IN THE SECURITIES APPELLATE TRIBUNAL

MUMBAI

Appeal No: 61/2003

Date of Hearing

28/10/2004

Date of Decision

17/11/2004

 

In the matter of

 

Appellant � Represented by:

VLS Finance Limited

Mahendra C. Bhuta, Company Secretary

Versus

 

Securities & Exchange Board of India

Respondent- Represented by

 

Dipan Merchant, Advocate

 

CORAM

 

��������� Justice Kumar Rajaratnam, Presiding Officer

��������� Dr. B. Samal, Member

��������� N.L. Lakhanpal, Member

 

 

Per:��� N.L. Lakhanpal, Member

 

 

1.                  The appeal is taken up with the consent of parties for final disposal.

2.                  The appeal is against the order dated March 31, 2003 passed by the Adjudication and Enquiry Officer, Securities and Exchange Board of India, imposing a penalty of Rs. 5 lakhs on the appellant M/s. VLS Finance Limited, under Section 15H(ii) of SEBI Act, 1992 for the appellant�s failure to make a public announcement under the SEBI (SAST) Regulations, 1997.

3.                  It is common ground that the appellant had advanced a sum of Rs. 2.40 crore to M/s. Trackparts of India Limited (TPIL) in terms of pledge document dated 09/03/1995.TPIL deposited 3,44,658 shares with the appellant, M/s. VLS Finance Limited by way of collateral securities for the sum advanced.As per the agreement, the acquirer had the right to sell the shares pledged to realize its dues.On 20/08/1998 the parties entered into a fresh Memorandum of Understanding (MOU) agreeing that the shares pledged would be transferred in the name of the pledgee but that these shares would continue to be held as collateral securities and the pledgee would sign a power of attorney in favour of Shri K.N. Bhargava and/or Shri B.N. Bhargava representing TPIL for the purpose of voting at shareholder�s meetings.It was further agreed that the outstanding amount would be paid by TPIL within a period of 3 months failing which the pledgee would be at liberty to dispose of the shares to realize his dues. Accordingly, the power of attorney was executed by the pledgee on 27/08/1998 whereby it authorized Shri K.N. Bhargava, Chairman and Managing Director and Shri B.N. Bhargava, Senior Vice President and Joint Managing Direct of TPIL �as our lawful attorneys to attend and vote for us on our behalf at all the general meetings of the TPIL, Kanpur, to be held hereafter�. The shares of TPIL were transferred in the name of VLS Finance Limited on 26/08/1998. The appellant made an application to SEBI on 09/11/1998 seeking exemption from the provisions of SEBI (SAST) Regulations, 1997 which was rejected by SEBI vide order dated 19/02/2002. The Adjudicating Officer was appointed on 12/12/2002 to enquire into and adjudge the contraventions of Regulation 10 of SEBI (SAST) Regulations, 1997 by M/s. VLS FinanceLimited for failure to make the public announcement pursuant to the acquisition of these 3,44,658 shares which constituted 16.41% of the paid up equity capital of the target company, TPIL.The impugned order imposing a penalty of Rs. 5 lakhs was passed on March 31, 2003.

4.                  During the hearing of the appeal before us, with the facts not being in dispute, the only short point for consideration was whether the transfer of shares in the name of the appellant for realizing its lawful dues amounted to acquisition as defined in SEBI (SAST) Regulations, 1997. The learned Senior Counsel for the appellant argued in this context that the transfer of shares took place as a result of a mutual agreement and that in terms of this agreement, the shares continued to remain with the appellant as collateral securities despite transfer of ownership and the voting rights arising from the transfer of these shares continued to be exercised by Shri K.N. Bhargava and Shri B.N. Bhargava on the basis of the power of attorney executed in their favour. According to the learned counsel the transfer of these shares was also a subject matter of dispute before the Hon�ble Company Law Board and that even if this transfer was considered as acquisition, such acquisition was not yet complete and final because of the challenge before the Company Law Board.On going through the impugned order we find that the same two grounds had been taken up before the Adjudication and Enquiry Officer also and these issues have been adequately and correctly considered in the impugned order. In any case, the fact of the matter is that the shares were indeed transferred in the name of the appellants and it was the appellant whose name came to be entered as beneficial owner in the register of members of the company and under Section 41(3) of the Companies Act, it was the appellant who was deemed to be a member of the TPIL w.e.f. the date of transfer of shares.The voting rights thus vested with the appellant and the question whether he exercised these voting rights himself or through Shri K.N. Bhargava and Shri B.N. Bhargava through the power of attorney does not alter the situation with respect to the acquisition in any manner whatsoever.In the light of this position we do not find anything objectionable in the impugned order.

5.                  During the hearing, the learned Counsel for the appellant seemed to be inclined to accept this position but was apprehensive that despite this adjudication order SEBI might nevertheless again direct him to make a public offer or take further proceedings under Section 11 or Section 24 of the SEBI Act, 1992.The learned counsel for the respondent fairly made a statement across the bar that even though SEBI could take additional actions as apprehended by the appellant, there was no such proposal before SEBI to initiate any further proceedings. On instructions, the learned Counsel for SEBI agreed that his statement across the bar be taken on record for allaying the appellant�s apprehensions on this score. With this view of the matter we dismiss the appeal and confirm the impugned order.There shall be no order as to costs.

 

(Justice Kumar Rajaratnam)

Presiding Officer

 

 

(Dr. B. Samal)

Member

(N.L. Lakhanpal)

Member

 

Place: Mumbai

Date: 17/11/2004

 

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