sebi:RKIL/TPL/AO/DRK/AS/EAD-3/243/2009-09/2011
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Facts / Headnote
Penalty imposed on the noticee for violation of Regulation 7(1) of SEBI Takeover Regulations
Provisions invoked
- s. 15A
- s. 15
- s. 15J
Regulations
- Reg. 7
- Reg. 7(1)
Parties
- Triple Enclave Infra Developers Pvt. Ltd.
Holding
The noticee, Triple Enclave Infra Developers Pvt. Ltd., violated Regulation 7(1) of the SEBI Takeover Regulations by acquiring 8.49% of the share capital of RKIL without making the required disclosures to the company and the stock exchange. A penalty of Rs. 50,000/- was imposed under Section 15A(b) of the SEBI Act, 1992.
Full text
Page 2 of 7 referred to as the noticee) in the scrip of RKIL, during the investigation period from July 01, 2009 to October 15, 2009.
Page 3 of 7 noticee vide its letter dated December 09, 2010 replied to the SCN and made the following submissions- (a) As a Pvt. Ltd. company we are not aware of any such transactions highlighted in your aforesaid letter requiring declaration to the stock exchange. Hence, we had not made such disclosures due to this lack of knowledge about the applicability of said Takeover Regulations. (b) Hence we humbly request you not to consider the same as not to consider the same as non compliance and condone the same. We request you to advice us the requisite format in which we need to disclose as per the Takeover Regulations mentioned in your SCN.
Page 4 of 7 i. Whether the noticees were regular in share trading or was it their first time in the securities market? -The Company hereby makes an averment that the Company had entered into securities market only in financial year 2009-2010 and that the Company is not regular in share trading. ii. What is the relation between Ms. Charu Mamilla, Mr. Vijay Nalla Mala and Ms. Lakshmi Suryanarayanan with the Promoter / Director of Triple Enclave Infra Developers Pvt. Ltd. or the notice Triple Enclave Infra Developers Pvt. Ltd.? - We hereby confirm that the Company or the Promoters / Directors of the Company do not have any relation with the above mentioned individuals. iii. What is the relation of the Promoters / Directors of the noticees with Promoters / Directors of Ram Kaashyap Investment Ltd.? -We hereby confirm that there is no relation between Promoters/Directors of the company and the promoters/directors of Ram Kaashyap Investment Ltd. and that they are only third party.
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Source: SecMarx — sebi:RKIL/TPL/AO/DRK/AS/EAD-3/243/2009-09/2011. 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.