along with supporting documents that they wished to rely upon, within 14 days from the date of the receipt of the notice, and also indicate whether they were desirous of a personal hearing. In reply to the same, the two past promoters vide their letters; both dated July 23, 2001 sought two months time to submit their reply, which was granted by the then adjudicating officer. Subsequently, the past promoters vide their letters; both dated August 7, 2001 denied non-compliance of the said Regulations as brought out in the notice and further made the following submissions:

a.        The required information had been submitted to SSL in due compliance with Regulations 6[1] and [2] of the Regulations for the year 1997 and the same was evident from the letter issued by the merchant banker certifying compliance of Regulation 8(1) of the Regulations for the year 1997.

b.      Due to the change of management in SLL, they were unable to provide the necessary documentary proof to substantiate their claim of compliance of Regulation 6[1] of the Regulations independent of Regulation 8[1] of the Regulations.

c.       Based on the information supplied by them, SLL had also complied with the requirement of Regulation 8[3] of the Regulations on April 22, 1997 as certified by the merchant banker in their letter dated April 22, 1997. Therefore, compliance of Regulation 8[1] on their part could not be disputed.

d.      There was as no reason to assume that they had not complied with the requirement of Regulation 6[1] of the Regulations, when they had complied with Regulation 8(1) of the Regulations. Further Regulation 6 the Regulations was a transitional provision while Regulation 8 the Regulations required yearly disclosures. Thus upon making the disclosure under Regulation 8 the Regulations within the prescribed period, no further default remained on their part.

e.       They held more than 10% of the shares of SLL and the disclosure to that effect was made on April 19, 1997 which also covered the disclosures to be made under Regulations 8[1] and 6[1] of the Regulations.

f.        Since Regulation 6[3] is parallel to Regulation 8[2] of the Regulations, the disclosures made by them on April 19, 1997 under Regulation 8[2] of the Regulations, as per the certificate of the merchant banker, would also cover the disclosure under Regulation 6[3] of the Regulations even if the same was not separately made. Hence there was no default as regards Regulation 6[3] of the Regulations.

g.       From the certificate of the merchant banker, it was clear that they had made the necessary disclosures in terms of Regulations 8[1] and 8[2] of the Regulations. Hence there was no default for the year ending March 31, 1997. So far as the years ended on March 31, 1998, March 31, 1999 and March 31, 2000 were concerned; they “must have made the required disclosure”, but were not in a position to provide the documentary proof to substantiate their claim.

h.       Assuming that they had not made subsequent disclosures on an annual basis, the same was of a technical nature since there was no change in the shareholding pattern till March’ 2000.

i.         Yearly disclosures were to be made only if there was any change in shareholding between two balance sheet dates. Hence, there was no breach of Regulations 8[1] and 8[3] of the Regulations. In this context, they referred to the decision of the Supreme Court in the case of Hindustan Steel Ltd vs. State of Orissa and also that of the Gujarat High Court in the case of Commissioner of Income-tax vs. Harsiddh Construction (P) Ltd. On the said basis, it was contended that no penalty should be imposed upon them and their mistake should be condoned since it was of a technical nature.

 

5. Subsequently, in terms of Rule 5(1) of the SEBI (Procedure for Holding Enquiry and Imposing Penalty by the Adjudicating Officer) Rules, 1995, the then adjudicating officer sent a notice dated August 14, 2002 calling upon the past promoters to attend the hearing proceedings to be held on August 27, 2002 and submit further submissions, if any, in their defense. In reply to the same, the past promoters vide their letter dated August 24, 2002 stated that they had already made their submissions in their letter dated August 7, 2001 and on the said basis, requested that the proceedings be dropped.

 

6. In the mean time, SEBI introduced the SEBI Regularisation Scheme, 2002 (hereinafter referred to as the said ‘Scheme’) which was in force from October 1, 2002 to January 31, 2003 for listed companies which had failed to comply with or complied with the requirements of Regulations 6[2], 6[4] and 8[3] of the Regulations after the expiry of the period specified in the said Regulations. For persons who had failed to comply with or complied with the requirements of Regulations 6[1], 6[3], 8[1] and 8[2] of the Regulations after the expiry of the period specified in the Regulations, the scheme was in force from October 1, 2002 to December 31, 2002. Consequently, an opportunity was provided both to the target companies and the persons in control / promoters, for regularizing the non-compliance with Regulations 6 and 8 of the Regulations for the years 1997 – 2002.  

 

7.  Despite being granted an opportunity to regularize their non-compliance of the provisions of the Regulations 6[1], 6[2], 8[1] and 8[2] of the Regulations, the past promoters did not participate in the said scheme.

 

8. However, keeping in mind, the principles of natural justice, another opportunity was granted to the past promoters vide notice bearing no. A&E/SVK/641/04 dated August 17, 2004, not only to be heard in person on September 15, 2004 but also to submit the documentary proof in support of their compliance. It was further made clear to the past promoters that in case they failed to appear for the said proceedings, the matter would be decided solely on the basis of the material available on record.  However, the above notice of hearing was returned undelivered by the postal department with remarks “Informed” and “N/C”.

 

CONSIDERATION OF ISSUES:

 

9. I have taken into consideration the facts and circumstances of the case, the material available on record including the show cause notice, the replies of the past promoters as well as the notices of hearing sent to them. I have noted that the past promoters were holding 48,000 shares i.e. 20% of the shareholding and voting rights of SLL and remained promoters of SLL till March 12, 2001 as disclosed in the letter of offer filed by the acquirers with SEBI. Therefore by virtue of being a promoter of SLL, the past promoters were under an obligation to comply with the provisions of Regulations 6(1) and 6(3) of the Regulations for the year 1997 and Regulations 8(1) and 8(2) of the Regulations for the years 1997, 1998, 1999 and 2000.  

 

10. Sub regulations (1) and (3) of Regulation 6 of the said Regulations reads as follows:

 

“6[1] Any person, who holds more than five percent shares or voting rights in any company, shall within two months of notification these Regulations disclose his aggregate shareholding in that company, to the company.

 

6[3] A promoter or any person having control over a company shall within two months of notification of these Regulations disclose the number and percentage of shares or voting rights held by him and by person(s) acting in concert with him in that company, to the company”.

 

11. Further sub regulations (1) and (2) of Regulation 8 of the said Regulations reads as follows:

“8 (1) Every person, including a person mentioned in Regulation 6 who holds more than fifteen percent shares or voting rights in any company, shall, within 21 days from the financial year ending March 31, make yearly disclosures to the company, in respect of his holdings as on 31st March.

8(2) A promoter or every person having control over a company shall, within 21 days from the financial year ending March 31, as well as the record date of the company for the purposes of declaration of dividend, disclose the number and percentage of shares or voting rights held by him and by persons acting in concert with him in that company to the company.

 

12. From the letter of offer dated April 17, 2001 as well as the information provided by the merchant banker, the past promoters had allegedly not complied with the provisions above mentioned. In their defense, the past promoters have consistently denied any violation of the provisions of the said Regulations, but have failed to provide the documentary proof to substantiate their claim inter alia on the ground that there was a change of management control in SLL.

 

13. The past promoters seem to rely heavily upon the certificate of compliance issued by the past promoters for the year 1997. As can be seen from the status of compliance by the past promoters in the table given below, the certificate of compliance was issued only for the year ending March 31, 1997.

 

Status of the compliance in respect of the past promoters (sellers

to the agreement)

S.No.

Regulation/ Sub-Regulatin

Due date for compliance

Actual date of compliance

Delay, if any, (in no. of days)

Col 4 – Col 3

Remarks

1

2

3

4

5

6

I

Reg.6(1)

20.04.1997

Nil

----

Not complied

II

Reg.6(3)

20.04.1997

Nil

----

Not complied

III

Reg.8(1)

21.04.1997

19.04.1997

----

 

 

 

21.04.1998

 Nil

-----

Not complied however no change

 

 

21.04.1999

 Nil

------

 

 

21.04.2000

 Nil

------

IV

Reg.8(2)

21.04.1997

19.04.1997

----

 

 

 

21.04.1998

 Nil

-----

Not complied however no change

 

 

21.04.1999

 Nil

------

 

 

21.04.2000

 Nil

------

 

 

14. The promoters have stated that they had submitted the information to SLL as on April 19, 1997 under Regulation 8[1] of the Regulations. However the said information only provides details of the number of shares held, and percentage of the individual shareholding of each of the promoters in the target company but does not disclose the aggregate number of shares and percentage of the shares / voting rights held by each of them along with persons acting in concert, as well as details of the control if any held by such persons. Thus, the absence of requisite information does not validate the non compliance by the past promoters and the certificate issued with reference to Regulation 8[1] cannot be used as a reference point for due compliance under Regulations 6[1] & 6[3] of the Regulations.

 

15. Regulation 8 emphasizes  the requirement of continual disclosures. However, the disclosures made under Regulation 8[1] would not amount to compliance of Regulation 8[2] of the Regulations, since in terms of Regulation 8[2] of the Regulations, every promoter/ person having control over a company is required to disclose the number and percentage of shares/ voting rights held by them and by persons acting in concert within in that company, to that company. Thus details of mere shareholding without information as regards control over a company, does not amount to compliance thereof.

 

16. Further, there is no basis for the contention of the past promoters that compliance with Regulation 8[1] of the Regulations would automatically mean compliance with Regulation 6[1] of the Regulations. The said contentions are based on assumptions which cannot be arrived at, without any basic facts to substantiate them. There is a clear distinction between Regulations 6[1] and 8[1] of the Regulations. As detailed above, the Regulation 6[1] of the Regulations contains transitional provisions which enable SEBI to use that information as a reference point for subsequent compliances. For instance, in case of a compliant received against an entity to the effect that there was no compliance by it of certain regulations or change in control of management of a specific company, the information provided under Regulation 6 of the Regulations is taken into account to arrive at the finding as regards the complaint so made. In any case, as stated earlier the information provided on April 19, 1997 to SLL would only have relevance for the year April 21, 1997 and could not have been used for the subsequent years i.e., 1998, 1999 and 2000. Even in case there was no change of control in the subsequent years, the same was required to be disclosed in as much as the said information requires such disclosures to be made every year (annual disclosure).

 

17. It would be relevant to state here that in proceedings initiated against SLL inter alia for the failure to make disclosures under Regulation 8[3] of the Regulations for the years 1997,1998,1999 and 2000, SLL was directed to participate in the regularization scheme and inform the stock exchanges about the status of shareholdings of persons in terms of Regulation 8[3] of the Regulations for the years 1997,1998,1999 and 2000 although the same remained unchanged for the said years. In terms of the scheme, the target company was not required to pay any money for submitting this information.

 

18. From the above, it is clear that the required information under Regulations 8[1] and  8[2] of the Regulations for the years 1997, 1998, 1999 and 2000 was not provided to SLL which therefore did not file the information under Regulation 8[3] of the Regulations to the stock exchange for the said years.

 

19. Moreover, SLL had also vide their undated letter received by SEBI on September 18, 2001, clearly stated that the earlier management of the company had not disclosed the required information under the provisions of the Regulations.

 

20. In this context, it would be relevant to refer to the earlier discussed scheme that was introduced to enable defaulting persons and companies to comply with the disclosure requirements mentioned under Regulations 6 and 8 of the Regulations that they had failed to make earlier, within the stipulated period as provided for in the Regulations.

 

21. As the past promoters were aware that they had no documentary proof in their possession to prove their compliance of the relevant regulations, when in fact they should have maintained such documents, they could have participated in the said scheme and regularized their non-compliance thereof. However, they did not avail this opportunity. On the contrary, despite being offered several opportunities to present their case, they kept themselves away from the hearing proceedings and stuck to their contention that they had complied with the regulations, but never provided any evidence to support their claim.

 

22. Mere contentions stating compliance with the regulations without furnishing the documentary proof of the same to substantiate the claim, does not absolve the past promoters from the charge of non-compliance of the said Regulations.

 

23. It is clear from the facts and events above mentioned that it was open for the past promoters to conclude these proceedings at a very early stage simply by producing the necessary documents as proof of having made the disclosures at the relevant point of time. Their failure to do so makes it clear that they had nothing to offer or submit in support of their defense and as a last resort have raised the plea of technicality and the issue of their bonafides.

 

24. In so far as the bonafides of the past promoters is concerned, there is nothing on record to lead one to the inference that the past promoters honestly believed that they had made the necessary disclosures when called upon to do so. On the contrary, from the facts detailed above, an inference can easily be drawn that the past promoters were not unaware of the compliance requirements and yet deliberately disregarded the legal obligations cast upon them. Any evasion of the compliance requirements of the regulations is bound to affect the interest of the investors in as much as these initial and continual disclosures to the company each year not only ensure transparency and timely disclosures to the company about the shareholding / voting rights of specified persons but also enables dissemination of the said information in turn to the shareholders and the public at large by the company by way of submission of information to the stock exchanges where the shares of the company are listed. While the failure to submit the required information and the subsequent loss, if any, caused to the investor is not tangible and cannot be specifically computed in monetary terms, the fact remains that every statute and the regulatory provisions contained therein have a specific purpose behind its enactment. The very purpose of enacting any legislation is due adherence to the provisions / procedures laid down there under. If no cognizance were to be taken of any breach of these provisions and no liability fixed there upon, the entire purpose of incorporating the provisions of the said Regulations would become redundant.

25. It is not that the past promoters had a series of procedures to follow and that although part of the procedure was complied by them; the remaining was left uncomplied, thereby lending credence to their contention of having acted in a bonafide manner. Their very defense that “they must have complied but had no documents to prove the same” not only seems unbelievable but shows their apathy in conforming to the regulatory provisions.

 

26.  In view of the above, it is clear that the case laws cited by the past promoters does not have any relevance to the present case.  

 

27. I have examined the principle laid down in the case of Hindustran Steel Ltd  vs State of Orissa, which considerably deals with the issue of imposition of penalty and agree that the penalty to be imposed for failure to perform a statutory obligation, is a matter of discretion of the authority to be exercised judiciously after considering all the relevant circumstances.

 

28. However, there is no obligation not to impose any penalty whatsoever upon an entity especially in cases where there was a technical breach, which could have been rectified. In the instant case, the regularization scheme provided the said opportunity. In spite of being aware of the fact that they had no proof to show compliance of the regulations, the past promoters never availed this opportunity to regularize their acts. In fact, I have it on record, that in cases where certain entities had no proof to substantiate their claim, they took part in the regularization scheme. Thus the manner in which the past promoters acted, it is clear that the said breach did not flow from a bonafide belief to act in the manner prescribed by the statute.

 

29.. In view of the above, no case has been made out by the past promoters for not imposing any penalty whatsoever and dropping the present proceedings.

30. One of the objectives of the Takeover Regulations is to protect the rights of the investors through prompt disclosures.

 

31. As brought out earlier, the purpose of such initial and continual disclosure to the company each year, is to ensure transparency and timely disclosures to the company about the shareholding/ voting rights of the specified persons and the dissemination of the said information in turn to the shareholders and to the public at large, by the company by way of submission of the said information to the stock exchanges where the shares of the said company are listed. Thus the failure on the part of the past promoters has defeated the very essence of the Regulations which envisage timely disclosure of the requisite information to the company and in turn to the shareholders at large.

 

32. Even assuming for a while that the required disclosures were made by the past promoters, in the absence of any documents evidencing that they have complied with the said Regulations or in the absence of any material available on record, viz., the dates when the required disclosures / information was furnished to the company or any other information relevant to the case, it would not be wrong to conclude that there has been total non-compliance by the past promoters of Regulations 6[1], 6[3], 8[1] and 8[2] of the Regulations. However I have taken note of the fact that though the past promoters were under an obligation to comply with the provisions of Regulations 6(1) and 6(3) of the Regulations for the year 1997 and Regulations 8(1) and 8(2) of the Regulations for the years 1997, 1998, 1999 and 2000, in the case of Regulations 8(1) and 8(2) of the Regulations, there was no change in shareholding or control for the years 1998, 1999 and 2000.

33. Failure to make requisite disclosures attracts monetary penalty as specifically provided in Section 15A(b) of the SEBI, Act, 1992 which reads as follows:

 

“If any person who is required under this Act, or any rules or Regulations made there under –

 

(b) to file any return or furnish any information, books or other documents within the time specified therefore in the Regulations, fails to file return or furnish the same within the time specified thereof in the Regulations, he shall be liable to a penalty not exceeding five thousand rupee for every day during which such failure continues.”

 

34. Thus, non-compliance of Regulations 6[1], 6[3], 8[1] and 8[2] of the Regulations attracts the penalty as prescribed under clause (b) of Section 15A of the Act i.e., Rs.5000/- per day, during which such failure continues, for each such failure. The question now arises as to what penalty should be imposed on the past promoters, in the light of the provisions of the said regulations read with clause (b) of Section 15A of the Act. In the case of the past promoters, the table below enumerates the due dates for compliance, the number of days of delay in the said compliance and the penalty that can be levied under the provisions of section 15A(b) of the Act (calculated on the basis of the quantum of the penalty that is to be imposed as on the date of the commission of the offence).

 

Non-compliance of Regulations

Due date for

Compliance

Date of compliance

No. of days of delay

Penalty as per Section 15A(b) of the SEBI Act,1992*

Penal Amount in Rs.*

6(1) & 6(3)

20-Apr-1997 

Not complied till date of hearing i.e

17-Aug-2004 

2676

Rs.5000/- per day till the date of compliance

1,33,80,000

8(1) & 8(2)

21-Apr-1997 

 -do-

2675

 - do-

1,33,75,000

8(1) & 8(2)

21-Apr-1998

 -do-

2310

 -do-

1,15,50,000

8(1) & 8(2)

21-Apr-1999

 -do-

1945

 -do-

97,25,000

8(1) & 8(2)

21-Apr-2000

 -do-

1579

 -do-

78,95,000

Total

5,59,25,000

 *However, with effect from October 28, 2002 the penalty amount was increased to Rs.1 lac per day during which the failure continued or Rs.1 crore whichever is less

 

35. It is to be noted that the Takeover Regulations deal primarily with issues which include consolidation of holdings, conditional offers, change in control, periodic disclosures and most important of all investor protection.  The past promoters would seem to that extent to have failed to satisfy the criteria of having ensured transparency in their various transactions and provide proof of the disclosures of their shareholding and control in a listed company.

 

36. However, the Parliament in its wisdom has directed certain factors to be taken in to account by the adjudicating officer, before imposing a penalty as is evident from the provisions of Section 15J of the Act which reads as follows:

 

15 J . While adjudging quantum of penalty under section15-I, the adjudicating officer shall have due regard to the following factors, namely: -

a)  the amount of disproportionate gain or unfair advantage, wherever quantifiable, made as a result of the default;

b)  the amount of loss caused to an investor or group of investors as a result of the default;

c)  the repetitive nature of the default

 

37. These provisions also find mention in Rule 5(2) of the SEBI (Procedure for holding enquiry and imposing penalty by the Adjudicating Officer) rules, 1995.

 

38. Thus, it is clear that the adjudicating officer is required to have due regard to the factors mentioned above. The same is a direction and not an option, which is however to be exercised with due regard to his discretion. This discretion is to be exercised judiciously, depending upon the facts and circumstances of each case as well as after analysing all the relevant material available on record especially in the case of failure to perform statutory obligations.

 

39.  In the present case, there is no dispute regarding the fact that no documentary proof was submitted to the adjudicating officer at any point of time by the past promoters for the present proceedings to be dropped. The default of the past promoters is continuing till date. However, the penalty cannot be a multiplier simpliciter of the number of days and the amount i.e., Rs.5000/-.

 

40. Thus the commensurate penalty to be levied in the instant case, has to be fixed keeping in mind the rationale behind the requirement of initial and continual disclosures to be made to the company, the nature of violation, the extent to which the violation has affected the interest of the investors in securities, the facts and circumstances of the case as discussed earlier in detail, the mitigating factors, if any. Bearing these factors in mind, I am inclined to hold that although the penalty need not be imposed in terms of the calculations made in the tabular column brought out earlier, the imposition of penalty is very much necessitated.  

 

ORDER:

 

41. In terms of the SEBI Regularisation Scheme, the amount payable for regularizing non-compliances of Regulations 6(1), 6[3], 8[1] and 8[2] is Rs.10000/- each per year. Keeping the same in mind as well as the principles enunciated above, in exercise of the powers conferred upon me under Rule 5 of the SEBI (Procedure for Holding Enquiry and Imposing Penalty by the Adjudicating Officer) Rules, 1995, I am inclined to arrive at a equitable resolution of the issue on hand and in the interest of justice, equity and good conscience think it appropriate to levy a penalty of Rs. 50,000/- collectively payable by the two past promoters for non-compliance of the Regulations 6[1], 6[3], 8[1] and 8[2] as mentioned earlier.

 

42. The penalty amount shall be paid through a cross demand draft drawn in favour of “SEBI- Penalties remittable to the Government of India’ and payable at Mumbai which may be sent to Shri.S.V.Muralidhar Rao, General Manager, Securities and Exchange Board of India, Mittal Court, B Wing, 224 Nariman Point, Mumbai – 400021.

 

 

Date:  NOVEMBER 11, 2004 G. BABITA RAYUDU
Place: Mumbai ADJUDICATING & ENQUIRY OFFICER