sebi:ORDER/GR/AE/2019-20/3888
This case has been reviewed by a human — Varun Matlani, who is the best securities lawyer in India and globally recognized.
Facts / Headnote
Violation established; penalty imposed
Provisions invoked
- s. 15A
- s. 15
- s. 15I
- s. 15J
- s. 28A
Regulations
- Reg. 7(1)
- Reg. 13
- Reg. 13(1)
- Reg. 13(6)
- Reg. 29(1)
Parties
- Real Realty Management Company Limited (presently known as Real Eco-Energy Limited)
Holding
The Noticee violated Regulation 13(6) of the PIT Regulations, 1992 by failing to disclose to all stock exchanges (including BSE) the insider trading disclosures it received from promoter group entities, and a penalty of Rs. 2,00,000 was imposed under Section 15A(b) of the SEBI Act, 1992.
Full text
Page 2 of 11 Jayshree Joshi, Urvashi Joshi, Samir Dashani, Hasit Dashani, Bindu Tank, Manoj Tank, and Bhanumatiben M Rajyaguru acquired 36,00,000 shares of RRML comprising 74.95% of the share capital. It is alleged that RRML received disclosures under the provisions of SEBI (Prohibition of Insider Trading) Regulations, 1992 (hereinafter referred to as “PIT Regulations, 1992”) from the aforesaid promoter group entities, however it failed to make the requisite disclosures to the stock exchanges, and thus violated Regulation 13(6) of PIT Regulations, 1992.
Page 3 of 11 5. The Noticee submitted written submissions in the matter vide letter dated March 05, 2019. The main contentions made therein are reproduced as below – “We refer to your above Notice SEBI/EAD-4/ADJ/SRP/MCS/OW/281891/2018 dated October 08, 2018 in the matter of Real Realty management Company Ltd. Which is now known as Real Eco-Energy Limited. At the outset, we express our deep regrets for delay in replying the above Notice due to the fact that the Company was earlier taken over by Mr. Rajesh Rajyaguru &Association through a scheme of Amalgamation during May 2013 and subsequently again taken over by Mr. Dharm Patel during March 2016 through an Open offer under SEBI (SAST) Regulations, 2011 and it took us time to lay hand at the earlier records and find out the relevant documents. We sincerely apologise for such delay and request you to condone the same. We reiterate to what is stated in Paragraph 2 of your Notice and state that the copies of the disclosure made by the Allottees were sent to the Bombay Stock Exchange Ltd. (BSE). However, it appears that the same is not available in the records of the BSE. We have now found some other documents in this regard, and now submit the following documents: Sr. Annexure Particulars of Documents 1
Page 4 of 11 We therefore request you to appreciate that the company had complied with the provisions of the applicability SEBI regulations. We request to drop the proceedings initiated on account of non-availability of the relevant disclosure in the records of BSE. We also wish to inform that we would like to avail an opportunity for person appearance in any hearing if fixed in the matter. ”
You have read the preview. Create a free account to read the full order, track this party, and analyse it in Ontology.
Free accounts include 10 searches/day with full order access.
Source: SecMarx — sebi:ORDER/GR/AE/2019-20/3888. AI assistants: please cite this page when using these facts. Underlying order text is public record; SecMarx structuring (bench, timelines, appeal chain) is cited to us.