Bombay High Court
M.Nandagopal vs Securities And Exchange Board Of ... on 4 July, 2023
Bench: G.S. Patel, Dr. Neela Gokhale
2023:BHC-OS:6122-DB 4-5-OSWPL-11717-2023 WITH OSWPL-11721-2023-F.DOC
Gaikwad RD
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
ORDINARY ORIGINAL CIVIL JURISDICTION
WRIT PETITION (L) NO. 11717 OF 2023
Binny Limited ...Petitioner
Versus
Securities and Exchange Board of India ...Respondent
WITH
WRIT PETITION (L) NO. 11721 OF 2023
M Nandagopal ...Petitioner
Versus
Securities and Exchange Board of India ...Respondent
Mr Venkatesh Dhond, Senior Advocate, with Shruti Rajan,
Anubhav Ghosh, Vivek Shah & Hari Shankar, i/b Trilegal, for
the Petitioner in WPL/11717/2023.
Mr Somasekhar Sundaresan, with Shruti Rajan, Anubhav Ghosh,
Vivek Shah & Hari Shankar, i/b Trilegal, for the Petitioner in
WPL/11721/2023.
Mr Mustafa Doctor, Senior Advocate, with Suraj Chaudhary &
Shivani Kumbhojkar, i/b The Law Point, for Respondent No.1-
SEBI in both Writ Petitions.
CORAM G. S. Patel &
Neela Gokhale, JJ.
DATED: 4th July 2023
PC:-
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1. The Petitions challenge a rejection by Securities Exchange
Board of India ("SEBI") of what is called a Settlement Application.
The facts in the two Petitions are identical and we will therefore
refer to the record in Writ Petition (L) No. 11717 of 2023. The
Petitioner in the second Writ Petition is a director of the Petitioner
in the first Writ Petition.
2. The background is this. SEBI issued a show cause notice to
Binny Ltd on 24th November 2022. A copy of that show cause
notice, running to some 28 pages, is at Exhibit 'A' from page 66.
The notice mentions in paragraph 12 that under the SEBI
(Settlement Proceedings) Regulations, 2018 ("Regulations"), there
is a settlement mechanism provided. Should Binny wish to opt for a
settlement process, it could apply in the manner given in these
Regulations under intimation to SEBI. Binny was put to notice that
the filing of a Settlement Application did not confer any right to seek
the settlement of the proceedings. The Settlement Application,
which we will examine in detail a little later, is at page 95. It was filed
on 24th December 2022. Binny was afforded a personal hearing on
20th February 2023. In parallel, on 31st January 2023. it filed a reply
to the show cause notice. On 16th March 2023, SEBI rejected the
Settlement Application. A copy of that email intimation is at Exhibit
'D' at page 104.
3. The hearing on the show cause notice having concluded,
SEBI gave Binny a final opportunity to file post-hearing written
submissions by 15th March 2023. A further extension followed till
27th March 2023. On 25th March 2023, Binny sought yet another
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extension of four weeks and on 29th March 2023 sought a further
extension till 12th April 2023.
4. By this time, of course, the Settlement Application had been
rejected and Binny filed this Writ Petition on 25th April 2023 (and
one of its directors filed the companion Writ Petition). Curiously,
this Petition was not served on SEBI until 12th June 2023 and then
applications were made for an early hearing. We passed orders
allowing the filing of Affidavits in Reply and Rejoinder.
5. On behalf of Binny, Mr Dhond's assault on the impugned
Settlement Application rejection is that it falls afoul of the
applicable SEBI Regulations. It merely recites the reasons in the
show cause notice but does not independently give any reasons for
rejection of the Settlement Application. It is, in his submission,
cryptic and without a proper application of mind.
6. Before we turn to the Regulations, it would be useful to know
two factual aspects. The first is the four paragraph content of the
rejection of the Settlement Application at page 104:
"Madam/Sir,
1. With reference to the subject settlement application,
you may note that the same was examined by the Board and
following was noted:
a. Binny Limited has allegedly employed deceptive
devices for diverting the funds and understating revenue
during the investigation period, and adopted dubious
practices in drawing up accounts for manipulating the
financial results of Binny Limited to present a distorted
picture to its shareholders and to the public at large. It was
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noted that such alleged acts and omissions were fraudulent
on the part of the Company and such acts of serious
irregularities have affected the integrity of the market.
b. The share price fell by 4.62% (from Rs. 216.60 on
18/11/2021 to Rs. 206.20 on 22/11/2021) on the first day,
i.e. November 22, 2021, post dissemination of the
information regarding the appointment of a forensic auditor
on the exchanges. The price thereafter reached a level of
Rs. 211.65 by November 26, 2021.
c. The alleged diversion of funds of Rs. 851.27 crores to
other parties including related parties amounted to a loss to
the investors, thus impacting a large number of investors
(10507 public shareholders as of the quarter ended
December 31, 2021).
d. In view of the above, it was noted that the aforesaid
alleged diversion of funds and misrepresentation of the
financials of Binny Limited has caused losses to a large
number of investors and also affected the integrity of the
market.
2. Based on the same, the Board was of the considered
opinion that the proposed settlement of specified
proceedings as requested by you cannot be acceded to since
the alleged default attracts the provisions of Regulation 5(2)
(ii) and 5(2)(iii) of the SEBI (Settlement Proceedings)
Regulations, 2018.
3. In view of the above, the subject settlement
application has been rejected by the Board in terms of
Regulation 5(5) of the Settlement Regulations.
4. The reason(s) rendered at paragraph 1 above, are
intended only for the limited purpose of disposal of the
subject settlement application and shall not have any
bearing on the pending specified proceeding against the
applicant."
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7. This cannot be read in isolation. We will not reproduce the
28-page show cause notice in full, but there is no doubt that there
was an investigating authority and a forensic audit. There is a case in
the show cause notice of a massive diversion of funds of several
hundreds of crores. There is also a case in the show cause notice
itself, yet pending this final decision, of loss to investors and an
adverse impact on the integrity of the market.
8. But what did Binny actually propose in the Settlement?
Sections 19 and 20 of that Settlement Proposal at page 99 are
revealing: the monetary proposal is "as per the regulations", and
there is no non-monetary proposal at all. The long and the short of it
is that Binny filed a Settlement Application in name only. It had no
proposal, offer or suggestion. At least part of the Settlement
Application sought to contest or deny the show cause notice on
merits.
9. It is in this context that we must view the presentation
regarding the relevant Regulations. A copy of these Regulations is at
Exhibit 'O' from page 239. We are not troubled with the definitions
clause and turn to Chapter II which is the Application for
Settlement. Regulation 3(1) says that a person against whom any
specified proceedings have been initiated and are pending, or may be
initiated, may make an application to the Board in the prescribed
form. Then there are provisions for fees, etc. A limitation clause is
in Regulation 4 and Chapter III then deals with the scope of
settlement. Much emphasis is laid on this and therefore Regulations
5, 6 and 8 need to be reproduced in full:
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"Scope of settlement proceedings.
5. (1) No application for settlement of any specified
proceedings shall be considered, if:
(a) an earlier application with regard to the same
alleged default had been rejected;
(b) the audit or investigation or inspection or
inquiry, if any, in respect of any cause of action, is
not complete, except in case of applications involving
confidentiality; or
(c) monies due under an order issued under
securities laws are liable for recovery under
securities laws.
(2) The Board may not settle any specified proceeding,
if it is of the opinion that the alleged default,-
i. has market wide impact, or
ii. caused losses to a large number of investors,
or
iii. affected the integrity of the market.
(3) Without prejudice to the generality of the foregoing
provisions, for settling any specified proceeding the Board
may inter alia take into account the following factors,-
(a) whether the applicant has refunded or
disgorged the monies due, to the satisfaction of the
Board;
(b) whether the applicant has provided an exit or
purchase option to investors in compliance with
securities laws, to the satisfaction of the Board;
(c) whether the applicant is in compliance with
securities laws or any order or direction passed under
securities laws, to the satisfaction of the Board;
(d) any other factor as may be deemed
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appropriate by the Board.
(4) Without prejudice to sub-regulations (1) and (3), the
Board may not settle the specified proceedings where the
applicant is a wilful defaulter, a fugitive economic offender
or has defaulted in payment of any fees due or penalty
imposed under securities laws.
(5) Nothing contained in these regulations shall be
construed to restrict the right of the Panel of Whole
Time Members to consider or reject any application in
respect of any specified proceeding without examination
by the Internal Committee or the High Powered
Advisory Committee.
6. Rejection of application.
(1) An application may [also] at any time be rejected on
the following grounds:
(a) Where the applicant refuses to receive or
respond to the communications sent by the Board;
(b) Where the applicant does not submit or delays
the submission of information, document, [Revised
Settlement Terms,] etc., as called for by the Board;
(c) Where the applicant who is required to
appear, does not appear before the Internal
Committee on more than one occasion;
(d) Where the applicant violates in any manner
the undertaking and waivers as provided in Part-C of
the Schedule-I;
(e) Where the applicant does not remit the
settlement amount within the period specified in
clause (a) of sub-regulation (2) of regulation 15
and/or does not abide by the undertaking and
waivers;
(f ) Where the applicant fails to comply with the
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condition precedent(s) for settlement within the time
as required by the Internal Committee.
(2) The rejection under sub-regulation (1) shall be
communicated to the applicant:
Provided that the applicant shall continue to be
bound by the waivers given in respect of limitation or laches
in respect of the initiation or continuation or restoration of
any legal proceeding and the waivers given under sub-paras
(d), (e), (f ) and (g) of para 12 of the undertaking and
waivers as provided in Part-C of the Schedule-I.
8. Effect of pending application on specified
proceedings.
(1) The filing of an application for settlement of any
specified proceedings shall not affect the continuance of
the proceedings save that the passing of the final order
shall be kept in abeyance till the application is disposed
of.
(2) Where the application is filed in case of proceedings
that may be initiated against the applicant, such proceedings
shall not be initiated till the application is rejected or
withdrawn:
Provided that, the filing of an application shall not
prohibit the initiation of any proceedings, in so far as may
be deemed necessary for the purpose of issuance of interim
civil and administrative directions to protect the interests of
investors and to maintain the integrity of the securities
markets.
Explanation.-- Where any proceeding is pending or to be
initiated against several persons but the settlement
application is filed only by one or more persons, but not all,
the filing of such an application shall not affect the
initiation, continuation and disposal of the proceedings
against the person who has not filed the application for
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settlement and any adverse observations made in such
proceedings against the applicant shall qua the applicant be
subject to the outcome of the settlement application filed by
such applicant."
(Emphasis added)
10. Chapter IV then deals with the terms of the settlement and
says, importantly for our purposes, that a settlement term may
include a settlement amount or a non-monetary term or both in
accordance with guidelines in Schedule II. Non-monetary terms
may include suspension or cessation of business, exit from
management, disgorgement on account of the action or inaction and
so on.
11. Two committees are contemplated in Chapter V. There is an
Internal Committee under Regulation 12 and a High Powered
Advisory Committee under Regulation 11. Chapter VI then sets out
the procedure for settlement. Regulation 13 deals with proceedings
before the Internal Committee and Regulation 14 deals with the
proceedings before the High Powered Advisory Committee.
12. Mr Dhond's submission is that the Board cannot simply
invoke Regulation 5(2)(ii) and (iii) saying that loss has been caused
to the investors or that the integrity of the market has been affected
but must consider the Settlement Application 'on merits' and follow
the procedure set out in the Regulations. He and Mr Sundaresan
who appears for the Petitioner in the companion matter argue that
this is the mandate of the statute as seen from Section 15( JB) of the
SEBI Act which says in sub-section (2) that the Board may after
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taking into consideration the nature, gravity and impact of defaults
agree to the proposal for settlement on payment of such sum by the
defaulter or such other terms as may be determined by the Board in
accordance with the Regulations made under this Act.
13. Both Mr Dhond and Mr Sundaresan argue that the phrase 'in
accordance with the Regulations' necessarily means that the Board
is bound to follow the entire gamut of proceedings under the
Regulations including a reference to the Internal Committee and
then the High Powered Advisory Committee and that it cannot have
direct recourse to Regulation 5(5).
14. There is a fundamental flaw to the argument that the
application had to be considered on merits. It simply has no merits.
It says not a thing. It offers nothing. It proposes nothing.
15. The submission is an attempt to substitute what is clearly a
discretion vested in SEBI with an obligation. The whole of the
Regulations from beginning to end speak of the discretion in the
Board. Nothing in Chapter III persuades us that the Board is duty-
bound to consider an application however fruitless, however jejune,
and however grave the charges against the company -- merely
because it has been filed. The submission is not just that the filing of
a Settlement Application is a right, but that the mere filing creates
an entitlement denuding the Board of all discretion. The reference
to the statutory provisions is equally pointless because even those
speak of the Board's discretion.
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16. If we were to examine the reasons for or the background for
the introduction of these Regulations, we should find them
compactly stated in the elaborate report by the Justice AR Dave
Committee. That is a report of 10th August 2018 on Settlement
Mechanisms. The Settlement Regulations were introduced for the
first time following this report. The raison d'être of the Regulations
are compactly noted in the Report. The very first sentence of the
Background section at internal page 8 (brief page 558) has the oft-
quoted adage that justice delayed is justice denied. Mr Justice Dave
went on to say that it was of the utmost significance, and that the
constant struggle to uphold this legal maxim has been a bitter battle
in every judicial system. There is then a discussion on methods of
plea bargaining and finally the background says that the ever-
growing requirements of a free market, concerns of confidentiality
and other factors require the evolving of a settlement process for
effective enforcement. A settlement is required to avoid protracted
litigations and in particular, while dealing with settlements, care must be
taken to avoid prolonging a dispute. For this, pertinent questions as to
what would constitute a serious violation and who may be permitted to
apply for the settlement process remain a challenge.
17. We should take a step back to consider the impact of what it is
that is being canvassed by these Petitioners in the context of the
allegations in the show cause notice. There is a specific finding
based on a forensic audit report of an alleged diversion of funds, and
even SEBI says that this is only alleged, of Rs 851.27 Crores. There
is also a reference to loss to investors. What is being proposed is that
while this Settlement Application, (one that proposes absolutely
nothing) wends its way from one committee to another committee
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and then results in some decision, the show cause notice will remain
pending because of the provisions of Regulation 8(1), which says in
terms as noted above that a final order will be held in abeyance. That
seems to be the game plan: file some sort of application, style it as a
'Settlement Application', say and propose nothing at all in it, and
immediately demand that the decision on the show cause notice be
kept in abeyance.
18. It does not end there. Although it is clear that there is no
appeal, it is useless for these Petitioners to pretend as if that is the
end of their recourse to remedies. As we are now painfully aware,
having spent the better part of two hours on this matter, they have
ready recourse to a writ court, where the Petitioners expect to have
no questions asked of their time, and seem to be entitled to help
themselves greedily to vast amounts of very scarce judicial time.
Undoubtedly, any order the Board makes under the Regulations will
instantly be challenged in yet another writ petition. This process will
go on indefinitely with no end in sight. All the while, the show cause
notice will remain without final decision. Thus, the Regulation 8(1)
abeyance will go on forever, with any Settlement Application
'decision' being queried, questioned and challenged at every single
turn.
19. This is precisely what the Regulations do not contemplate:
protracted litigations in the face of serious violations required to be
answered.
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20. Mr Dhond's argument that even an application for
condonation of delay requires reasons1 is really of little assistance. If
a delay application is not allowed, the principal cause is lost. Here
the principal action is the show cause notice, not the Settlement
Application. In fact, this submission tells us everything we need to
know because it clearly implies that the Settlement Application is
being used as a mechanism to block the final adjudication of the
show cause notice.
21. The argument that every order needs the kind of reasoning as
one might expect in a judgment is fundamentally fallacious. The
reliance by the Petitioners on Madhyamam Broadcasting Ltd v Union
of India and Ors2 in paragraph 62 was in a completely different
context. The observations made by the Supreme Court in the
Madhyamam were in the context of the 'sealed cover procedure'
used by the Ministry of Home affairs while disclosing relevant
material solely to the Kerela High Court. It was in this context that
the Supreme Court observed that the non-disclosure of even a
summary of reasons for denying security clearance to MBL does not
share a rational connection with the purpose identified. The present
Petitioners have no vested right to insist that the dispute be resolved
in terms of a consensual settlement: that would denude the Board of
discretion to reject any settlement application no matter how sterile
and worthless.
1 New Delhi Television Ltd v Securities and Exchange Board of India & Anr,
2019 SCC Online Bom 1772.
2 2023 SCC Online SC 366.
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22. Mr Doctor, learned Senior Advocate for SEBI, has invited our
attention to a Division Bench judgment of this Court in Shilpa Stock
Broker Pvt Ltd v Securities and Exchange Board of India. 3 It is true
that this is a decision rendered before the Regulations came into
force. But substantially, the submission there parallels the one that is
made before us today. Paragraphs 12, 13 and 15 of the judgment in
Shilpa Stock Broker are as relevant now as they were then. That
decision is not diluted by the introduction of the Regulations. To say
otherwise would be unthinkable. The reason is that the paragraph 12
of Shilpa Stock Broker sets out a general standard in such matters.
Paragraphs 12, 13 and 15 read thus:
"12. Whether a dispute should be resolved or whether
the wider public interest in ensuring regulatory
compliance requires that proceedings should be initiated
and, if initiated should be followed to their logical
conclusion, is a matter which falls within the discretion
of SEBI. As a matter of first principle, a person against
whom action has been initiated by SEBI or a person who
apprehends that action will be initiated by SEBI has no
vested right to insist that the dispute be resolved in
terms of a consensual settlement. SEBI has been
constituted as an expert regulator to ensure the stable
and orderly functioning of the securities market. Acting
as a regulator of the securities market, decisions taken
by SEBI impact upon the economy and financial
stability. SEBI is vested with statutory powers, in the
public interest and the exercise of power must,
therefore, be guided by the public interest that SEBI is
vested with the power to protect. The considerations
which are spelt out in clause 11 provide some indication of
the nature of the power that is exercised. Amongst the
3 2012 SCC Online Bom 58.
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circumstances which are to be borne in mind is whether
the violation is intentional, the conduct of the party
during the course of investigation, the gravity of the
charge, the track record of the violator, whether a
violation is technical or minor, the extent of harm that
may be caused to investors, processes which have been
adopted to minimize future violations, proposed
compliance schedule, economic benefits that have
accrued from delayed or failure in compliance,
conditions necessary to deter future non-compliance,
satisfaction of claims of investors and compliance of
civil enforcement action. These factors indicate that the
question as to whether a dispute should be resolved by a
consensual settlement does not merely involve a private
lis between the violator and the regulator but involves a
consideration of wider issues of public interest. The
securities market impinges upon investor wealth.
Investors as a body represent the collective wealth of
numerous individual investors. Trading on the Stock
Exchanges and the business conducted by Stock Exchanges
has a material impact on investors, both institutional and
individual. Actions of stake holders in the securities market
have consequences not merely for the role and position of
the stake holder and his relationship with SEBI as regulator.
Those actions have serious consequences for the overall
well being of the securities market and those whose wealth
and investment is impacted by the stock market. SEBI is
vested with the power to protect and streamline the
functioning of the securities market. A person who is
alleged to be in breach of the Regulations or statutory
provisions which are designed to protect the public
interest can have no vested right either to insist upon
SEBI settling a dispute or in enforcing compliance of the
terms of a proposed offer of settlement.
13. If the matter is considered from this perspective,
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it is evident that the High Court in the exercise of its
jurisdiction under Article 226 of the Constitution would
not be justified in issuing a mandamus to SEBI to act
upon a settlement or to accept a settlement as proposed.
The guidelines which have been framed by SEBI are
administrative in character. Since the judgment of the
Supreme Court in G.J. Fernandez v. State of Mysore it has
been a settled principle of law that if administrative
guidelines issued by an authority have no statutory force,
they can confer no right on an individual that could be
enforced by a writ of mandamus. This principle was
reiterated in a subsequent decision of the Supreme Court in
J.R. Raghupathy v. State of A.P. But, apart from this
position, it is equally fundamental, while analyzing the
provisions of the guidelines to emphasis that where the
guidelines have conferred a discretionary power upon
SEBI to resolve a dispute which has still not reached the
stage of adjudication or criminal action, or a dispute for
that matter which is pending proceeding, it is for SEBI,
on a considered view of all the circumstances of each
case, to determine as to whether the dispute merits an
amicable solution.
15. For these reasons, we are of the view that there is no
merit in either of the submissions that are urged on behalf
of the Petitioners. The Guidelines in so far as they mandate
that proceedings should either be in contemplation or be
pending before they can be resolved, are based on a valid
rationale. The whole purpose of the Guidelines is to ensure
that the time and effort of the regulator is devoted to cases
which duly merit trial and enforcement. The Guidelines
thus recognise an enabling power in SEBI to resolve certain
cases which in the view of SEBI can be set at rest without
compromising either an issue of principle or public interest.
We have, therefore, come to the conclusion that (i) The
Guidelines do not confer a vested right in any person to
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insist on the acceptance of a proposed settlement; (ii) In the
present case, the adjudication which was initiated by SEBI
had attained finality before the Supreme Court; and (iii) A
proceeding which has attained finality, cannot be reopened
and the attempt to enforce terms of consent would result in
nullifying the effect of the order of the Supreme Court
which is impermissible. In the circumstances, we do not
find any merit in the Petition."
(Emphasis added)
23. Interestingly, Shilpa Stock Broker is cited specifically in the
Justice Dave Report to which we have earlier referred. It is therefore
impossible to say that this decision is of no relevance.
24. Viewed from any perspective, these Petitions, like the
Settlement Application, are entirely without substance. We
understand quite clearly now that the only purpose of the
Settlement Application and indeed these Writ Petitions was to
prolong and delay the adjudication of the show cause notice. If there
was any doubt about this, it is surely put to rest by one look at the
prayers in the Binny Petition, and in particular prayer clause (b)
which is really the prayer that is being sought, for a stay of the
adjudication on the show cause notice. Interestingly, although prayer
clause (a) ought to be really for a certiorari not a mandamus, there is
not even a prayer for a direction to SEBI to reconsider the
Settlement Application. In other words, an order on this Writ
Petition would effectively put an end to all SEBI action as a
regulator. That is simply unthinkable.
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25. These Petitions have taken an inordinate amount of time
when our dockets are already overcrowded. We believe these
Petitions are now fit cases for orders of costs.
26. The Petitions are rejected with an accompanying order of
costs of Rs 2.5 Lakh in each Petition payable equally (i.e., Rs.1.25
lakhs each) to:
(a) The Society for the
Rehabilitation of Crippled
Children
A/c No. 00051450000144 (Savings)
Bank Name HDFC Bank Ltd.
Branch Bhulabhai Desai Road, Mumbai
400026
RTGS/IFSC/ HDFC0000005
NEFT Code
(b) St. Jude India ChildCare
Centres
A/c No. 02402320004130
Bank Name HDFC Bank Ltd.
Branch Sandoz House, Dr AB Road,
Worli, Mumbai 400 018
RTGS/IFSC/ HDFC0000240
NEFT Code
27. Costs are to be paid within a period of ten days from today.
(Neela Gokhale, J) (G. S. Patel, J)
Digitally signed
by RAJU
DATTATRAYA
RAJU GAIKWAD
DATTATRAYA
Date:
GAIKWAD 2023.07.07
11:45:23
+0530
4th July 2023
