Interpretation of Securities Laws

ManojSinghBisht
INTERPRETATION OF
SECURITIES LAWS

CONTENTS
 Rules of Interpretation
 Rules of language
 Making a choice – factors to be considered
 Why do we need Securities Laws ?
 Equity Vs Law
 Reasonable Man Theory
 Regulator’s Thinking
 Ruthless Approach – Need of the Hour ?
 SEBI Informal Guidance Scheme
 Some Interpretation exercise
 Some Case Studies – for Interpretation

Why do statutes needs interpreting ?
• Several statutes are notified year on year.
• Everyone desires that the statute(s) come with a clear and
unambiguous language
• Legislature (Big Boss) expects it to be so !
• “JALDI” train……. !
• However, post notification of such statutes and while applying
provisions of such statutes in real life situations, several
ambiguities and infirmities comes into notice!
• Thereby, leading to confusion, panic, turbulence and litigation (
which may go on for years)
• Hence, role of professionals, bureaucrats, judiciary including
quasi judiciary bodies becomes critical, in order to safeguard the
intent for which the statute(s) was brought into force.

Key Rules of Interpretation
 Literal - interpret the statute literally according to ordinary
plain meaning
 Golden Rule – absurdity arises by applying literal rule ?
Choose reasonable meaning approach. “Ordinary sense of
the words” – dictionary meaning.
 Mischief Rule (Purposive) -
a) what was the law before the statute was passed
b) what ‘ mischief’ was sought to be remedied’
c) what remedy was being provided
Suppresses the mischief and provides remedy.

Literal Rule
→ The first and foremost principle of interpretation of
a statute in every system of interpretation is the
literal rule of interpretation.
→ The other rules of interpretation e.g. the mischief
rule, purposive interpretation etc. can only be
resorted to when the plain words of a statute are
ambiguous or lead to no intelligible results or if
read literally would nullify the very object of the
statute.

Literal Rule
→the literal rule of interpretation is not only followed by Judges and
lawyers, but it is also followed by the lay man in his ordinary life. To
give an illustration, if a person says "this is a pencil", then he means
that it is a pencil; and it is not that when he says that the object is a
pencil, he means that it is a horse, donkey or an elephant.
→In other words, the literal rule of interpretation simply means that
we mean what we say and we say what we mean. If we do not follow
the literal rule of interpretation, social life will become impossible,
and we will not understand each other.
→If we say that a certain object is a book, then we mean it is a book.
If we say it is a book, but we mean it is a horse, table or an elephant,
then we will not be able to communicate with each other. Life will
become impossible. Hence, the meaning of
the literal rule of interpretation is simply that we mean what we say
and we say what we mean.

Downside of Literal !
Whitely vs. Chappel (1868)
 a statute made it an offence "to impersonate any person entitled to
vote".
 The defendant used the vote of a dead man.
 The statute relating to voting rights required a person to be living in
order to be entitled to vote.
 The plain meaning rule was applied and the defendant was thus
acquitted.

Golden Rule
 The golden rule permits the courts to depart from the plain (literal)
meaning rule if the meaning leads to consequences it considers to
be absurd or ambiguous.
 In construing… statutes… the grammatical and ordinary sense of
the words is to be adhered to, unless that would lead to some
absurdity, or some repugnance or inconsistency with the rest of the
instrument, in which case the grammatical and ordinary sense of
the words may be modified, so as to avoid the absurdity and
inconsistency, but no farther

Adler v George (1964)
Under the Official Secrets Act 1920 it was an offence to
obstruct a member of the armed forces 'in the vicinity' of a
prohibited place.
 The defendant was actually in the prohibited place, rather than
"in the vicinity" of it, at the time of obstruction.
 The courts had to determine whether “in [the] vicinity of”
included on/in the premises. The court applied the golden rule.
 The court said that in the vicinity did include on or in as well. It
would be absurd for a person to be liable if they were near to a
prohibited place and not if they were actually in it. The
defendant’s conviction was therefore upheld.

Purposive Approach - Badshah Vs.Sou. Urmila
Badshah Godse and Anr. (SC 2013)
 while interpreting a statute the court may not only take into consideration the purpose for
which the statute was enacted, but also the mischief it seeks to suppress. It is this
mischief rule, first propounded in Heydon's Case (1854) 3 Co. which became the
historical source of purposive interpretation.
 where alternative constructions are possible the Court must give effect to that which will
be responsible for the smooth working of the system for which the statute has been
enacted rather than one which will put a road block in its way.
 If the choice is between two interpretations, the narrower of which would fail to achieve
the manifest purpose of the legislation should be avoided. We should avoid a
construction which would reduce the legislation to futility and should accept the bolder
construction based on the view that Parliament would legislate only for the purpose of
bringing about an effective result. If this interpretation is not accepted, it would amount
to giving a premium to the husband for defrauding the wife.

ejusdem generis - of the same kind, class, or
nature. where general words follow a list they are
interpreted in the context of the list (Specific)
expressio unius est exclusio alterius - the
expression of one excludes others
noscitur a socciis - known by the company it keeps

Illustrations
Notes
Long Title
INTERNAL AIDS TO
CONSTRUCTION
Punctuation
Preamble
Headings
Marginal Notes
Explanation
Proviso
Definition Section
Schedules
Transitional
Provisions

Foreign Decisions
Indian Judgments
Parliamentary History
EXTERNAL AIDS TO
CONSTRUCTION
Dictionaries
Historical facts
Reference to other statutes
Effect of usage and practice
General Clauses Act

WHY DO WE NEED SECURITIES LAWS ?
DOES THE LAW FOR INSIDER TRADING WORK IN REAL
LIFE SITUATIONS AND AGAINST EVERY REAL LIFE
WRONGDOING ?
WHY TAKEOVER CODE ?
WHY ICDR Regulations ?
WHY LODR Regulations ?

EQUITYVS LAW
a) It is well settled that when there is a conflict between law and
equity, it is the law which has to prevail, in accordance with the
Latin maxim 'dura lex sed lex', which means 'the law is hard, but
it is the law'.
b) P.M. Latha and Anr. v. State of Kerala and Ors. (SC-2003) :
Equity and law are twin brothers and law should be applied and
interpreted equitably, but equity cannot override written or settled
law....
c) Laxminarayan R. Bhattad and Ors. v. State of Maharashtra
and Anr. (SC-2003) : It is now well settled that when there is a
conflict between law and equity the former shall prevail....

REASONABLE MAN THEORY IN
CONTEXT OF SECURITIES LAWS
-What is it ?
-What do you feel, is it ?

REGULATOR’S THINKING
• HOW RELEVANT ?
• SEBI’S TOOLS = INTERPRETATIVE GUIDANCE/ EXEMPTIONS
/ FAQs/ CIRCULARS and So on………..
• Binding effect ?
• Combination of Equity and Law ?
• SEBI is a well respected “Respondent or Plaintiff” !
• SEBI’s actions are believed to be in the interest of shareholders and
securities market
• SEBI after SAHARA………..
• SEBI after SPICEJET……….

RUTHLESS
Strict enforcement of procedural and time bound compliances
Heavy penalties enforced against the non-compliant companies,
promoters etc.
The nature of offence vs Physical disabilities
SCORES
Action taken against Professionals for incorrect certificates/
reports.

FAQs comes with disclaimer !
These FAQs offer only a simplistic explanation/clarification of
terms/concepts related to the SEBI (Substantial Acquisition of
Shares and Takeovers) Regulations, 2011 [“SAST Regulations,
2011”]. Any such explanation/clarification that is provided
herein should not be regarded as an interpretation of law nor
be treated as a binding opinion/guidance from the Securities
and Exchange Board of India [“SEBI”]. For full particulars of laws
governing the substantial acquisition of shares and takeovers,
please refer to actual text of the Acts/Regulations/Circulars
appearing under the Legal Framework Section on the SEBI
website.

NO ACTION LETTER
OR
INTERPRETATITVE LETTER

SEBI may not respond to the following types of requests:
i. those which are general
and those which do not
completely and
sufficiently describe the
factual situation;
ii. those which involve
hypothetical situations;
iii. those requests in which
the requestor has no
direct or proximate
interest;
iv. where the applicable
legal provisions are not
cited;
v. where a no-action or
interpretive letter has
already been issued by
that or any other
Department on a
substantially similar
question involving
substantially similar
facts, as that to which
the request relates;
vi. those cases in which
investigation, enquiry or
other enforcement
action has already been
initiated;
vii. those cases where
connected issues are
pending before any
Tribunal or Court and on
issues which are sub
judice; and,
viii. those cases where
policy concerns require
that the Department
does not respond

SEBI’S Disclaimer
A no-action letter or an
interpretive letter issued by
a Department constitutes
the view of the Department
but will not be binding on
the Board, though the
Board may generally act in
accordance with such a
letter

No Sanctions attached !
The letter issued by a Department
under this scheme should not be
construed as a conclusive decision or
determination of any question of law
or fact by SEBI. Such a letter cannot
be construed as an order of the
Board under section 15T of the Act
and shall not be appealable.

No Action Letter
Where a no action letter is
issued by a Department
affirmatively, it means that
the Department will not
recommend enforcement
action to the Board, subject
to other provisions of this
scheme

Guidance Letter
The guidance offered through
the letters issued by
Departments is conditional
upon the requestor acting
strictly in accordance with the
facts and representations
made in the letter.

Fraud, Misrepresentation of Facts
Where the Department finds that a letter issued
by it under this scheme has been obtained by
the requestor by fraud or misrepresentation of
facts, notwithstanding any legal action that the
Department may take, it may declare such
letter to be non est and thereupon the case of
the requestor will be dealt with as if such letter
had never been issued. Where SEBI issues a
letter under this scheme, it may post the letter,
together with the incoming request, in the SEBI
website, subject to the provisions of para 11
(confidentiality request)

Corporate governance requirements with respect to
subsidiary of listed entity. 24(4)
(4) The management of the unlisted subsidiary shall periodically bring to
the notice of the board of directors of the listed entity, a statement of all
significant transactions and arrangements entered into by the unlisted
subsidiary.
Explanation.-For the purpose of this regulation, the term “significant transaction or arrangement” shall mean any individual
transaction or arrangement that exceeds or is likely to exceed ten percent of the total revenues or total expenses or total
assets or total liabilities, as the case may be, of the unlisted material subsidiary for the immediately preceding accounting
year.
What if the management of the unlisted subsidiary refuses to
share the details with the listed entity. Can it be said to be a
non-compliance by the listed entity ? Whether this would
depend on facts of the case or generic answer is possible ?

DIVIDEND - LODR
The listed entity shall declare and
disclose the dividend on per share basis
only.

Clause 20A of erstwhile listing agreement-
SEBI/CFD/DIL/LA/1/2009/24/04 April 24, 2009
Uniformity in dividend declaration – Insertion of clause 20A
It has been decided to mandate that listed companies shall
declare their dividend on per share basis only. This is expected
to bring uniformity in the manner of declaring dividend amongst
the listed companies.
20A:
“20AThe Issuer agrees to declare and disclose the dividend on per
share basis only.“

GENERALLY AVAILABLE INFORMATION
UNDER PIT REGULATIONS
Regulation 2(1)(e ) of SEBI PIT Regulations:
"generally available information" means information that is
accessible to the public on a non-discriminatory basis.
NOTE: It is intended to define what constitutes generally available
information so that it is easier to crystallize and appreciate what
unpublished price sensitive information is. Information published on
the website of a stock exchange, would ordinarily be considered
generally available.

What is a generally
available information ?
Is it a matter of fact or law ?

Non-discrimination
The words “non-discriminatory basis” represents equality.
As per Sodhi Committee Report whether some information
is available on a non-discriminatory basis would be a
question of fact to be answered adopting the standards of a
reasonable man.

GIFTVS SALE under Reg. 72(2) of ICDR
72(2) - The issuer shall not make preferential issue of specified
securities to any person who has sold any equity shares of the issuer
during the six months preceding the relevant date:
Provided that in respect of the preferential issue of equity shares and
compulsorily convertible debt instruments, whether fully or partly, the
Board may grant relaxation from the requirements of this sub-regulation,
if the Board has granted relaxation in terms of regulation 29A of the
Securities and Exchange Board of India (Substantial Acquisition of
Shares and Takeovers) Regulations, 1997 to such preferential allotment.
Explanation: Where any person belonging to promoter(s) or the
promoter group has sold his equity shares in the issuer during the six
months preceding the relevant date, the promoter(s) and promoter group
shall be ineligible for allotment of specified securities on preferential
basis.”

SEBI’s Department says
The said regulation and its explanation do not differentiate
between inter-se transfers made to entities within promoter group
and sales made to others. Hence, the term “any person who has
sold any equity shares of the issuer” shall also include any person
who has made inter-se transfers within the Promoter group.
Thus, as per the extant Regulations, if there is any inter-se
transfer among the promoter group entities in the preceeding six
months, then all the persons/entities forming part of “promoter(s)
and promoter group” shall become ineligible for allotment of
specified securities on preferential basis.

Of late, some instances of misuse of preferential allotment
route by promoters to enrich themselves at the cost of other
shareholders, have come to the notice of SEBI. Apparently,
promoters are taking advantage of bull run by offloading shares
at ruling market prices (which are much higher) and going in for
a preferential allotment at minimum price as per the formula
given in SEBI (DIP) guidelines (which are lower than current
market prices). As such, promoters are profiteering from the
bull run and are also in a position to maintain their stake
through preferential allotments made to themselves. To
address the above concerns, SEBI decided to review
the Preferential Allotment Guidelines on an urgent basis to
incorporate proper checks.

In this regard, SEBI convened a meeting of Primary Market
Advisory Committee on 01.12.2003.
The committee deliberated the issue and felt the need to
put certain safeguards in place to ensure that promoters do
not take advantage of the price difference merely, on
account of their position. The existing safeguard as per the
provision of the Companies Act 1956, of seeking
Shareholders’ consent is not full proof as promoters being
in majority, get the resolution passed in their favor very
easily.

In view of the above, the committee opined that there should be
a ban on sale of promoters’ stake for a certain time period prior
to and after any preferential allotment of shares, if promoters’
participate in the said allotment. Further, in order to ensure that
there is proper and effective monitoring of the same, it was also
suggested that promoters’ entire stake shall be in demat mode
so that the freeze on sale before and after the allotments can
be effectively ensured by Stock Exchanges.

The committee therefore recommended that the SEBI (DIP)
Guidelines regarding preferential allotment may be suitably modified
to incorporate the following, in addition to the lock-in requirement of
the existing clause 13.3.1:
a) In case, promoter(s) of a company sells his shares during last six
months from the relevant date (as defined in Explanation a of
Clause 13.1.1.1 of SEBI (DIP) Guidelines, 2000) , he will not be
eligible to acquire shares through preferential allotment.
b) In case, the company is making a preferential allotment of
shares to promoters, the entire shareholding of the promoter(s)
shall necessarily be in demat mode.
c) In case, shares are being issued to a promoter(s) of the
company through preferential allotment, then entire pre-
preferential issue shareholding of the promoter(s) shall be under
lock-in from the relevant date up to a period of six months from
the date of Preferential Allotment.

Sale
 Section 4 of Sale of Goods Act, 1930 deals with the contract of sale.
Sub-section (1) of Sale of Goods Act, 1930 states that ‘a contract of
sale of goods is a contract whereby the seller transfers or agrees to
transfer the property in goods to the buyer for a price.There may be a
contract of sale between one part-owner and another.’
 Further, section 4 of Sale of Goods Act, 1930 has been heavily used
to defend case for exemption for inter-se transfer of securities by
way of gift. However, it is a settled law that the Sale of Goods Act,
1930 is a general law and section 4 of the Sale of Goods Act, 1930
can not strictly be applied to interpret Regulation 72(2) of the SEBI
ICDR Regulations, 2009. It is also pertinent to note that the word
“sale” or “sold” has not been defined under the SEBI ICDR
Regulations.

• As per Black’s law dictionary, a contract of sale means a contract by
which one of the contracting parties, called the "seller," enters into
an obligation to the other to cause him to have freely, by a title of
proprietor, a thing, for the price of a certain sum of money, which the
other contracting party, called the "buyer," on his part obliges
himself to pay. Poth. Cont.; Civ. Code La. 1000, art. 21.10;White v.
Treat (C. C.) 100 Fed. 201; Sawmill Co. v. O'Shee, 111 La. 817, 35
South. 919.
• Benjamin’s Sale of Goods (2nd Edition) states that leaving aside
the battle of forms, sale is a transfer of property in the goods by
one, the seller, to the other, the buyer.

GIFT
At the same time, it is imperative to note meaning of the word “gift” which
is as under:
• As per Black’s law dictionary, gift means a voluntary conveyance of
land, or transfer of goods, from one person to another, made
gratuitously, and not upon any consideration of blood or money. A gift
is a transfer of personal property, made voluntarily and without
consideration. Civil Code Cal.
• Therefore, underlining similarity between sale and gift is that both
entail transfer of property/ownership.

Surjit Singh vs MahanagarTelephone
Nigam Ltd on 21 April, 2008 (SC)
 We may also consider the matter from the point of view of our
traditional principles of interpretation. The great Sanskrit
grammarian Nagesh Bhatt in his book ‘Param Laghu Manjusha’
has said that a word or phrase can have three meanings:
a) Abhidha i.e. literal meaning;
b) Lakshana i.e. the indicative or suggestive meaning;
c) Vyanjana i.e. the figurative meaning.
 Lakshana or implication assumes two forms
a) Suddha or Pure,
b) Gauni or subordinate.

 Suddha or Pure, implication again assumes two forms
a) Upadana Lakshana and
b) Gauni Lakshana.
 Upidana Lakshani is that in which the literal or principal
meaning is not set aside or thwarted but retained along with the
meaning projected which helps clearing the principal meaning
left uncleared i.e. Helmets entered the house. In this case
helmets means persons wearing helmets.
http://shodhganga.inflibnet.ac.in/bitstream/10603/36739/6/06_ch
apter3.pdf

 The cases where though two objects are different, they have
similarity in some respects due to which the characteristics of
one are transferred on the other e.g. this boy is a lion. This
means the boy is so brave as can be entitled with the
characteristics of a lion. Such cases fall within the field of Gauni
Lakshana or subordinate implication and not pure
implication.

Section 56 of the Companies Act, 2013
In Section 56 of the Companies Act, 2013, there is no condition
that the transfer of securities shall be pursuant to contract of sale.
In other words, in view of Section 56 of the Companies Act, 2013,
transfer of securities could also be as a result of gift.

Lock in –3 years for Promoter and Group
78(1) Lock-in of specified securities.
The specified securities allotted on preferential basis to promoter or
promoter group and the equity shares allotted pursuant to exercise of
options attached to warrants issued on preferential basis to promoter or
promoter group, shall be locked-in for a period of three years from the
date of allotment of the specified securities or equity shares allotted
pursuant to exercise of the option attached to warrant, as the case may be:
Provided that not more than twenty per cent. of the total capital of the issuer
shall be locked-in for three years from the date of allotment: Provided further
that equity shares allotted in excess of the twenty per cent. shall be locked-in
for one year from the date of their allotment pursuant to exercise of options
or otherwise, as the case may be.

Reg. 79 - Transferability of locked-in specified
securities and warrants issued on preferential
basis.
Subject to the provisions of Securities and Exchange Board of India
(Substantial Acquisition of shares andTakeovers) Regulations, 1997,
specified securities held by promoters and locked-in in terms of sub-
regulation (1) of regulation 78 may be transferred among promoters
or promoter group or to a new promoter or persons in control of the
issuer: Provided that lock-in on such specified securities shall
continue for the remaining period with the transferee.

•Whether sale includes gift – by plain reading of
72(2)
•78(1) read with 79
•Sale vs sold
•SEBI Committee Report, purpose, object.
•Market practices and hygiene, loophole,
factual scenario.

SEBI INFORMAL GUIDANCE IN
THE MATTER OF HDFC BANK
DISCRETIONARY PORTFOLIO MANAGEMENT
IS SUBJECT TO COMPLIANCE OF INSIDER
TRADING REGULATIONS.

NON-DISCRETIONARY PORTFOLIO
MANAGEMENT SERVICES
“Non-Discretionary Portfolio Management Services” or
“Services” means the portfolio management services rendered
to the Client by the Portfolio Manager on the terms and
conditions contained in this Agreement, where the Portfolio
Manager invests in a Portfolio of Securities for and on behalf of
the Client with the consent of the Client.

Discretionary Portfolio Manager
“discretionary portfolio manager” means a portfolio manager
who exercises or may, under a contract relating to portfolio
management, exercise any degree of discretion as to the
investments or management of the portfolio of securities or the
funds of the client, as the case may be.

SPICEJET – A CASE STUDY ?
http://corporates.bseindia.com/xml-
data/corpfiling/AttachHis/Spicejet_Ltd_020315_SAST.pdf
under any law or regulation

Defence
• the Acquirer relied upon the letter issued by the Civil Aviation Ministry
(Ministry) and stated that it is a ‘CompetentAuthority’ however, no copy
of the letter was served on its website nor was it made public by the said
ministry or Acquirer or otherwise.
• In the meantime,CCI vide its letter dated February 19, 2015 approved the
combination and acquisition of entire shareholding of Mr. Kalanithi Maran
by the said Acquirer.
• in the specific column pertaining to price at which the shares were
proposed to be bought, the Acquirer stated that “in terms of the Share Sale
and Purchase Agreement dated January 29, 2015 betweenTarget Company,
Sellers and Acquirer for acquisition of these shares is confidential”.

Amazing !
Firstly, claiming it to be exempted under
Regulation 10(1)(d)(iii) by stating that the
Ministry is a competent authority and
secondly, not quoting the consideration for
acquisition of shares, made it a classical case
for discussion.

Perplexed !
‘Competent authority’ as used in regulation 10 has not
been defined in the Takeover Code and therefore, it is
open to several interpretations.
However, it is to be borne in mind that the competent
authority is supposed to pass an order and not give its
approval merely by issuing a letter.
It seems that the acquirer used the concept of
‘Competent Authority’ purely in order to meet the letter
of law but not the spirit.
However, that seems to be not meeting the letter of law
as well.

ROLE PLAY
Without even going into the issue of whether order was passed
or not and whether letter issued by the Ministry can be said to
be an order or whether the signing authority believed that it was
a ‘Competent Authority’ in context of Regulation 10 or not or the
Acquirer used these golden words to safeguard its interest,
even if one looks at the provisions of the Aircrafts Act, 1934 or
Aircrafts Rules, 1937, it could be noticed that none of those
provisions contains anything as such which gives such wide
powers to the Ministry or its officers to approve a scheme of
reconstruction and revival acting as a competent authority.

Is Competent Authority Defined ?
 As regard Civil aviation sector, one can find definition of
Competent Authority in regulations like Airport authority of India
(General Conditions of Service and Remuneration of Employees)
Regulations, 2003, Airport Authority of India (Management of
Airports) Regulations, 2003 etc..
 For instance, in Airport Authority of India (Management of Airports)
Regulations, 2003, 'Competent Authority' is defined in Regulation
3(8) which reads as under:
 'Competent Authority' means in relation to exercise of any power
of the Authority, the Chairperson, and any member authorized by
the Chairperson, Airport Director or Controller of Aerodrome or
incharge of any Airport or civil enclave or any other officer
specified by the Chairperson in that behalf.

Black’s law dictionary states that ‘Competent
Authority’ as applied to courts and public officers,
imports jurisdiction and due legal authority to deal
with the particular matter in question. Mitchel v. U.
S., 9 Pet. 735, 9 L.Ed. 283; Charles v. Charles, 41
Minn. 201, 42 N.W. 935.

In this case, such powers have been too
purposively used, by the Civil Aviation Ministry ( or
at least, too purposively used by the Acquirer to
defend its case and say that the said letter issued
by the Ministry is a order of competent authority).
This could be a classic case of colourable exercise
of power.

Price Angle !
• As regard the price for shares purchased by the acquirer, finally,
on September 02, 2016, the Acquirer filed a revised disclosure
under Regulation 10(6) stipulating that “Re. 1 (Rupee One Only)
for entire shares, paid to each transferor”. That means, the
acquirer purchased almost 58.46% shares/control over the Target
Company by paying merely Re. 2 as a total consideration. It is not
clear as to whether the revised filing was made at the request of
the stock exchange/SEBI or by its own. In fact, whether any action
was taken or notice was served by Stock Exchange/SEBI, is also
not known as yet.
• http://corporates.bseindia.com/xml-
data/corpfiling/AttachHis/32283172_69D6_4097_B3DE_24FE988E
6CAC_175813.pdf

In essence, not quoting price paid for such shares was
not a case of typo error or error of judgment. The series
of events which unfolded over a period of time lead to
the conclusion that it may have been a well thought out
strategic decision.

To conclude, we may note that no voice of concern was or
has been raised by the shareholders of the Company, this
is in itself, is very surprising.
However, if one looks at the steps taken by the new
management post acquisition and financial statement of the
Target Company for the financial year ended March 31,
2016, it seems that the Target Company is doing well under
the new promoter and is surely, hoping to survive, compete
and bring more value on table, in long term.
All said and done, Stock exchange, SEBI and concerned
Ministry has a lot to answer.
Well done Acquirer!

Interpretation of Securities Laws

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