Re-classification of any person as Promoter / public - Regulation 31A

Reclassification of Promoters and Promoter Group 

Re-classification of any person as Promoter / public - Regulation 31A  as amended by SEBI (Listing Obligations and Disclosure Requirements) (Sixth Amendment) Regulations, 2018

CONTENT COVERED IN THE ARTICLE

1.     Brief information from the newspaper articles

2.     Brief introduction about the amended Regulation 31A

3.     Checklist for Company for action to be taken in respect of Reclassification under Regulation 31A

4.     Step-wise Process for reclassification

5.     Terms and conditions for reclassification

6.     Repercussions of Non-Compliance by Promoter seeking re-classification

7.     Timelines to be adhered to for reclassification under Regulation 31a of SEBI (LODR) Regulations, 2015

8.     Draft of the application / annexures as required to submit for re-classification

BRIEF INFORMATION FROM THE NEWSPAPER ARTICLES

Markets regulator SEBI has come out with new regulation for re-classification of a promoter as a public investor, wherein an outgoing promoter will have to relinquish special rights as well as control over the affairs of the listed firm and not be allowed to hold over 10 per cent stake.

Besides, the promoter would not be allowed to have any representation on the board of directors or act as a key managerial person in the listed entity.

Furthermore, the promoter seeking re-classification must not be a willful defaulter or a fugitive economic offender, the Securities and Exchange Board of India (SEBI) said in a notification dated November 16.

The norms, aimed at simplifying, streamlining and bringing greater clarity in existing regulations, come after SEBI 's board in September approved a proposal in this regard.

The Kotak panel on corporate governance had suggested that there should be a mechanism to allow such re-classification to ensure persons who may have been promoters but are no longer in the day-to-day control of management and have a low shareholding should have the option to be re-classified.

Under the new rules, in the case of a promoter seeking re-classification as a public shareholder, SEBI said the promoter group and persons acting in concert will not hold over 10 per cent of the total voting power in the listed entity and exercise control over the affairs of the entity directly or indirectly and will not have "any special rights with respect to the listed entity through formal or informal arrangements".

In order to ensure that only compliant listed entities are eligible to apply for re-classification, Sebi said such listed firms need to be compliant with 25 per cent minimum public shareholding requirement; their shares should not have been suspended from trading and they must not have any outstanding dues to the regulator, exchanges and depositories.

In all cases of re-classification of promoters, including the recommendation of the board, the proposal would be required to be placed by the listed entity before the shareholders in a general meeting and approved through an ordinary resolution.

The regulator said a listed entity will be considered as a 'listed entity with no promoter' if the entity does not have any promoter due to re-classification. Earlier, such firms were termed as 'professionally managed'.

Source:  Economics Times

INTRODUCTION 

The Securities and Exchange Board of India (SEBI) on 16th November 2018, by way of the SEBI (Listing Obligations and Disclosure Requirements) (Sixth Amendment) Regulations, 2018 has amended and replaced Regulation 31A of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 relating to the reclassification of existing promoters of listed companies as public shareholders. The new framework has been introduced based on the recommendations of the Kotak Committee on Corporate Governance.

CHECKLIST FOR COMPANY FOR ACTION TO BE TAKEN IN RESPECT OF RECLASSIFICATION UNDER REGULATION 31A

Sr. No	Particulars
1.	Application on Letter head of the company along with details of listing on other Exchange (if applicable). (Format enclosed – Annexure I A)
2.	Copy of BOD resolution approving the application of the promoter along with its recommendation to shareholders.
3.	Copy of the notice sent to the shareholders seeking their approval inter-alia including the views of the Board on the application made by the promoter
4.	Shareholders voting outcome (Voting results) along with certified true copy of the resolution passed.
5.	Latest Pre and Post Reclassification shareholding pattern as per format along with all the Annexure.
6.	Undertaking from the Company Secretary in the prescribed format. (Annexure I B)
7.	Letter from Promoter seeking reclassification from promoter to public inter-alia containing the rationale for seeking such re-classification and how conditions specified in clause 31A(3)(b) are satisfied.
8.	List of persons related to the promoter(s) seeking reclassification specifying the relation with the person seeking reclassification as per Reg 2(1) (pp) of SEBI (ICDR), 2018.
9.	Chronology of Events including details of various disclosures related to reclassification made by the company as required under Reg.31A (8)
10.	RTGS/ NEFT Payment of Rs. 50,000* + GST (18%) towards Processing Fees.

 

Step-wise Process for reclassification

A.    Application seeking reclassification

·         The promoter seeking reclassification (Outgoing Promoter) shall apply to Company for reclassification along with the supporting documents (undertaking), if any and the manner in which the following conditions are satisfied (Reclassification Application).

B.    Prerequisites for making Application:

Application for Reclassification can be made subject to fulfilment of following prerequisites

1.      The entities seeking to reclassify themselves under Public Category should be amongst those disclosed by the Company under Promoter and Promoter Group as per the latest shareholding pattern submitted to the Exchange.

2.      Persons related to the promoter(s) seeking re-classification “shall mean such persons with respect to that promoter(s) seeking re-classification who fall under Regulation 2(1)(pp) sub-clauses (ii), (iii) and (iv) of Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018”.

Definition of “promoter group” as per Regulation 2(1)(pp) sub-clauses (ii), (iii) and (iv) of Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018” which  includes: ii)   an immediate relative of the promoter (i.e. any spouse of that person, or any parent, brother, sister or child of the person or of the spouse); and iii) in case promoter is a body corporate: A) a subsidiary or holding company of such body corporate; B) any body corporate in which the promoter holds twenty per cent. or more of the equity share capital; and/or any body corporate which holds twenty per cent. or more of the equity share capital of the promoter; C) any body corporate in which a group of individuals or companies or combinations thereof acting in concert, which hold twenty per cent. or more of the equity share capital in that body corporate and such group of individuals or companies or combinations thereof also holds twenty per cent. or more of the equity share capital of the issuer and are also acting in concert; and iv) in case the promoter is an individual: A) any body corporate in which twenty per cent. or more of the equity share capital is held by the promoter or an immediate relative of the promoter or a firm or Hindu Undivided Family in which the promoter or any one or more of their relative is a member; B) any body corporate in which a body corporate as provided in (A) above holds twenty per cent. or more, of the equity share capital; and C) any Hindu Undivided Family or firm in which the aggregate share of the promoter and their relatives is equal to or more than twenty per cent. of the total capital;

3.      Application shall be for prior approval only, i.e. cases where the Reclassification has not already been made effected.

4.      As per the Regulations, the entity should be compliant with Minimum Public Shareholding (MPS) requirement as prescribed under Regulation 38 and trading in shares should not have been suspended. Further, there should be no outstanding dues against the company which is either payable to SEBI, Exchanges or Depositories.

5.      The entity(ies) seeking reclassification shall not be represented on the board of directors (including as a nominee director) and shall not act as Key Managerial Person in the listed entity for a period of 3 years from the date of such re-classification.

6.      The outgoing promoter should not be a ‘wilful defaulter’ as per the Reserve Bank of India Guidelines and should not be a fugitive economic offender.

7.      Prior to and Post reclassification, the promoter(s) seeking re-classification:

a.   shall not hold more than ten percent of the total voting rights in the listed entity,

b.  shall not exercise control over the affairs of the listed entity directly or indirectly, and

c.   shall not have any special rights with respect to the listed entity through formal or informal arrangements including through any shareholder agreements.

Upon failure to comply with above continuous requirements, the outgoing promoter shall automatically be reclassified as promoter/ persons belonging to promoter group, as applicable.

8.      If any public shareholder seeks to re-classify as promoter, it shall be required to make an open offer in accordance with the provisions of SEBI (SAST) Regulations 2011 as required under Listing Regulation 31A (5). No separate application needs to be done to the Exchange for this purpose, however intimation of the same may be provided to the Stock Exchange.

9.      The Company is required to intimate the stock exchanges where its shares are listed (Exchanges) of the receipt of the Reclassification Application within 24 hours of receipt of such application.

C.    Analysis by the Board of Directors

1.    The Board of Directors of the listed entity shall analyse the request and place the same before the shareholders in a general meeting for approval along with their views.

2.    There shall be a time gap of at least three months but not exceeding six months between the date of board meeting and the shareholders meeting considering the request for reclassification.

3.    Outcome of board meeting shall be submitted to the Exchange within 24 hours of the conclusion of board meeting in which resolution regarding reclassification is approved.

4.    For proceeding with the reclassification, the following conditions must be satisfied:

§  the Company must be compliant with minimum public shareholding (MPS) requirements.

§  trading in the shares of the Company must not have been suspended by the Exchanges.

§  the Company must not have any outstanding dues owed to SEBI, Exchanges or depositories.

D.    Approval of request by Shareholder in General Meeting

v  The board of directors must place the proposed reclassification before the shareholders of the Company, along with the views of the board of directors on the proposed reclassification.

v  There must be a gap of minimum 3 months and maximum 6 months between the date of meeting of the board and the date of meeting of the shareholders considering the proposed reclassification.

v  The Outgoing Promoter and the Persons Related to the Outgoing Promoter shall not vote on the resolution pertaining to such reclassification.

v  The shareholders of the Company must approve the proposed reclassification by way of an ordinary resolution

v  The Company is required to intimate the Exchanges of the outcome of the meeting of its shareholders within 48 hours of such meeting.

E.    Submission of application to the Stock Exchanges

v  After the Shareholder’s approval for the proposed reclassification, an application for reclassification in prescribed format as per the checklist and with the relevant supporting documents within 30 days from the date of approval by shareholders in the General Meeting shall be submitted to the Stock Exchange.

v  Additionally, disclosure of the fact that such application has been filed with the Exchanges shall be submitted to the Exchange as intimation of material event within 24 hours of the filing of such application.

v  Thereupon, the Exchange shall process the application subject to the application being complete in all respects and compliant with all applicable regulations and shall approve or reject the Reclassification Application.

v  In case of incomplete applications, company shall be provided opportunity to rectify the deficiencies. If the deficiencies are not rectified within 30 days of intimation of the same to the Company, the application shall be liable to be rejected and the processing fee paid by the company will be forfeited.

v  Letter of acceptance shall be issued to the company by the Exchange to effect the reclassification in the shareholding pattern subject to compliance with applicable SEBI regulations.

v  After Exchange approval / rejection of the reclassification application, same is also required to be disclosed as material event within 24 hours of communication of decision of the Exchange.

F.    Compliance to be undertaken by the promoter(s) seeking re-classification:

The promoter(s) seeking re-classification, subsequent to re-classification as public, shall comply with the following conditions:

(a)   he shall continue to comply with conditions mentioned at sub-clauses (i), (ii) and (iii) of clause (b) of Regulation 31A(3) at all times from the date of such re-classification failing which, he shall automatically be reclassified as promoter/ persons belonging to promoter group, as applicable;

(b)   he shall comply with conditions mentioned at sub-clauses (iv) and (v) of clause (b) of sub-regulation 3 for a period of not less than three years from the date of such re-classification failing which, he shall automatically be reclassified as promoter/ persons belonging to promoter group, as applicable.

Other Conditions

The promoter(s) seeking re-classification and persons related to the promoter(s) seeking re-classification shall not:

(i)     together, hold more than 10% of the total voting rights in the listed entity;

(ii)    exercise control over the affairs of the listed entity directly or indirectly;

(iii)   have any special rights with respect to the listed entity through formal or informal arrangements including through any shareholder agreements;

(iv)  be represented on the board of directors (including not having a nominee director) of the listed entity;

(v)   act as a key managerial person in the listed entity;

(vi)  be a ‘wilful defaulter’ as per the Reserve Bank of India Guidelines;

(vii) be a fugitive economic offender.

Repercussions of Non-Compliance by Promoter seeking re-classification

If the aforesaid conditions not complied, such person(s) shall automatically be reclassified as promoter/ persons belonging to promoter group, as applicable.

TIMELINES TO BE ADHERED TO FOR RECLASSIFICATION UNDER REGULATION 31A OF SEBI (LODR) REGULATIONS, 2015

Sr. No.	Particulars	Intimation to the Exchange	Assumption Dates
1.	Application by the Promoter to the Company     along      with       requisite undertaking.		01.01.2020
2.		Intimation to the Exchange within 24 hours of receipt of application.	02.01.2020
3.	Resolution must be passed in the meeting of Board of Directors for approving reclassification.	(any next BM)	15.02.2020
4.		Intimation to the Exchange within 24 hours of conclusion of Board meeting including Minutes	16.02.2020
5.	Hold Shareholder’s meeting and pass ordinary resolution for approving reclassification. (Ensure time gap of at least three months but not exceeding six months between the date of board meeting and the shareholder’s meeting.)		17.05.2020 Or by 15.08.2020
6.		Intimation to the Exchange within 24 hours of conclusion of Shareholder meeting.	18.05.2020
7.	Submit reclassification application along with supporting documents to the Exchange within 30 days of conclusion of shareholder’s meeting.	30 days of conclusion of shareholder’s meeting.	16.06.2020
8.	Deficiencies in application must be rectified by the company within 30 days of intimation.	30 days of receipt of intimation.
9.	Letter of acceptance to be issued to the Company to effect the reclassification.		15.07.2020
10.		Intimation to the Exchange within 24 hours of receipt of Letter of acceptance by the company.	16.07.2020

Reclassification of Non Promoter (Public Shareholder) to Promoters and Promoter Group [Regulation 31A(5)]

If any public shareholder seeks to re-classify itself as promoter, it shall be required to make an open offer in accordance with the provisions of Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 2011. [Regulation 31A(5)]

Reclassification in case of transmission, succession, inheritance and gift of shares [Regulation 31A(6)]

(a)   immediately on such event, the recipient of such shares shall be classified as a promoter/ person belonging to the promoter group, as applicable.

(b)   subsequently, in case the recipient classified as a promoter/person belonging to the promoter group proposes to seek re-classification of status as public, it may do so subject to compliance with conditions specified in as specified above. [Reg 31A (3)]

(c)   in case of death of a promoter/person belonging to the promoter group, such person shall automatically cease to be included as a promoter/person belonging to the promoter group.

Listed entities with no promoters [Regulation 31A(7)]

Under the Amended Regulations, a Company will be considered as 'listed entity with no promoter' if due to reclassification or otherwise, the Company ceases to have a promoter.

Disclosure of Material events to the stock exchanges within 24 hours from the occurrence of the event [Regulation 31A(8)]

(a)   receipt of request for re-classification by the listed entity from the promoter(s) seeking re-classification;

(b)   minutes of the board meeting considering such request which would include the views of the board on the request;

(c)   submission of application for re-classification of status as promoter/public by the listed entity to the stock exchanges;

(d)   decision of the stock exchanges on such application as communicated to the listed entity;

The procedure described above for reclassification of promoter will not be applicable, if such reclassification is pursuant to a resolution plan approved under the Insolvency and Bankruptcy Code, 2016, subject to the condition that the Outgoing Promoter must not remain in control of the Company.

Exception / Non-applicability of the above provisions

Reclassification pursuant to insolvency proceedings [Regulation 31A(9)]

Whether there is re-classification of promoter(s)/ promoter group of the listed entity as per the resolution plan approved under section 31 of the Insolvency Code, subject to the condition that such promoter(s) seeking re-classification shall not remain in control of the listed entity, the procedure described above for reclassification of promoter shall not be applicable.

COMMENTS

The Amended Regulation 31A streamlined the process for reclassification of promoters and provides for one set of rules applicable to all reclassifications. There were several ambiguities under the old regime which have been addressed and certain loopholes have also been plugged.

Certain restriction imposed upon the going promoter with respect to connection with the entity. The clarification regarding the persons entitled to vote on reclassification resolutions puts to rest controversies regarding the ability of Outgoing Promoters and persons acting in concert with the Outgoing Promoters to vote.

Further, in another welcome move, onerous restrictions under the earlier regime for categorizing a company as 'professionally managed' have been removed.

DRAFT DOCUMENTS / ANNEXURES

A.        LETTER FOR INTIMATION TO STOCK EXCHANGE

____________(Month), 2020

DCS - Listing BSE Limited Phiroze Jeejeebhoy Towers, Dalal Street, Mumbai - 400 001 Scrip Code - …………..

Listing Department National Stock Exchange of India Limited Exchange Plaza, C-1, Block G, Bandra Kurla Complex, Bandra (East), Mumbai - 400 051 Scrip Symbol - ………………….

 

Dear Sir,

Sub :      Reclassification of shareholding from "Promoter and Promoter Group" Category to "Public" Category as per Regulation 31A of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015

In accordance with Regulation 31A(8)(a) of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, we hereby inform that we are in receipt of the requests for reclassification from "Promoter and Promoter Group" category to "Public" category under the provisions of the said Regulation from each of the following shareholders of the  Company:

The requests have been received from all the above shareholders currently belonging to the "Promoter and Promoter Group" category of the Company as of __th ____________(Month), 2020, and are enclosed along with this intimation.

The requests for reclassification have been considered by the Board of Directors at its meeting held on __th ____________(Month), 2020, and the same have been approved by the Board of Directors subject to approval of shareholders at the ensuing Annual General Meeting and the Stock Exchanges in terms of Regulation 31A of SEBI (LODR) Regulations, 2015. The Company shall take appropriate steps for securing approval of shareholders and Stock Exchanges in terms of provisions of SEBI (LODR) Regulations, 2015. After receipt of necessary approvals, Promoters' shareholding in the Company would be _ _._ _%.

We request you to take the above on record and treat this as our intimation for material event in accordance with Regulation 31A(8)(a) of SEBI (LODR) Regulations, 2015.

Kindly take the same on record.

Thanking You, Yours Faithfully,

For ………………………Limited

(…………………………………)

DGM - Legal & Company Secretary

Encl : As above

Annexure I

B.        COMPANY APPLICATION TO STOCK EXCHANGE FOR RECLASSIFICATION

Date:

To,

BSE Limited,

Listing Compliance Monitoring Cell, 24th Floor, P.J. Towers,

Dalal Street, Mumbai -400001

                                                 Sub: Application for Reclassification under Listing Regulation 31A.

The Company is in receipt of a request from (mention name of the promoter), promoter/ (s) of the Company, seeking reclassification as public under Regulation 31A of SEBI (Listing Obligations and Disclosure Requirements) Regulations 2015.

In this regard, please find attached herewith the requisite documents as specified in the checklist.

In addition to BSE Limited, Company is also listed at _ (Mention the names of all Exchanges where Issuer is listed, in case Company is listed only at BSE, please mention ‘no other exchange’)

Please find enclose herewith the details of RTGS/ NEFT Payment made towards processing fees of Rs.50,000 + GST (18%).

We hereby request you to kindly process our application for reclassification of promoter as public under Regulation 31A of Listing Regulations 2015 and grant your approval.

In case of any query, please contact the following person:

Name:

Designation:

E-mail ID:

Cell No:

Telephone No:

Yours Faithfully,

(Name and contact details of signatory with designation)

 

Annexure II

C.        UNDERTAKING BY THE COMPANY SECRETARY FOR RECLASSIFICATION UNDER REG. 31A OF LISTING REGULATION

Date:

To,

The Deputy General Manager, Listing Compliance Monitoring Cell, 24th Floor, P.J. Towers,

Dalal Street, Mumbai -400001

Sub: Application for Reclassification under Regulation 31A of SEBI (Listing Obligations and Disclosure Requirements) Regulations (Listing Regulations), 2015

Dear Sir / Madam,

With relation to our application for reclassification of promoter shareholders, we confirm as under:

1.     The application has been filed within 30 days from the date of approval of reclassification of promoters by the shareholders of the company.

2.     Outgoing Promoter(s) and persons related to him do not hold more than Ten percent of the total voting rights in the Company.

3.     Post reclassification, the Outgoing promoter(s) will not exercise direct or indirect control over the affairs of the Company.

4.     All special rights of the Outgoing Promoter(s) which were acquired by virtue of any shareholder agreements have been terminated.

5.     Outgoing Promoter(s) will not be represented on the Board of Directors (including a Nominee Director) of the Company for a period of not less than three years from the date of such reclassification.

6.     Outgoing Promoter(s) will not act as a key managerial person in the Company for a period of not less than three years from the date of such reclassification.

7.     The company, its promoters, its directors are not in violation of the restrictions imposed by SEBI under SEBI circular no. SEBI/HO/ MRD/DSA/CIR/P/2017/92 dated August 01, 2017.

8.     that the company or its promoters or whole-time directors are not in violation of the provisions of Regulation 24 of the SEBI Delisting Regulations, 2009.

9.     Outgoing Promoter(s) are not a wilful defaulter as per the Reserve Bank of India Guidelines.

10.  Outgoing Promoter(s) are not a fugitive economic offender.

11.  That the company is compliant with the requirement for minimum public shareholding as required under Regulation 38 of SEBI (Listing Obligation and Disclosure Requirement) and the proposed reclassification is not being initiated for achieving the Minimum Public Shareholding.

12.  That trading in the shares of the company has not been suspended by the stock Exchanges

13.  That the Company does not have any outstanding dues to the SEBI, the Stock Exchanges or Depositories.

14.  The company has complied with the disclosure requirements as specified under Reg.31A(8) of Listing Regulations.

Yours faithfully

(Name and contact details of signatory with designation)

D.    CHRONOLOGY OF EVENTS FOR RECLASSIFICATION UNDER REGULATION 31A OF SEBI (LODR) REGULATIONS, 2015

Date:

To,

The Deputy General Manager, Listing Compliance Monitoring Cell,

24th Floor, P.J. Towers,

Dalal Street, Mumbai -400001

Sub:     Chronology of Events for Reclassification under Regulation 31A of SEBI (LODR) Regulations, 2015.

Sr. No.	Particulars	Date of the Event
1	Receipt of Application by the Promoter to the Company along with requisite undertaking.
2	Submission of intimation of receipt of promoter application by the Company to the Exchange
3	Date of Board meeting wherein reclassification matter is considered and approved
4	Submission of Minutes of the BOD meeting wherein the proposal of the promoter seeking reclassification has been considered
5	Date of Shareholder Meeting wherein reclassification has been approved.
6	Submission of reclassification application with the Stock Exchange

Case Law: 

Gillette India

The Indian arm of the world's largest consumer goods company Procter and Gamble, the Securities Appellate Tribunal or SAT has dismissed the company's appeal against Sebi for alleged violation of the market regulators minimum public shareholding norms. SAT also vacated the interim relief granted earlier to the company on May 30th, 2013.

Men’s grooming product maker Gillette India had sought to meet the 25% minimum public shareholding threshold by reclassifying its promoter shareholding as non-promoter shareholding but its proposal was rejected by Sebi as the regulator felt the route intended to circumvent the guidelines and was not in line with the "spirit" of the norms. Sebi had argued that the Gillette proposal did not talk about offering shares to the public and would not create the dispersed shareholding structure essential to provide liquidity to the investors and discover the fair price.

On Wednesday, while passing an order, SAT member Jog Singh termed the proposal a " contentious and circuitous method which is against the spirit of the law". The tribunal further said that " the appellant seems to have overlooked, whether deliberately or inadvertently, the fact that the underlying philosophy behind the requirement of a minimum public holding of 25% is prevention of concentration of shares in the hands of a few market players by ensuring a sound and healthy public float to stave off any manipulation or perpetration of other unethical activities in the securities market which would unfortunately be the irrefragable consequences of the reins of the market being in the hands of a few."

The tribunal also pulled up Gillette India for delaying the proposal to achieve the minimum public shareholding saying that the company " waited till the fag end of the window period of 3 years provided to listed companies to ensure adherence with the regulation." "We are looking into the order in detail, and remain committed to complying with the new law and engaging with SEBI to achieve compliance with the minimum 25% public shareholding requirement norm,” said P&G spokesperson responding to specific queries.

"This order upholds stronger corporate governance principles and is a signal to India Inc and MNC's that the regulations apply to all equally," says Akil Hirani, Managing Partner, Majmudar & Partners.

The Gillette promoters hold 88.76% according to exchange filings. According to the three-tiered formula of the company, firstly the Indian promoters ( SK Poddar Group) would transfer a 4% stake to parent company Procter & Gamble at a 25% premium for giving up control and certain statutory rights.Then the shareholder agreement between P&G and Poddar Group would be terminated. And finally, P&G would sell 4.9% through OFS to bring down the total promoter holding to 75%.

According to the arguments of Gillette India’s counsel's in the tribunal, Sebi has ignored similar cases of reclassification by other companies like Gokaldas Exports, Capital First (formerly Future Capital). In response to these claims, SAT had earlier observed that Sebi should examine the shareholding patterns of the relevant entities.

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