WTM/RKA/NRO/CIS/135/2014

BEFORE THE SECURITIES AND EXCHANGE BOARD OF INDIA

ORDER
Under sections 11 and 11B of the Securities and Exchange Board of India Act, 1992 read
with regulations 65 of the Securities and Exchange Board of India (Collective Investment
Schemes) Regulations, 1999 in the matter of Sheen Agro & Plantations Ltd.
In respect of (1) Sheen Agro & Plantations Ltd. and its directors, namely (2) Mr. Ajeet
Lal Sharma), (3) Mr. Angrez Singh Bhadwal, (4) Mr. Surinder Kr. Trilokia, (5) Mr. Nasib
Singh Pawar, (6) Mr. R. S. Bhau, (7) Mr. Brita Singh Bhau, (8) Mr. Kamal Singh Bhau,
(9) Mr. Yograj Singh Bhau, (10) Mr. Tej Pal Singh, (11) Mr. Shyam Lal Pahwa, (12) Mr.
Sohan Singh, (13) Ms. Renu Bala, (14) Mr. Pawan Kumar Khajuria, (15) Ms. Anita
Sharma, (16) Mr. Kirpal Singh, (17) Mr. Sudershan Singh Jamwal and (18) Mr. Gurpreet
Singh (hereinafter collectively referred to as "the noticees" or by their respective names).

1. Sheen Agro & Plantations Ltd (hereinafter referred to as 'Sheen Agro' or 'the Company'), on
October 16, 2003 had filed a Winding up and Repayment Report (WRR) under the
provisions of the SEBI (Collective Investment Schemes) Regulations, 1999 (hereinafter
referred to as 'CIS Regulations'). As per the WRR, on May 01, 2003, out of 3,076 investors to
whom the Information Memorandum was circulated by the Company, 2,958 investors had
given positive consent to continue with the schemes and the remaining 118 investors were
refunded the amount mobilized from them. It was observed from the WRR that against an
amount of 2.34 crores mobilized from 3,076 investors, an amount of 22.42 lakhs was
repaid to 118 investors.
2. Securities and Exchange Board of India (hereinafter referred to as "SEBI") received several
complaints in 2006 alleging that Sheen Agro has not repaid the amount due to its investors
on maturity of their investments made in the scheme/s of the Company, during the period
2002-2004. Further, letters were also sent to the investors seeking additional information. It
was observed that in year 2004, Sheen Agro had accepted investments from the public even
after furnishing WRR report to SEBI.
3. During the period 2008-10, SEBI had sent many letters and reminders to Sheen Agro
inquiring about the status of repayment and redressal of investor complaints. As the
Company failed to submit the information sought by SEBI despite repeated extension of
time, a Show Cause Notice dated February 24, 2010 (SCN) under section 11B of the SEBI
Act, 1992 read with regulation 65 of the CIS Regulations was issued to the noticees.
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4. Mr. Nasib Singh Pawar, Mr. Surinder Kumar Trilokia and Mr. Angrez Singh Bhadwal, who
were directors of the Company, vide their letter dated March 12, 2010 replied to the SCN
and inter alia made submissions that:
i. In May 2004, the then directors of the Company were asked by its promoters, viz., Mr.
Brita Singh Bhau and his family members, to resign from the Company.
ii. Therefore, the then directors signed a Memorandum of Understanding on May 15, 2004
and ceased to be directors of Sheen Agro with effect from May 29, 2004.
5. Mr. Brita Singh Bhau, Mr. R. S. Bhau and Mr. Yograj Singh Bhau vide their letters dated
March 13, 2010 replying to the SCN issued to them submitted that they had resigned from
the post of director of Sheen Agro with effect from September 22, 1998, June 16, 1998, and
November 26, 2005, respectively, and have no affairs with the Company from the date of
their respective resignations. Further, Mr. Baldev Singh Bhau informed that his father, Mr.
Brita Singh Bhau ceased to be director of the Company from June 23, 1998 and had passed
away in December 2000. However, Mr. Baldev Singh Bhau has failed to submit any
documentary proof in support of this.
6. In response to the SCN, the Company replied vide letter dated March 15, 2010 and made
submissions as under:
i. The Company has started redressing the complaints and has deposited a sum of 3 lakhs
with the appropriate authority as directed by the Court.
ii. Company is in the process of repaying its other depositors and has paid a sum of 50
lakhs during 2009.
7. Opportunities of personal hearing were given to the noticees on July 31, 2010, September 03,
2010, February 15, 2011 and November 23, 2012. It was observed that the hearing notices
issued to some of the noticees returned undelivered. Accordingly, a public notice to this
effect that SCN was issued to the noticees and personal hearings were scheduled, was
published in newspapers.
8. Mr. Nasib Singh Pawar, Mr. Angrez Singh and Mr. Sureinder Kr Trilokia appeared for
personal hearing on July 31, 2010 and informed that they were directors of the Company till
May 2004 and subsequently, the promoters of the Company had taken over the functioning
of the Company.
9. SEBI received a letter dated August 12, 2010 from Mr. Sohan Singh, who informed that he
has left the services of the Company on April 24, 2000.
10. Vide letter dated September 01, 2010, the Company made further submissions as under:
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i. The following three persons are directors in the Company viz., Mr. Ajeet Lal Sharma,
Mr. Yog Raj Singh Bhau and Mr. Sham Lal Pahwa. Mr. Ajeet lal Sharma was appointed
as director on March 19, 2005. Mr. Sham Lal Pahwa was first appointed as director on
May 29, 2004.
ii. Mr. Yograj Singh Bhau is the director who represents promoters of the Company and
took over from the old directors of the Company on May 29, 2004. However, Mr.
Yograj Singh is not co-operating and evading SEBI proceedings.
iii. Company has not mobilized fresh funds after filing the WRR. However, with the
concurrence of the members, some of the accounts were renewed due to financial
strains on the Company.
iv. The Company is in the process of redressing complaints of all such investors. Out of the
ten complaints forwarded by SEBI, the Company has redressed eight complaints and
made part payment to the ninth complainant. The Company is pursuing the tenth
complainant for out of court settlement.
11. During the course of hearing on September 03, 2010, the Companys directors (who were
present for the hearing) were directed to submit a tentative schedule of repayments to the
investors of the Company and a bi-monthly status report of repayments made by the
Company to its investors.
12. Vide letter dated September 06, 2010, the Managing director of the Company, Mr. Ajeet Lal
Sharma, submitted the following:
i. Repayments of 50 lakhs were made during FY 2008-2009;
ii. Repayments of 42 lakhs were made during FY 2009-2010;
iii. Repayments of 14 lakhs were made during 1st Quarter of FY2010-2011;
iv. Tentative outstanding liability to the investors as on June 30, 2010 was 432 lakhs;
v. The Company undertook to wind up the complete scheme and make payments to all the
investors in the time stipulated by SEBI.
13. Vide letter dated September 11, 2010, the Company submitted that the tentative outstanding
liability of 432 lakhs and the interest accrued on this liability would be repaid from the fixed
assets, i.e., lands and from recovering loans and advance from the debtors. The Company
has submitted that it is having fixed assets worth 120 lakhs and loans and advances worth
530 lakhs. It was also informed that the directors of the Company are going to put equity in
the Company.
14. Vide letter dated October 09, 2010 and letter dated December 08, 2010, the Company made
submissions with respect to the repayment plan as under:
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i.

ii.

Half yearly tentative repayment plan:

Particulars

Amount (in lakh)

Total outstanding liability to the investors as on June 30, 2010

Amount repaid during October to November 30, 2010

432
23

Balance as on March 31, 2011

Interest accrued upto March 31, 2011
Total Liabilities as on March 31, 2011

347
128
575

Source of Funds
Particulars
Recoveries
Loans

Upto
Upto
Sep 30, 2011 Mar 31, 2012
from

Sale of Fixed Assets

Fresh induction of
capital by director
Total
Application of Funds
Particulars
Recurring
Operational
Expenses

Upto
Sep 30, 2012

Upto
Mar 31, 2013

80

90

100

150

60

50

10

40

40

50

35

180

180

160

185

Upto
Upto
Sep 30, 2011 Mar 31, 2012

Upto
Sep 30, 2012

Upto
Mar 31, 2013

and

Repayment
to
Depositors
Payment of Interest
Total

15

15

15

15

140

145

130

160

25

20

15

10

180

180

160

185

Balance Liabilities
As on Sep 30, 2011

As on March As on Sep 30, As on March 31, 2013

31, 2012
2012
435
290
180
Nil

iii.

As regards cooperation of main promoter-director vis--vis requisite authority to

manage the affairs of the Company, it was confirmed that the management had the
requisite authority to manage the affairs since they were in majority.

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iv.

Though the promoter Mr. Brita Singh Bhau had resigned from the post of director of
the Company, he was controlling the affairs of the Company through his proxy
director Mr. Yograj Singh, who is his son. Vide Memorandum of Understanding
(MoU) entered into between the present management and erstwhile management, Mr.
Brita Singh Bhau took control of the Company through Mr. Yograj Singh. Mr. Brita
Singh Bhau has signed the MoU as identifier of Mr. Yograj Singh.

15. It was noted that the Company had submitted only part information and had not submitted
information pertaining to investors whose original investments were renewed and details of
repayments to be made to investors whose original investments were not renewed as on
September 30, 2011. Meanwhile, SEBI received another complaint dated November 27, 2010
from persons who deposited money in the Reasi Branch of Sheen Agro at the time when Mr.
Nasib Singh Jamwal was the Branch manager. It was alleged in the complaint that Mr. Nasib
Singh Jamwal had assured them that their money would be paid back at the time of maturity,
but Mr. Nasib Singh was absconding for the past six months. The complaint was forwarded
to the Company vide letter dated December 08, 2010 and the Company was advised to
redress the grievance of the investors.
16. Mr. Ajeet Lal Sharma, Mr. Nasib Singh Pawar and Mr. Angrez Singh Bhadwal had appeared
for personal hearing in the matter on February 15, 2011 and the Company and its directors
were advised to submit a comprehensive list of investors along with the dues (principal and
interest) payable to them by April 30, 2011. Further, it was informed by SEBI that the
submissions of the Company regarding payment to investors would be audited by
independent auditors.
17. The Company informed that it has repaid an amount of 28 lakhs during December 01, 2010
to January 31, 2011. In this way, the Company had made a total payment of 51 lakhs during
October 2010 to January 2011. The Company also made the following submissions:
i.
Amount of renewed deposits due for repayment upto Sep 30, 2010 shall be repaid upto
Sep 30, 2011.
ii.
Amount of renewed deposits due for repayment after Sep 30, 2010 shall be repaid upto
March 2012.
iii. The amount due for repayment upto Sep 30, 2010 and has not been renewed is being
paid along with renewed deposits and that whose deposit has matured first shall be
repaid first.
Particulars
Total amount of liability as on September 30, 2010
Interest Accrued

Amount (in lakh)

407.00
228.00

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Total
Amount of renewal deposit, due for repayment upto Sep 30,
2010
Amount of renewed deposit, due for repayment after Sep 30,
2010
Amount of deposit not renewed, but due for repayment upto
Sep 30, 2010

635.00
112.00
86.78
114.36

18. Further, the Company vide letter dated April 12, 2011 informed that it needs more time to
prepare details about the complete list of investors and sought for extension of time of 15
days.
19. Meanwhile, SEBI received two complaints dated May 09, 2011 wherein the complainants
have stated that Sheen Agro has failed to repay the amounts due against certain investments
made by the complainant. The complaint was forwarded to the Company, but returned
undelivered.
20. Vide letter dated May 14, 2011, the Company submitted part information about the list of its
investors and sought further time to submit complete information. Subsequently, vide letter
dated June 09, 2011 the Company submitted copy of Application form, brochure and
receipt. SEBI vide letter dated August 26, 2011 forwarded the various complaints received by
SEBI and advised the Company to redress the same and also submit the information sought
by SEBI. In response, the Company sought further time vide letters dated September 05,
2011 and vide letter dated September 19, 2011 submitted part information about list of
depositors. Further, the Company also informed that some of the deposit ledgers have been
retained by CBI in connection with complaints of depositors and hence complete
information could not be submitted. Even after a substantial lapse of time, the Company did
not submit the complete information sought by SEBI.
21. Since the instant proceedings had commenced and continued before the then Whole Time
Member who demitted office, in observance of principles of natural justice further
opportunity was provided to the noticees before me. However, the hearing notices issued to
some of the noticees were returned undelivered. Mr. Pawan Kumar Khajuria, Mr. Tejpal
Singh, Mr. Kamal Singh, Mr. Sudershan Singh, Mr. Surinder Kr. Trilokia, and Mr. Ajeeet Lal
Sharma had appeared before me on November 23, 2012 and made oral submissions.
22. Mr. Kamal Singh made submissions as under:
i.
He was a peon in the Company, and did not know to read and write.

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ii.
iii.
iv.

He was asked to sign on some documents by Mr. Brita Singh Bhau, and was not aware
that he was made director of the Company until he was asked to resign in May 2004.
He has not attended any meetings of the Company as a director.
He has not collected any money from the public.

23. Mr. Tejpal Singh submitted that he and his father Mr. Sudershan Singh Jamwal were asked to
sign some documents by Mr. A. S. Bhadwal, who is their relative. Further, they also made
deposits of around 30-40 lakhs in the Company. However, when they approached Mr. Brita
Singh Bhau or Mr. A. S. Bhadwal for their money, they were assured that the money will be
refunded later. Only when they were asked to resign from the Company did they realize that
they were directors of the Company.
24. Mr. Ajeet Lal Sharma made the following submissions:
i.
He worked as a Manager in the Company from 1996 to 2005. As a Manager, he used to
collect Deposits from the public, and the money was deposited in the Head Office.
ii.
On March 19, 2005 he was made director, and subsequently Managing Director of the
Company.
iii. From 2004 to 2008, no fresh deposits were collected, but only old deposits were
renewed. Further, after 2008, no deposits were renewed.
iv.
v.

During January 2011, Company has repaid 51 lakhs, and subsequently, upto
September 2012, Company has repaid upto 36.74 lakhs.
The Hon'ble Jammu and Kashmir High Court stayed the disposal of the properties of
the Company. When the stay by the Hon'ble High Court would be vacated, repayments
would be made as per the earlier schedule submitted to SEBI.

25. Mr. Surinder Kr. Trilokia submitted that he was made the director of the Company in 1999
and upto May 29, 2004. However, he has informed that during that period the money that
was collected from public were handled by Mr. Brita Singh Bhau, Mr. A. S. Bhadwal and Mr.
Nasib Singh.
26. Further, on November 20, 2012 Mr. Naseeb Singh visited SEBI New Delhi office, marked
his attendance in the visitor register but did not appear for the scheduled hearing. Therefore,
further opportunities were granted to Mr. Naseeb Singh on January 30, 2014, February 14,
2014 and March 04, 2014. However, Mr. Naseeb Singh did not avail the opportunities
provided to him. Considering the facts and circumstances that the noticees have been
provided with sufficient opportunities in this case, I deem it appropriate to proceed in this
matter. I have considered the oral and written submissions of Sheen Agro and its past and
present directors, the documents furnished by Sheen Agro, material received from RoC,
Jammu and Kashmir and the material available on record.
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27. In this case, admittedly, the scheme of the Company was a 'collective investment scheme'. It is for
this reason that the WRR in this case was filed by it under regulation 73 of the CIS
Regulations, which reads as under:73(1) An existing collective investment scheme which:
(a) has failed to make an application for registration to the Board; or
(b) has not been granted provisional registration by the Board; or
(c) having obtained provisional registration fails to comply with the provisions of regulation 71;shall wind
up the existing [collective investment scheme.
(2) The existing Collective Investment Scheme to be wound up under sub-regulation (1) shall send an
information memorandum to the investors who have subscribed to the [collective investment scheme]s,
within two months from the date of receipt of intimation from the Board, detailing the state of affairs of
the [collective investment scheme], the amount repayable to each investor and the manner in which such
amount is determined.
(3) The information memorandum referred to in sub-regulation (2) shall be dated and signed by all the
directors of the [collective investment scheme].
(4) The Board may specify such other disclosures to be made in the information memorandum, as it
deems fit.
(5) The information memorandum shall be sent to the investors within one week from the date of the
information memorandum.
(6) The information memorandum shall explicitly state that investors desirous of continuing with the
[collective investment scheme] shall have to give a positive consent within one month from the date of the
information memorandum to continue with the [collective investment scheme].
(7) The investors who give positive consent under sub-regulation (6), shall continue with the [collective
investment scheme] at their risk and responsibility:
Provided that if the positive consent to continue with the [collective investment scheme], is received
from only twenty-five per cent or less of the total number of existing investors, the [collective investment
scheme] shall be wound up.
(8) The payment to the investors, shall be made within three months of the date of the information
memorandum.
(9) On completion of the winding up, the existing collective investment scheme shall file with the Board
such reports, as may be specified by the Board
28. I note that the purpose of regulation 73 of the CIS Regulations which gave an option to the
investors of the existing CIS entities to continue with the schemes was only to enable a
gradual phasing out of operations of the unregistered CIS entity, without harming the
interest of investors. It is noted that pursuant to receiving the minimum stipulated positive
consent from investors to continue with its existing CIS, the Company had filed an
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application seeking registration with SEBI which was subsequently rejected by SEBI on
February 28, 2003. After such rejection the Company filed the WRR in October 2003.
29. In this context, the issue for determination in the instant matter is whether the mobilization
of fresh funds by the Company after submitting the WRR to SEBI constitutes a violation of
CIS Regulations and SEBI Act. It is evident from the submission of the Company that on
maturity of investments contributed by investors from whom positive consent had been
obtained, the Company renewed some of the investments for an additional term. In this
regard, it is relevant to mention that regulation 73 of the CIS Regulations is not meant to
enable an unregistered CIS entity to perpetuate its operations even after the expiry of the
original term for which investments had been accepted from the consenting investors. In my
view, since the application of Company seeking registration as 'collective investment scheme' was
rejected by SEBI it could not continue such activity. In this regard, reference may be drawn
to section 12 (1B) of the SEBI Act, 1992 in terms of which no person shall sponsor or cause to be
sponsored or carry on or cause to be carried on Collective Investment Scheme including mutual funds unless he
obtains a certificate of registration from the Board in accordance with the Regulations. Further, in terms
of regulation 3 of the CIS Regulations, no person other than a Collective Investment Management
Company which has obtained a certificate under the Regulations shall carry on or sponsor or launch a
collective investment scheme. Hence, renewal of investments post submission of the WRR and
after the expiry of the original term of such investments, and mobilization of fresh funds by
Sheen Agro after submission of WRR is in violation of the provisions of the CIS Regulations
and the SEBI Act.
30. According to the Company, as on March 31, 2011 its total liability for refund to investors
was 575 lakhs out of which it had paid only 51 lakhs. From the Balance Sheet of the
Company for the year ending March 31, 2003, (the latest financial statements have not been
submitted by the Company) it is observed that the Company had given loan to members and
others to the tune of 2 crore. From the Annexure to the Audit Report of the Accounts of
the Company, it is noted that most of the borrowers have defaulted in repaying the principal
and interest to the Company. However, the Company has not taken any steps to recover the
money. The Company has pleaded its inability citing reason that its land assets are under stay
order by the Hon'ble High Court of Jammu & Kashmir. Be whatever it may, the Company
has defaulted in repaying to the investors despite repeated assurances given by it and
substantial portion of investments are outstanding for refund to the investors.
.
31. In view of the above, I find that the Company has been engaged in mobilizing contributions

from public in the nature of 'collective investment scheme' without obtaining certificate of
registration from SEBI and , it has thus contravened provisions of section 12(1B) of the
SEBI Act and regulation 3 of the CIS Regulations. I further note that the activities of the
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noticees were not only in contravention of the provisions of the SEBI Act and CIS
Regulations for which the noticees are liable for appropriate action as contemplated in the
SCN; they were harmful and detrimental to the interest of the investors since the Company
has failed to refund/repay to them.
32. I note that Mr. Brita Singh Bhau has submitted that he resigned from the Company in 1998
and had no dealings with the Company. However, from the MoU signed between the
erstwhile directors of the Company and the promoters it is observed that Mr. Brita Singh
Bhau has signed as the identifier of Mr. Yograj Singh Bhau as the director of the Company.
Further, from the depositions of Mr. Surinder Kr. Trilokia, Mr. Tejpal Singh and Mr. Kamal
Singh made before me on November 23, 2012, I note that Mr. Brita Singh Bhau played a
significant role in managing the affairs of the Company even after 1998. Though Mr. Baldev
Singh Bhau has informed that his father, Mr. Brita Singh Bhau had passed away in December
2000, he has failed to submit any documentary evidence to corroborate this submission. I,
therefore, do not find reason to drop the proceedings against Mr. Brita Singh Bhau at this
stage.
33. Mr. R. S. Bhau and Mr. Yograj Singh also submitted that they resigned from the Company,
and are not associated with the Company in any manner. However, being the promoters and
also directors of the Company, their role in the affairs of the Company cannot be negated.
34. I note that Mr. Angrez Singh Bhadwal, Mr. Nasib Singh Pawar, Mr. Suriender Kr. Trilokia,
Mr. Tejpal Singh, Mr. Kamal Singh and Mr. Sudershan Singh Jamwal have submitted that
they ceased to be directors with effect from May 29, 2004. They have also submitted copies
of Form 32 in support of their claims. I note that during the tenure of the aforesaid noticees
as director of the Company, it renewed the investments which were due for maturity.
35. Mr. Kamal Singh, Mr. Tejpal Singh and Mr. Sudershan Singh Jamwal have further submitted
that they were appointed directors of Sheen Agro without their consent by deceptively taking
their signatures on several documents. I note that Mr. Kamal Singh, Mr. Tejpal Singh and
Mr. Sudershan Singh Jamwal were directors of the Company for nearly four to five years.
Also, none of them took any legal action against Sheen Agro for alleged illegal use of their
identity card and documents even when they became aware that they were made directors of
the Company without their consent.
36. I note that despite significant lapse of time, and numerous opportunities having been granted
to Sheen Agro it has failed to furnish information sought by SEBI and has also failed to
redress the grievance of the investors.

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37. Considering the facts and circumstances of the case, I, in exercise of the powers conferred
upon me by virtue of section 19 of the Securities and Exchange Board of India Act, 1992
hereby issue following directions under section 11 and 11B of the said Act read with
regulations 65 and 73 of Securities and Exchange Board of India (Collective Investment
Schemes) Regulations, 1999:i.

Sheen Agro and Plantations Ltd. and its present promoters/directors, namely, Mr.
Ajeet Lal Sharma, Mr. Brita Singh Bhau, Mr. R. S. Bhau, Mr. Yograj Singh Bhau, Mr.
Shyam Lal Pahwa, Ms. Renu Bala, Mr. Pawan Kumar Khajuria, Ms. Anita Sharma, Mr.
Kirpal Singh, and Mr. Gurpreet Singh to wind up its scheme and refund the money
collected by it under the scheme with returns which are due to the investors as per the
terms of offer within a period of three months from the date of this order and submit a
winding up and repayment report to SEBI in accordance with the SEBI (Collective
Investment Schemes) Regulations, 1999, including trail of funds claimed to be
refunded, bank account statements indicating refund to the investors and receipt from
the investors acknowledging such refund, failing which the following actions shall
follow:
(a) A reference would be made to the State Government/ local police to register a
civil/ criminal case against them for apparent offences of fraud, cheating, criminal
breach of trust and misappropriation of public funds, and
(b) Making a reference to the Ministry of Corporate Affairs, to initiate the process of
winding up of Sheen Agro & Plantations Ltd.
(c) SEBI shall also initiate attachment and recovery proceedings under section 28A of
the SEBI Act.

ii.

Sheen Agro & Plantations Ltd. and following persons who are/were
directors/prompters/managers/persons responsible for its actions at the relevant time
are directed to not to access the securities market and are further restrained and
prohibited from buying, selling or otherwise dealing in the securities market till all
collective investment schemes launched by Sheen Agro & Plantations Ltd. are wound
up and all the monies mobilised through it are refunded to the investors.
Sl. No.
1
2
3
4
5
6

Name
Mr. Angrez Singh Bhadwal
Mr. Surinder Kumar Trilokia
Mr. Naseeb Singh Pawar
Mr. Kamal Singh Bhau
Mr. Sham Lal Pahwa
Mr. Sudershan Singh Jamwal

PAN
ACBPB5282C
ACXPT9782D
APOPS9255C
BJKPS4811H
APQPP5268L
AAPPJ8220N

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Sl. No.
7
8
9
10
11
12
13
14
15
16
17

Name
Mr. R. S. Bhau
Mr. Brita Singh Bhau
Mr. Ajeet Lal Sharma
Mr. Sohan Singh
Ms. Renu Bala
Mr. Pawan Kumar Khajuria
Ms. Anita Sharma
Mr. Kirpal Singh
Mr. Yograj Singh Bhau
Mr. Tej Pal Singh
Mr. Gurpreet Singh

PAN
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available

38. Without prejudice to the above, SEBI would examine the feasibility of initiation of
prosecution proceedings under section 24 and adjudication proceedings under Chapter VI of
the SEBI Act against them.
39. The above directions shall come into force with immediate effect. Copy of this Order shall
be forwarded to the stock exchanges and depositories for necessary action.

Date: November 14th , 2014

Place: Mumbai

RAJEEV KUMAR AGARWAL

WHOLE TIME MEMBER
SECURITIES AND EXCHANGE BOARD OF INDIA

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