SEBI AND CORPORATE LAWS

Vol. 82, Part 1, for the week of February 18 – February 24, 2008

 

Contents

STATUTES

circular/press note

rbi/fema

-   Exim Bank’s Line of Credit of USD 35.20 million to the Government of the Kingdom of Combodia - A.P. (DIR series) Circular no. 27, dated 5-2-2008 

-   Memorandum of Instructions for Opening and Maintenance of Rupee/Foreign Currency Vostro Accounts of Non-resident Exchange Houses - A.P. (DIR series) Circular no. 28/a.p. (fl/rl series) circular no. 02, dated 6-2-2008 

sebi

-   SEBI (Issue and Listing of Debt Securities) Regulations, 2008/SEBI (Public Offer and Listing of Securitized Debt Instruments) Regulations, 2008/SEBI (Intermediaries) Regulations, 2008/Amendment to SEBI (Mutual Fund) Regulations, 1996 - press release no. 24/2008, dated 30-1-2008  2

-   ‘Art Funds’ Covered by Collective Investment Scheme - press release no. 44/2008, dated 13-2-2008 

circular/press release

sebi

-   Amendment to Securities Contracts (Regulation) Rules proposed - press release, dated 1-2-2008 

notification

industries (development and regulation) act

-   Section 29B of the Industries (Development and Regulation) Act, 1951 - Power to exempt in special cases - Amendment in Notification No. S.O. 477(E), dated 25-7-1991 - notification no. s.o. 246(e), dated 5-2-2008 

rules/regulations

insurance matters

-   Insurance Regulatory and Development Authority (Obligations of Insurers to Rural or Social Sectors) (Third Amendment) Regulations, 2008 - Amendment in regulation 3; insertion of regulations 3B, 4A, 5, 6 and 7 - notification f. no. irda/reg/1/42/2008, dated 3-1-2008 

-   Insurance Regulatory and Development Authority (Obligations of Insurers to Rural or Social Sectors) (Fourth Amendment) Regulations, 2008 - Amendment in regulation 3 - notification f. no. irda/reg. 2/13/2008, dated 25-1-2008 

secretarial standards

companies act

-   Secretarial Standard on Minutes (SS-5) 

-   Secretarial Standard on Transmission of Shares and Debentures (SS-6) 

reports

table of cases

Bapi Construction v. Pronob & Co. (P.) Ltd. (Cal.) 

Harinarayan G. Bajaj v. Union of India (Bom.) 

On Line Media Solutions Ltd., In re (AP) 

Oswal Agro Furane Ltd., (In Liquidation), In re (Punj. & Har.) 

Pearl Stripes (P.) Ltd. v. Secure Industries Ltd. (All.) 

Sonbhadra Minerals (P.) Ltd. v. Saxena (S.K.) (All.) 

Tax Recovery Officer v. Custodian (SC) 

subject index

Companies Act, 1956

Share capital

Reduction of

-   Petitioner-company filed petition seeking confirmation of proposal to reduce paid-up capital so as to bring parity with its assets and also to write off accumulated losses - Articles of association of petitioner enabled it to reduce its share capital in accordance with section 100 and shareholders of petitioner, in their annual general meeting, confirmed that proposal, by passing special resolution - Company had no secured creditors and two unsecured creditors had given their consent to reduction of capital - Reduction in share capital was uniform to all shareholders and was applicable to entire paid-up capital - Whether, on facts, proposal to reduce share capital was to be confirmed - Held, yes - On Line Media Solutions Ltd., In re (AP) 

Winding up

Circumstances in which a company may be wound up

-   Appellant filed winding up petition against respondent-company, alleging that goods sold and supplied by it were not paid for - Respondent’s case was that appellant’s demand was in respect of three introductory supplies which, not being as per respondent’s specification, had been returned to it and if appellant contended that it had not taken back said supplies, it should explain as to why it had not demanded payment therefor immediately but after more than one year - Company Judge refused to admit petition holding that respondent’s defence was not mala fide or moonshine - Whether on facts, Company Judge was justified in dismissing winding up petition filed by appellant - Held, yes - Pearl Stripes (P.) Ltd. v. Secure Industries Ltd. (All.) 

-   In respect of three purchase orders issued on respondent-company for supply of material, petitioner paid certain sum to company as advance - As company supplied material against two purchase orders only, petitioner after adjusting company’s bills for supplies, demanded refund of balance advance - In response to statutory notice, respondent contended that by issuing two letters, it had reminded petitioner that due to petitioner’s failure to lift goods, it had incurred heavy loss and after adjusting balance advance against such loss, petitioner itself was liable to pay certain amount to respondent-company - Petitioner admitted receipt of said letters and produced same - It was found that both letters were bland demands for supply of sales tax declarations forms - Whether, on facts, company’s defence was without any basis and, therefore, petition was to be admitted - Held, yes - Bapi Construction v. Pronob & Co. (P.) Ltd. (Cal.) 

Overriding preferential payment

-   Subsequent to winding up order and sale of assets of company-in-liquidation, workers filed an application before High Court seeking a direction to Official Liquidator to settle their claim - Court directed Official Liquidator to appoint a chartered accountant for scrutiny of workers’ claim and to settle their claims on basis of said report - Chartered accountant, so appointed, classified claims of workers under section 529A and claims of 33 employees under section 530 - Workmen conveyed acceptance to report of chartered accountant in respect of claims classified under section 529A, but in respect of claims classified under section 530, it was stated that fresh claims would be submitted - However, Official Liquidator, without seeking further evidence in terms of rule 159 and without accepting/rejecting claims of employees classified under section 530, sought approval of Court as if their claims fell under section 529A and after Court permitted him to pay dues of workmen as per report of chartered accountant, he paid all workmen including aforesaid 33 employees - Whether since claim of 33 employees had been paid without any acceptance of claims by Official Liquidator and on misrepresentation by Official Liquidator to Court, disbursement made to said employees was wholly unjustified, illegal and without jurisdiction - Held, yes - Whether, therefore, said 33 employees were to be directed to refund amount disbursed to them and Official Liquidator was to be directed to consider and pass appropriate order after adjudicating claim of employees classified under section 530 in terms of report of chartered accountant - Held, yes - Oswal Agro Furane Ltd., (In Liquidation), In re (Punj. & Har.) 

Powers of liquidator

-   Whether though Official Liquidator, under Court’s supervision, has jurisdiction to sell only assets of company-in-liquidation, Act does not prohibit Company Court to include an asset held by promoters, on their representation, which is integral part of sale or may be necessary to be included to make sale more attractive - Held, yes - A company, wholly owned and controlled by State Government, was ordered to be wound up - Tenders were invited for sale of assets of company-in-liquidation - Assets offered for sale also included certain mines, adjacent to factory of company, owned by State Government - Sale was confirmed in favour of highest bidder after receiving valuable consideration - In course of proceedings, Court was informed about some illegal mining going on in said mines and interim orders were passed restraining illegal mining activities - Applicant sought to recall those injunction orders, alleging that aforesaid mines, despite being in close proximity of factory premises of company-in-liquidation, were never its assets and Company Court had no jurisdiction to sell any property which was not asset of company-in-liquidation; and that those mines were subject of joint venture agreement and State Government had accorded approval for renewal of mines and permitted applicant to carry out mining activities in that area and, thus, it was wrongly restrained to carry on its legitimate and lawful mining activities - Whether since State Government, being guarantor to loans given by banks and financial institutions to company-in-liquidation, was interested to secure best available price to discharge its contractual liabilities and, therefore, agreed to add some more assets and offered reliefs and concessions to make sale more attractive for expeditious disposal of assets of company-in-liquidation for benefit of secured creditors including banks and financial institutions and about 6,000 workmen starving for last eight years, Court would not allow applicant to intermeddle in matter, particularly when it had not brought on record necessary approvals of mining operations to demonstrate that it was carrying on valid and legal mining activity in that area - Held, yes - Whether, therefore, application was liable to be rejected - Held, yes - Sonbhadra Minerals (P.) Ltd. v. S.K. Saxena (All.) 

Companies Act, 1956

-   Section 100 

-   Section 433 

-   Section 457 

-   Section 529A 

SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 1994

Applicability of regulation

-   Whether an indirect takeover of a company, by acquiring control of a corporate body, which holds a large percentage of shares of target company, attracts provisions of 1994 Regulations and Listing Agreement and makes it mandatory for acquirer-company to make public announcement/offer - Held, no - Whether if there is no acquisition of shares in a target company, provisions of Chapter III do not get triggered - Held, yes - Whether Chapter III does not apply to acquisition of shares of companies (formed and registered under the Companies Act, 1956 or earlier Companies Acts) which are not listed on any stock exchange - Held, yes - Respondent No. 4, a foreign company, held 51 per cent shareholding in respondent No. 3, target company listed in India - Respondent No. 4 was a hundred per cent subsidiary of another foreign company ‘E’, which, in turn, was a wholly owned subsidiary of respondent No. 5, another foreign company (MITSUI Group) - Before respondent No. 4 became a hundred per cent subsidiary of ‘E’, it was a hundred per cent subsidiary of LIVA, which was owned by a consortium of companies held by RIVA Group - In course of time, shareholding of respondent No. 4 changed hands from LIVA to ‘E’ and, therefore, control and management of respondent No. 3 passed on from RIVA Group to MITSUI Group - Petitioner alleged that acquisition of respondent No. 3 by respondent No. 5 through respondent No. 4 was in violation of 1994 Regulations and was also in violation of provisions of clauses 40A and 40B of Listing Agreement of Stock Exchange - Whether since no shares/securities were acquired in respondent No. 3 by any entity and only ownership of respondent No. 4 changed, transaction did not come within ambit of provisions of 1994 Regulations - Held, yes - Harinarayan G. Bajaj v. Union of India (Bom.) 

Takeovers

-   Acquisition of 10 per cent or more of shares of any company through negotiations - Whether expression ‘securities’ in regulation 9(3) clearly and obviously refers to securities of target company and not securities of a company which holds shares in target company - Held, yes - Harinarayan G. Bajaj v. Union of India (Bom.) 

SEBI (Substantial Acquisition of Shares and Takeovers) Regulation, 1994

-   Regulation 3 

-   Regulation 9 

SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 1997

Applicability of regulation

-   Whether indirect acquisition of shares or change in control has been introduced for first time by 1997 Regulations - Held, yes - Harinarayan G. Bajaj v. Union of India (Bom.) 

Repeal and savings

-   Whether SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 1994, on being repealed by 1997 Regulations, would be restricted in their operation as given in regulation 47, which provides for repeal and savings, but insofar as changes introduced by 1997 Regulations are concerned, particularly those provisions, which are substantive in nature and did not exist in 1994 Regulations, will have to be read in context of regulations which stand substituted - Held, yes - Harinarayan G. Bajaj v. Union of India (Bom.) 

SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 1997

-   Regulation 3 

-   Regulation 47 

Special Court (Trial of Offences Relating to Transactions in Securities) Act, 1992

Special Court

Powers of

-   Company ‘D’ was notified under Act and its assets stood attached to Special Court - ‘K’ owed substantial amount of money to ‘D’ - On recovery suit filed by Custodian on behalf of ‘D’, decree was passed against ‘K’ in execution of which, properties of ‘K’ were put to auction and money was realized - At that stage, Tax Recovery Officer filed intervention application before Special Court praying to restrain Custodian from distributing sale proceeds without first satisfying claim of Income-tax Department against ‘K’, which was pending for recovery - Application was rejected by Special Court as not maintainable - Whether in view of section 9A, jurisdiction of Special Court is in relation to any matter or claim relating to any property belonging to any person notified under Act and since, in instant case, notified party was ‘D’ and not ‘K’, application moved by Income-tax Department for realization of its income-tax dues from ‘K’ was rightly rejected - Held, yes - TRO v. Custodian (SC) 

Special Court (Trial of Offences Relating to Transactions in Securities) Act, 1992

-   Section 9A 

 

MAGAZINE

features

FOREIGN EXCHANGE LAWS

MANOJ FOGLA

-   A critique of the proposed Foreign Contribution (Regulation) Bill, 2006 

securities laws

Tulika Sinha

-   Role of stock exchange in development of economy 

Case Digest

table of cases

Branch Manager, Indian Bank v. Krishnamoorthy (Ker.) 

Indian Steel & Wire Products Ltd. v. Kothari Metals Ltd. (Cal.) 

Subject Index

Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002

Civil Court not to have jurisdiction

-   Respondent-borrower filed suit seeking decree for permanent injunction restraining petitioner-bank from trespassing into his plaint property - Petitioner filed interim application contending that suit was not maintainable by virtue of section 34 - Trial court, however, dismissed said application - Whether when respondent did not dispute amount due and did not claim that notice sent under section 13(2) was bad for non-mentioning details as provided under section 13(3), he was not entitled to circumvent provisions of Act or avoid bar under section 34 - Held, yes - Whether, therefore, it was absolutely clear that suit was barred under provisions of section 34 - Held, yes - Branch Manager, Indian Bank v. Krishnamoorthy (Ker.) 

Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002

-   Section 34 

Sick Industrial Companies (Special Provisions) Act, 1985

Suspension of legal proceedings, contracts, etc.

-   Whether if BIFR sanctions a scheme making provision for payments over several years to creditors, whose dues are reflected in company’s records up to a specified date, then dues of later creditors would not be covered by said scheme - Held, yes - Whether if BIFR, in a sanctioned scheme, does not provide for payment to some creditors, whose dues are reflected in sick company’s books, then it is not to be easily concluded that such creditors need not be paid at all, unless there is specific provision therefor, which is subject to appeal and judicial review - Held, yes - Whether an ordinary right of a supplier to receive payment for his wares can be deemed to have evaporated upon his claim not finding mention in scheme sanctioned by BIFR - Held, no - On a reference, a rehabilitation scheme was sanctioned by BIFR on 20-12-2003 - Petitioners claimed to have effected supplies to company during 2002-03 and 2003-04 - Whether embargo of section 22 was applicable in case of petitioners - Held, no - Whether petitioners’ claim could be disregarded merely because scheme was sanctioned at a time subsequent to entirety or part of their payments having fallen due - Held, no - Indian Steel & Wire Products Ltd. v. Kothari Metals Ltd. (Cal.) 

Sick Industrial Companies (Special Provisions) Act, 1985

-   Section 22