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WTM/SR/CIS-NRO/59 /08 /2014

BEFORE THE SECURITIES AND EXCHANGE BOARD OF INDIA, MUMBAI
CORAM: S. RAMAN, WHOE TIME MEMBER

ORDER

U!"#$ S#%&'(!) 11*1+, 11*4+ ,!" 11B (- &.# S#%/$'&'#) ,!" E0%.,!1# B(,$" (- I!"', A%&,
1992 $#," 2'&. R#1/3,&'(! 45 (- &.# SEBI *C(33#%&'5# I!5#)&6#!& S%.#6#)+ R#1/3,&'(!),
1999 '! &.# 6,&&#$ (- S&#7 U7 M,$8#&'!1 9$'5,&# '6'&#" * 9AN : AA:FS4;04< + ,!" '&)
D'$#%&($), 5'=., H,$>'& S'!1. D.,$'2,3 *9AN: AD?9D22849+ ,!" R,1.@'$ A,/$
*DIN:00B424;;+.
_______________________________________________________________________
1. Securities and Exchange Board of India (hereinafter referred to as "SEBI") received a
complaint dated June !" #1! against Step $p %ar&eting 'vt. (td. (hereinafter referred to
as "SUM9") alleging raising of mone) under its schemes "Real Step Pashupalan and Real Step
Breeding Farm for sale, breeding, rearing & keeping of livestock ".

#. *s a matter of preliminar) in+uir)" vide letter dated June #," #1! SEBI sought information
from the complainant such as -rochure" application forms" .opies of agreements" etc." if
availa-le regarding the operations of aforesaid schemes. /he said letter 0as dul) served"
ho0ever SEBI has not received an) response 1 repl) to the said letter.

!. /hereafter" SEBI" vide its letter dated 2cto-er !" #1!" sought the follo0ing details 1
documents from S$%'( in order to ascertain 0hether or not S$%'( is carr)ing on
'Collective Investment Schemes' in terms of Section 11 ** of the SEBI *ct" 133# (hereinafter
referred to as "SEBI A%&") 4
i. 5um-er of plans1schemes launched1proposed"
ii. Structure of such plans1schemes"
iii. /erms and conditions of each 'lans1Schemes launched -) S$%'("
iv. 6etails of the 'lan(s)1Scheme(s) 0ise amount collected along 0ith the num-er of
investors under such 'lans1Schemes as on Septem-er !" #1!"
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v. .opies of application forms that are re+uired to -e su-mitted -) the
investors1applicants to participate in S$%'( 7s plans1schemes and copies of
-rochures pertaining to S$%'(7s schemes 1 pro8ects "
vi. Sample copies of the agreements that are re+uired to -e entered into -)
investors1applicants 0ith S$%'( at the time of 8oining S$%'(7s
'ro8ects1Schemes and certificates issued to the investors 0ho su-scri-e to such
schemes"
vii. %emorandum and *rticles of *ssociation ("M(A and A(A") of S$%'( as filed
0ith concerned 9egistrar of .ompanies ("R(C")"
viii. *nnual 9eturns 1 Balance Sheets and 'rofit and (oss *ccounts of S$%'( since
incorporation as filed 0ith the concerned 9o."
ix. 6etails of past and present promoters1directors1:e) management personnel of
S$%'(.

;. In response to the aforesaid letter" S$%'( vide letter dated 5ovem-er 13" #1!" interalia"
furnished the follo0ing documents4
i. *pplication forms for purchase of livestoc&"
ii. Sample cop) of <oat &eeping .ertificate"
iii. Sample agreement for <oat=:eeping
iv. (ocation of current or proposed pro8ects along 0ith the profit> loss statement"
v. %o* and *o* of S$%'( as filed 0ith 9o."
vi. (ist of 'romoters of S$%'("
vii. .op) of *nnual return of S$%'("
viii. 6etails of the 6irectors of S$%'(.

?. S$%'( has also made the follo0ing su-missions in the aforesaid letter 4
a! S"#P$ is engaged in rearing of livestock mainl% goats etc& for its customers& 'long (ith the rearing of
the livestock, S"#P$ has also been selling livestock to the customers for a consideration (herein the
purchaser has the option of keeping the purchased livestock (ith S"#P$ for breeding and rearing
purposes onl% for a period of )&* %ears as per the terms and conditions laid do(n in the application form
given to the purchaser at the time of purchase of the livestock& In case the purchaser of the livestock decides
to keep the same (ith S"#P$ for rearing, a Certificate of +oat keeping (ould be issued b% S"#P$
bearing a registration number against the goats (hich purchaser opted to keep (ith them&
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b! ,he livestock of the purchaser (as kept (ith S"#P$, solel% for the purpose of rearing, as per the terms
and conditions mentioned in the application form and agreed upon b% the purchaser at the time of the
purchase of the goats&
c! S"#P$ does not issue an% instruments in the form of bonds, shares or an% other financial instruments&
It has not introduced an% kind of investment scheme in the regular course of business and its area of
business (as mainl% limited to the breeding and keeping of the goats kept (ith them b% the purchasers&
d! ,he complainant has not invested an% amount for investment purposes, as alleged& ,he amount given b%
the complainant to S"#P$ (as solel% for the purposes of purchase of goats and as the complainant
chose to keep the purchased goats (ith S"#P$ for rearing purpose as per the terms and conditions in
the application form, accordingl% the goat keeping certificates (ere issued against the keeping and rearing
of the purchased goats& S"#P$ has in no (a% issued an% investment scheme or issued an% kind of
instruments against the same as alleged b% the complainant in its complaint or other(ise&
e! ,he location of current pro-ect and proposed development is .illage +ulalpur , ,ehsil /hanora, /strict
0&P& 1agar, "ttar Pradesh

@. I have carefull) considered the material availa-le on record" correspondence exchanged
-et0een SEBI and S$%'(" along 0ith the documents contained therein and information
furnished -) the complainant" su-missions made -) S$%'(" etc. In this context" the issue
for determination is 0hether the mo-iliAation of funds -) S$%'( under its schemes "Real
Step Pashupalan and Real Step Breeding Farm for sale, breeding, rearing & keeping of livestock "falls
under the am-it of 2collective investment scheme3 in accordance 0ith Section 11** of the SEBI
*ct" 133# (hereinafter referred to as "SEBI A%&").

B. 2n an examination of the material availa-le on record " it is prima facie o-served that4

a) S$%'( (.I54 $?133C9##'/.!;31) 0as incorporated on June 1!" ##
having its registered office at S.D E @B > @," Sector 1@*" 2pposite 5ehru .ollege"
Darida-ad" Car)ana. Its 6irectors are Car8it Singh 6hari0al ('*54 *6J'6##,;')
and 9agh-ir :aur (6I5 4 !@#;BB).

-) *s per the %o* of S$%'(" one of its other o-8ect is 4to carr% on the business as dealers
in and purchasers of dair% farms garden produce of all kinds and in particular milk , cream, butter ,
ghee, cheese, poultr%, eggs, fruits, vegetable oils, vegetable ghee, porkpies, sausages, pra(ns, potted
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meat, table delicacies and to purchase, ac5uire, keep maintain, breed, sell or other(ise dispose of all
kinds of cattles, co(s buffaloes, pigs, poultr% and live and dead stock of all description4&

c) S$%'( is engaged in the activities of trading of livestoc& carried out -) 9eal Step
'ashupalan E a unit of S$%'( ( herein after referred to as "RS9 S%.#6#" ) and
-reeding" rearing and &eeping of livestoc& carried out -) 9eal Step Breeding Darms E
another unit of S$%'( ( herein after referred to as "RSBF S%.#6#" )F /here are
t0o separate *pplication Dorms that are re+uired to -e filled -) the applicant one in
respect of purchase of livestoc& (i&e& one +oat ) and the other in respect of <oat
:eepingF

d) /he purchaser has the option of &eeping the purchased livestoc& 0ith S$%'( for
-reeding and rearing purposes for a period of three and half (!G) )ears. In case the
applicant exercises the option to &eep the purchased livestoc& 0ith S$%'(" the
applicant is mandated to sign on -oth the aforesaid application forms ( i.e.
application form for the purchase of livestoc& (i&e& one +oat) and application form in
respect of <oat :eeping) 0hich indicate its agreement to the terms and conditions in
regard to activities carried out under -oth schemes.

e) /he terms and conditions of the "RSBF Scheme4 as mentioned in the application form
is reproduced as under4
6& ,he applicant hereb% is an independent +oat 7s! 8(ner 7CIGOC! (ho (ants to keep his 9her
+oat7s! (ith RSBF for keeping and breeding purposes& ,he RSBF promises to pa%9give
appro:& ;<= of the breeding produce 7 i&e& offspring of the particular +oat provided b% the I+8
at the end of ) > %ears as selected b% the applicant& Rest appro:& ?<= shall be kept b% RSBF
for profit, rearing & keeping purpose&
@& ,he RSBF shall not in an% circumstances 9event be liable for pa%ment of an% damages in case
of failure to perform an% acts stated herein above (herein the said failure of as possible occurred
due to unforeseen reasons such as (ar, earth5uake and an% other natural calamities, etc& and
an% other reasons incidence be%ond control of the contractor
)& ,he I+8 shall not be pa%ing an% charges for the feeding, insurance, mediation, rearing or an%
other keeping purpose at all&
;& ,he I+8 can visit the RSBF to see the keeping progress of his9her +oat 7s! at his 9her o(n
cost (ith prior appointments onl%&
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*& ,he I+8 hereb% agrees that he9she is not at all in an% circumstances eligible to receive an%
monitor% benefits 9pa%ments before ) > %ears of surrendering his9her +oat 7s! at RSBF&
?& ,he I+8 hereb% agrees that he9she shall not demand an% monetar% proceeds 9pa%ments from
the RSBF before ) > %ears of surrendering his 9her +oat7s!& If I+8 demands so, it shall onl%
constitute a violation 9breach of the terms and conditions, b% virtue of (hich all the rights of the
applicant pertaining to the said +oat 7s! and the amount if an%, receivable b% the I+8 from
the RSBF shall be terminated automaticall% & the I+8 (ill have no claim (hatsoever against
the RSBF&
A& ,he I+8 hereb% declares that he9she has kept his9her +oat7s! (ith RSBF (ithout an% force,
pressure, and influences from an%one (hosoever&
B& 8nl% the RSBF is entitled to take all the benefits such as subsides , financial, ta: e:emptions
and all other such benefits likel% to be provided b% the +overnment 9state government or an%
other organiCation
D& RSBF reserves the right to amend , change or modif% the terms and conditions time to time and
all the updated terms (ill be posted on&
6<& ,he I+8 must claim his9her +oat7s! after completion of ) > %ears , (ithin ? months& 'fter ?
months he 9she (ill not liable to claim an% +oat 7s! and benefits &

,. /he features of the so=called "RSP and RSBF schemes for sale, breeding, rearing & keeping of
livestock "offered -) S$%'( have to -e considered in light of the provisions of Section 11**
of the SEBI *ct. /he aforesaid Section 11**" 0hich provides for the conditions to
determine 0hether a scheme or arrangement is a 'collective investment scheme'" reads as under 4

476! 'n% scheme or arrangement (hich satisfies the conditions referred to in subsection 7@! shall be a
collective investment scheme&
7@! 'n% scheme or arrangement made or offered b% an% person under (hich,E
7i! the contributions, or pa%ments made b% the investors, b% (hatever name called, are pooled and
utiliCed solel% for the purposes of the scheme or arrangementF
7ii! the contributions or pa%ments are made to such scheme or arrangement b% the investors (ith a vie(
to receive profits, income, produce or propert%, (hether movable or immovable from such scheme or
arrangementF
7iii! the propert%, contribution or investment forming part of scheme or arrangement, (hether identifiable
or not, is managed on behalf of the investorsF
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7iv! the investors do not have da% to da% control over the management and operation of the scheme or
arrangement&G

3. It is noted that when the activity of trading of livestock (RSP Scheme) is viewed in
conjunction with the activity of Breeding, Rearing and Keeping of Livestock (RSBF
Scheme) that an element of scheme in line with ection !!"" of the #BI "ct $ecomes
apparent% In this regard" the scheme of "RSP and RSBF schemes for sale, breeding, rearing &
keeping of livestock " offered -) S$%'( is examined as under 4
*'+ T.# %(!&$'@/&'(!), ($ 7,D6#!&) 6,"# @D &.# '!5#)&($), @D 2.,&#5#$ !,6#
%,33#", ,$# 7((3#" ,!" /&'3'=#" )(3#3D -($ &.# 7/$7()#) (- &.# )%.#6# ($
,$$,!1#6#!&E
S$%'( as part of its operations is accepting mone) from the applicant1
purchaser(s) along 0ith application form for purchase of livestoc& under its 4RSP
scheme4& It is noted from the application form that an amount of ` @"31=-) 0a)
of demand draft is mandated for 8oining the scheme. It is noted from the
su-missions of S$%'( that if an applicant1 purchaser exercises the option of
&eeping the livestoc& 0ith the compan) for -reeding and rearing purpose" the)
have to ma&e a separate application form for <oat :eeping under 4RSBF Scheme4.
/he applicant1purchasers of 4RSBF Scheme4 0ere given goat &eeping certificates in
respect of &eeping and rearing of the purchased goats. /he said certificate indicates
S$%'(Hs 0illingness to ma&e arrangements1tie=ups to0ards &eeping the livestoc&
for -reeding and &eeping purposes at its H'ssociates FarmsI. *t the end of three and
half (!G) )ears" the J'ssociates FarmsI 0ill return maximum upto four (;) <oats
to the respective o0ners. /he consideration for the services rendered -) S$%'( is
indicated in the form of retention 1 &eeping the rest of the &ids i.e. offspring of the
particular <oat provided -) Independent <oat 20ner (I<2)" -) the J'ssociates
FarmsI for -reeding" insurance" feeding medication" profits and other &eeping
purposes. S$%'(7s Balance Sheet as on %arch !1" #1 states that an amount of
`#1"31"@11= had -een received as advance from the .ustomers. It is noted from
the application forms that an amount of `@"31= is pooled from each
applicant1purchaser of RSP Scheme& *s the contri-utions received from the
investors1purchasers under its schemes are pooled for the purpose of the schemes"
prima facie it appears that the instant 7schemes7 satisfies the first condition stipulated in
Section 11**(#) of the SEBI *ct.
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*''+ T.# %(!&$'@/&'(!) ($ 7,D6#!&) ,$# 6,"# &( )/%. )%.#6# ($ ,$$,!1#6#!& @D
&.# '!5#)&($) 2'&. , 5'#2 &( $#%#'5# 7$(-'&), '!%(6#, 7$("/%# ($ 7$(7#$&D, 2.#&.#$
6(5,@3# ($ '66(5,@3# -$(6 )/%. )%.#6# ($ ,$$,!1#6#!&E
It is noted from the terms and conditions of the application form for "RSBF
Scheme" that S$%'( ena-le returns ( -reeding produce ) at the ratio of ;4@
-et0een "RSBF" and the applicant1purchaser. It also confers an option to the
applicant1purchaser(s) to surrender the <oat(s) and receive -enefits on completion
of three and half (!G) )ears under "RSBF Scheme"(Clause 6). Besides this" it is noted
from the complainant7s letter dated 5ovem-er ##" #1# addressed to the S$%'(
that a demand had -een made to handover of a certain num-er of goats &ept under
supervision or to refund amount pertaining to the such num-er of goats at
prevailing mar&et price as per the schemes . /he same corro-orates the aspect of
optional redemption of certificate issued -) "RSBF Scheme" at prevailing mar&et
price clearl) indicates returns 0hile contri-utions are accepted. In light of the
aforesaid" prima facie the nature of -enefits receiva-le -) the applicant 1 purchaser
at the end of the term of their contractual relationship under "RSBF Scheme"
indicates an element of return for 0hich mone) has -een provided -) the investors
to S$%'(. Cence" the second condition" 0hich stipulates that the contri-utions
or pa)ments are made to such scheme or arrangement -) the investors 0ith a vie0
to receive profits" income" produce or propert) as stipulated in second condition in
Section 11** (#) of the SEBI *ct is also fulfilled.
*'''+ T.# 7$(7#$&D, %(!&$'@/&'(! ($ '!5#)&6#!& -($6'!1 7,$& (- )%.#6# ($
,$$,!1#6#!&, 2.#&.#$ '"#!&'-',@3# ($ !(&, ') 6,!,1#" (! @#.,3- (- &.# '!5#)&($)E
*'5+ T.# '!5#)&($) "( !(& .,5# ",D &( ",D %(!&$(3 (5#$ &.# 6,!,1#6#!& ,!"
(7#$,&'(! (- &.# )%.#6# ($ ,$$,!1#6#!&.
*s per the terms and conditions stated on the application form for <oat :eeping"
an applicant1purchaser unconditionall) authoriAe "RSBF Scheme" to ta&e all the
necessar) and appropriate decision as regards -reeding" rearing and other &eeping
purposes in respect of applicant7s <oat(s). *s regards pa)ment of an) charges for
feeding" insurance" medication" rearing or an) other &eeping purpose of <oat(s)"
S$%'( manage the same for and on -ehalf of purchasers1investors. Sole
entitlement to the accretions i.e. o0nership and ph)sical custod) of the offspring
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etc. of the said <oat(s) is 0ith S$%'(. Similarl)" -enefits routinel) lin&ed to
o0nership such as su-sidies" financial" tax exemptions and all other such -enefits
li&el) to -e provided -) the government1 state government or an) other
organiAation are solel) conferred upon S$%'(. In light of foresaid and as per the
terms" the management of goats under the said schemes is solel) conferred on
S$%'( . In these facts and circumstances" it is clear that S$%'( manages the
propert)" contri-ution or investment forming part of "RSP and RSBF schemes for sale,
breeding, rearing & keeping of livestock "on -ehalf of its *pplicant1purchaser.

*s per the terms and conditions of application form for "RSBF Scheme"" it appears
that S$%'( is solel) managing the affairs of its schemes and the investors do not
have an) sa) 0hatsoever. /his can -e seen from the follo0ing clauses viA." .lause @
states "the I+8 hereb% agrees that he9she shall not demand an% monetar% proceeds 9pa%ments
from the RSBF before )> %ears of surrendering his 9her +oat7s!& If I+8 demands so, it shall
onl% constitute a violation 9breach of the terms and conditions, b% virtue of (hich all the rights of
the applicant pertaining to the said +oat 7s! and the amount if an%, receivable b% the I+8 from
the RSBF shall be terminated automaticall% & the I+8 (ill have no claim (hatsoever against
the RSBF&"*s per .lause 3 "RSBF reserves the right to amend , change or modif% the terms
and conditions time to time4. .lause 1 states that "the I+8 must claim his9her +oats7s!
after completion of )> %ears , (ithin ? months& 'fter ? months he9she (ill not be able to claim
an% +oat 7s! and benefits4& In vie0 of a-ove" it is clear that the *pplicant1purchaser
do not have da) to da) control over the management and operation of the scheme
of "RSP and RSBF schemes for sale, breeding, rearing & keeping of livestock ". I" therefore"
find that the instant 'Schemes' satisfies the third and fourth condition stipulated in
Section 11**(#) of the SEBI *ct.

1. In this context" it ma) -e relevant to refer to the o-servations made -) the ConH-le Supreme
.ourt of India in P&+&F& $imited & 8rs& .s& "8I & 'nr& 7#'1"9SC&<@;A9@<6)!, (herein it
(as statedI H&&&subsection 7@! of Section 66'', (hich defines a collective investment scheme disclose that it is
not restricted to an% particular commercial activit% such as in a shop or an% other commercial establishment or
even agricultural operation or transportation or shipping or entertainment industr% etc& ,he definition onl%
seeks to ascertain and identif% an% scheme or arrangement, irrespective of the nature of business, (hich attracts
investors to invest their funds at the instance of someone else (ho comes for(ard to promote such scheme or
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arrangement in an% field and such scheme or arrangement provides for the various conse5uences to result
therefrom&G

11. In light of the a-ove anal)sis and examination" it appears that the activit) of fund
mo-iliAation -) S$%'( camouflaged in "RSP and RSBF schemes for sale, breeding, rearing &
keeping of livestock" 0ith a resultant promise of returns 0hen considered in light of its peculiar
characteristics and features" as discussed in the preceding paragraphs" prima facie satisfies all
four conditions specified in Section 11** (#) of the SEBI *ct and hence falls 0ithin the
am-it of 'Collective Investment Schemes' as defined under Section 11** of the SEBI *ct.

1#. I note that in terms of Section 1#(1B) of the SEBI *ct" 4no person shall sponsor or cause to be
sponsored or cause to be carried on a 'collective investment scheme' unless he obtains a certificate of registration
from the Board in accordance (ith the regulationsG. 9egulation ! of the SEBI (.ollective Investment
Schemes) 9egulations, 6333 (hereinafter referred to as CCIS R#1/3,&'(!)C) also prohi-its
carr)ing on .IS activities 0ithout o-taining registration from SEBI. /herefore" the
launching1 floating1 sponsoring1causing to sponsor an) 'collective investment scheme' -) an)
'person' 0ithout o-taining the certificate of registration in terms of the provisions of the .IS
9egulations is in contravention of Section 1#(1B) of the SEBI *ct and 9egulation ! of the
.IS 9egulations. In this regard" I note that S$%'( has not o-tained an) certificate of
registration from SEBI under the .IS 9egulations for its fund mo-iliAing activit) from the
pu-lic" under the instant 'Schemes' offered -) it.

1!. I also find that the fund mo-iliAing activit) of S$%'( through its "RSP and RSBF schemes for
sale, breeding, rearing & keeping of livestock "" prima facie" amounts to a fraudulent practice in terms
of 9egulation ;(#)(t) of the SEBI ('rohi-ition of Draudulent and $nfair /rade 'ractices
9elating to Securities %ar&et) 9egulations" #! ("9FUT9 R#1/3,&'(!)").

1;. 'rotecting the interests of investors is the first and foremost mandate for SEBI and
therefore" steps have to -e ta&en to ensure that S$%'( does not collect further funds under
its schemes and no investors are defrauded. Drom the materials availa-le on record" it is
o-served that Car8it Singh 6hari0al ('*5 4 *6J'6##,;') and 9agh-ir :aur (6I5 5o.
!@#;BB) are the present 6irectors 0ho 0ere in charge of and responsi-le for the da) to
da) affairs of S$%'(. Durther" in order to safeguard the assets1propert)" ac+uired -)
S$%'( and its 'romoters16irectors using the funds collected from the investing pu-lic
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until full facts and materials are -rought on record and a final decision is ta&en in the matter"
it is incum-ent on SEBI to ta&e preventive action -) 0a) of an immediate measure. In the
light of the same and as S$%'( failed to su-mit complete details1information as sought -)
SEBI" I find no other alternative -ut to ta&e recourse through an interim order against
S$%'( and its 6irectors for preventing them from further carr)ing on 0ith its existing fund
mo-iliAing activit) -) launching 2collective investment scheme3 0ithout registration from SEBI in
accordance 0ith la0.

1?. In vie0 of the foregoing" I" in exercise of the po0ers conferred upon me under Sections
11(1)" 11B and 11(;) of the SEBI *ct" 133# read 0ith 9egulation @? of .IS 9egulations and
'D$/' 9egulations" here-) direct S$%'( and its 6irectors viA." Car8it Singh 6hari0al
('*5 4 *6J'6##,;') and 9agh-ir :aur (6I5 4 !@#;BB) 4
not to collect an% fresh mone% from investors under its e:isting schemesF
not to launch an% ne( schemes or plans or float an% ne( companies to raise fresh mone%sF
to immediatel% submit the full inventor% of the assets including land obtained through mone% raised
b% S"#P$F
not to dispose of an% of the properties or alienate the assets including land obtained directl% or
indirectl% through the mone% raised b% S"#P$F
not to divert an% funds raised from public at large, kept in bank account7s! and9or in the custod% of
S"#P$F
to furnish all the information9details sought b% SJBI (ithin 6* da%s from the date of receipt of this
order, including,
i& /etails of amount mobiliCed and refunded till date,
ii& Scheme (ise list of investors and their contact numbers and addresses,
iii& P'1 of /irectors of S"#P$ and
iv& 'udited accounts for the past three %ears&

1@. /he a-ove directions shall ta&e effect immediatel) and shall -e in force until further orders.

1B. /his order is 0ithout pre8udice to the right of SEBI to ta&e an) other action that is deemed
fit to -e initiated against S$%'( and its 6irectors in accordance 0ith la0.


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1,. /he prima facie o-servations contained in this 2rder are made on the -asis of the materials
availa-le on record. In this context" S$%'( and its a-ovementioned 6irectors ma)" 0ithin
1? da)s from the date of receipt of this 2rder" file their repl)" if an)" to this 2rder and ma)
also indicate 0hether the) desire to avail themselves an opportunit) of personal hearing on a
date and time to -e fixed on a specific re+uest made in that regard.





93,%#: M/6@,' S. RAMAN
D,&#: A/1/)& 22, 2014 WHOE TIME MEMBER
SECURITIES AND EXCHANGE BOARD OF INDIA

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