A PROJECT ON:

Law relating to promoters of a Company

duties and liabilities- An analysis

SUBMITTED TO:

Ms. Navita Aggarwal

(Faculty of Corporate Law I)

SUBMITTED BY:

Prashant Kerketta

ROLL NO. 119

SEMESTER-V

HIDAYATULLAH NATIONAL LAW UNIVERSITY, RAIPUR (C.G.)

1
 ACKNOWLEDGEMENTS

I take this opportunity to express my profound gratitude and deep regards to my teacher

Ms. Navita Aggarwal for his exemplary guidance and encouragement throughout the course of

this project. The blessing help and guidance given by him time to time shall carry me a long way

in the journey of life on which I am about to embark.

I also take this opportunity to express a deep sense of gratitude to IT lab staff and library

staff for their cordial support, valuable information and guidance which helped me in completing

this task efficiently.

Lastly, I thank almighty, my family and friends for their constant encouragement and

help without which this assignment would not be possible.

Prashant Kerketta

Batch 13

2
 RESEARCH METHODOLOGY

Aims and Objectives:

The aim of the project is to present a detailed study of the topic promoters through decisions and
suggestions and different writings. The aim has been to come to a conclusion very much indigenous.

Scope and Limitations:

Though the topic role of promoters is a project which can be written pages. Because of certain restrictions
and limitations researcher is constrained to the availability of the material.

Sources of Data:

The following secondary sources of data have been used in the project-

1. Books

2. Website

Method of Writing and Mode of Citation:

The method of writing followed in the course of this research paper is primarily analytical. The researcher
has followed Uniform method of citation throughout the course of this research paper.

3
 TABLE OF CASES

1. Bosher v Richmond Land Co, 89 Va 455 (16) SE 360

2. Emma Silver Mining Co v Lewis, (1879)4 CPD 396
3. Erlangerv New SombreroO Phosphate Co., (1878) 3 App Cas 1218
4. Gluckstein V Barnes, [1900] AC 240
5. Gomba Holdings U.K v Homan , [1986] 3 All ER 94 Ch D
6. Great Wheal Polgooth Ltd, Re, (1883) 53 LJ Ch. 42.
7. Kelner v. Baxter, (1866) LR 2 CP 174
8. Re Leeds & Hanley Theatres Of Varities Ltd.(1902), [1902] 2 Ch 809. 210.
9. Tengku Abdullah v Mohd Latiff bin Shah Mohd,[1996] 2 MLJ 265
10. Tracy v Maandalay (1952-53) 88 CLR 215
11. Tycross v Grant, [1877] CPD 469
12. Whaely Bridge Calico Printing Co v Green , (1880) 5 QBD 109
13. Fairview Schools Sdn. Bhd v Indrani [1998] 1 MLJ 110

LIST OF ABBREVIATIONS

1. AC- Advance California Reports

2. All ER – All England Reporter
3. App Cas- Law Reports, Appeal Cases
4. Ch - Chancery
5. CLR- Clarke New York Chancery Reports
6. CPD- Cape Provincial Division Reports
7. LR- Law Reporter
8. MLJ -Madras Law Journal
9. QBD- Queen’s Bench Division
10. SE-South Eastern Reporter

4
 Table of contents

 Introduction………………………………………………………………………………….…6

 Definition………………………………………………………………………..……….7
 Functions……………………………………………………………………………..………..8
 Types of promoters………………………………………………………………….………..9
 Stages of promotion……………………………………………………………….………….10
 Relationship with the company…………………………………………………..…………..11
 Position of a promoter…………………………………………………………….………….12
 Remuneration……………………………………………………………………………..…..13
 General duties……………………………………………………………………………..…..13
 Liability for pre incorporation contracts……………………………………………….…….14
o Comparison of laws………………………………………………………….……….14
 Rewards…………………………………………………………………………….………….15
 Indian law…………………………………………………………………………….……….15
o Specific Relief Act, 1963…………………………………………………………….16
o Novation of contract………………………………………………………….………17
 U.s law………………………………………………………………………………..………..17
 English law…………………………………………………………………………….………17
 Conclusion……………………………………………………………………………….……18
 Bibliography……………………………………………………………………………….….19

5
 INTRODUCTION

I didn’t grasp the basic principle of being a promoter, which was; put on music but also generate an
income. I was on the dole most of the time.

-Alex (musician)

Like this quote, all the concentration of a person should not just be on doing something. He must also
concentrate on letting people know that he has done something. When a person starts a company, public
or private, it is very essential that the people come to know about the company. They must be made aware
that a new company has come into existence. They must be informed that they now have wider options. In
the case of a public company it is even more essential that the people are made aware of the new
company. It’s because the more people come to know, the more are the chances of people investing in the
company build its share capital.

This is done through advertisement. The company is brought to the knowledge of people through
advertisements in the media-newspapers, magazines, internet, television etc. The goodwill of the
company must be built up and that can happen only when many people know about the company and start
trusting it. They will start trusting in it only when the company makes some progress and when the
progress is made known to the public.

Puffery statements, exaggeration and falsification do not build up the image of the company but degrades
it. So a company must take reasonable care while promoting herself. As it is a very essential and
important job of a company, it must be done with a lot of circumspection.

Since the job is very sensitive one, it is handled by those people who are specialized in image building. In
the business fraternity, they are called “PROMOTERS”. A promoter, although the term creates
connotations of someone in the building and construction industry, is actually a generic term associated
with the person who starts a business. In common parlance, this person is also referred to as the founder
of the business.

A promoter typically is responsible for raising capital, targeting initial leads and chasing initial business
opportunities, entering into the initial contracts for the business formation and incorporating the company.
A promoter conceptualizes the idea of a company and the purpose of its formation. The promoter acquires

6
and invests the initial capital for the company. Once all the formalities are completed, the promoter hands
over the authority to the directors. A promoter can be a person or a registered company as well.

A promoter is

(a) Any person who is in control of the target company

(b) Any person named as promoter in any offer document of the target company or any
shareholding pattern filed by the target company with the stock exchanges pursuant to the listing
agreement, whichever is later1;

So the logical meaning of this is that although the promoter ordinarily means the person who started the
company, in certain exceptional cases, it can even mean the person who is in control of the company even
if he / she did not actually start the company. A common doubt most people have with regard to a
promoter is with reference to the contracts, documentation and expenses incurred by the promoter prior to
the incorporation of the company -these are called “pre-incorporation expenses” and most people want to
know how they can be recovered from the company after the incorporation.

 DEFNITION

There is no strict definition of a promoter defined under the company laws of any country in the world.
The definition is mostly deduced through the case laws and circumstances. The difficulties in defining the
term led judges to state that the term ‘promoter’ is not a term of art, nor a term of law, but of business 2.
The emphasis upon its business implication is quite apparent from the statement of Bowen LJ that the
term is used to sum up “in a single word a number of business operations, familiar to the commercial
world, by which a company is generally brought into existence”3.

In Tengku Abdullah v Mohd Latiff bin Shah Mohd4, Gopal Sri Ram JCA said: “A promoter is one
who starts off a venture-any venture-not solely for himself,
but for others, but of whom, he may be one.”

Companies Act, 2013 defines- promoter to mean a person –

1
SEBI (Substantial Acquisition of Shares and Takeovers) Regulation, 1997

2
Gomba Holdings U.K v Homan , [1986] 3 All ER 94 Ch D
3
Whaely Bridge Calico Printing Co v Green , (1880) 5 QBD 109
4
[1996] 2 MLJ 265

7
(a) who has been named as such in a prospectus or is identified by the company in the annual return, or

(b) who has control over the affairs of the company, directly or indirectly whether as a shareholder,
director or otherwise; or

(c) in accordance with whose advice, directions or instructions the Board of Directors is accustomed to
act.

Provided that nothing in sub-clause (c) shall apply to a person who is acting merely in a professional
capacity

Most of the definitions are in terms of categories of work that the promoters usually perform. “A
promoter is a person who brings about the incorporation and organization of a company. He brings
together the persons who become interested in the enterprise, aids in procuring subscriptions, and sets in
motion the machinery, which leads to the formation itself.”5

“A promoter is one who undertakes to form a company with reference to a given project and to set it
going, and who takes the necessary steps to accomplish that purpose”.6 The term therefore has no very
definite meaning7. Whether a person is a promoter or not is a question of fact in each case. Much depends
upon the nature of the role played by him in the promotion of business.

A solicitor is not a promoter8. A person may help in getting a purchaser of the company’s patent or of
shares, or in getting personnel for the company. Any such role may make him promoter 9. “A promoter is
one who starts off a venture-any venture-not solely for himself, but for others, but of whom, he may be
one”10.

 FUNCTIONS

The general functions of a promoter are:

 Conceptualizing the scheme of company formation.

 Finalizing the name of the company and getting it registered.

5
Bosher v Richmond Land Co, 89 Va 455 (16) SE 360
6
Tycross v Grant, [1877] CPD 469
7
Emma Silver Mining Co v Lewis, (1879)4 CPD 396
8
Great Wheal Polgooth Ltd, Re, (1883) 53 LJ Ch. 42.
9
Tracy v Maandalay (1952-53) 88 CLR 215
10
Tengku Abdullah v Mohd Latiff bin Shah Mohd,[1996] 2 MLJ 265

8
 Filing the important documents, such as Memorandum and Articles of association with the
Registrar.

 Getting the consent of the director before finalizing the nomination.

 Completing the formalities regarding the nomination of directors, secretary, etc.

 Organizing the printing of Memorandum and Articles.

 Handling the complete procedure for the registration of the company.

 Handling the details relating to the prospectus.

 Making necessary appointments of lawyers, bankers and agents.

 Obtaining the co-operation of all the people who are associated with the company.

 TYPES OF PROMOTERS11

1. Professional Promoters:
They are experts who specialize in company promotion. They float the company and hand it over to the
shareholders or their representatives. Promotion is their main profession or occupation.

2. Occasional Promoters
There promoters take interest in floating some companies. They are not engaged in promotion work on a
regular basis. They take up the promotion of some company and once it is over they go to their original
profession. For instance, engineers, etc. may float some companies.

3. Entrepreneur Promoters
They are both promoters and entrepreneurs. They conceive idea of a new business unit, do the
groundwork to establish it and subsequently become a part of the management.

4. Financer Promoters
Some financial institutions, like investment banks or industrial banks, may take up the promotion of a
company with a view to finding opportunities for investment.

11
Company Law and Practices – by D.P Mittal 2nd Edition

9
 STAGES OF PROMOTION12

1. Discovery of business.
The first stage in company promotion is the conception of a new idea. It is the promoter who conceives
the idea of setting up a business. If makes an assessment of the viability of a particular business.

2. Detailed investigation.
Promoters undertake a detailed investigation of the viability, profitability and future prospects of the
growth of the proposed activity. To assist then in this venture, they seek the help of specialists such as
chartered Accountants, Cost Accountants, Company Secretary, Engineers. Organizations engaged in
market research and other specialized agencies. Specialists are in a position to make an objective analysis
of their own areas which may help the promoters. Decisions have to be taken regarding the size, location,
layout, man power etc.

3. Assembling the factors of production

If the proposed endeavor gives promise of success and the promoter is willing to undertake the risk of
forming the business, steps must be taken to assemble various factors of production viz, land, labour,
capital and managerial personnel. Assembly of resources involves making contracts for the purchase of
material, land, machinery, etc.

4. Entering into preliminary contracts

The promoter enters into contracts with different parties before the registration of the company. After
registration, the company approves these contracts.

 RELATIONSHIP WITH THE COMPANY

Relationship between a company and a promoter is fiduciary .He is bound to disclose all the accounts and
other contracts he entered into before incorporation of the company to an independent and competent
board of directors so that he may be held accountable for any ill gained profits and may be held
accountable for them before the board. The following are some of the fiduciary duties that the Courts will
insist that a Company promoter has to observe.

1. Top of the list is not to make a secret profit at the expense of the company

12
Guide to Companies Act- by A. Ramaya 15th Edition 2001

10
 2. A duty to account to the company for the benefit for any property he might Purchase with the
intent of selling the property to Company for a profit later.
3. A duty not to defraud the Company by active concealment of any affairs relating to the company
4. A duty not to disclose confidential information to outsiders
5. A duty not to hide his personal interests through a nominee.
A Promoter is in a fiduciary relationship with the Company he promotes and as such he owes fiduciary
duties towards it. This means that he is in a position of trust and must at all time act honestly and in good
faith for the Company as a whole. However, the most important aspect of his duty is not to make a secret
profit at the expense of the Company. In the case of Fairview Schools Sdn. Bhd v Indrani13 Mahadev
Shanker JCA said, “Promoters have a legal duty not to make a secret profit out of the promotion of the
Company without the Company's consent and also to disclose to the Company any interests the promoters
have in any transaction proposed to be entered into by the Company”.

There are many cases where Promoters did not remain true to their fiduciary duties. The bottom-line
requirement from Promoters is that they must be transparent in their dealings with the Company.

There are three remedies in situations where the Promoters have breached the Fiduciary Duties.

1. RESCISSION
If the Company has entered into a Contract with the promoter and it is later discovered there had been no
transparency, the Company is entitled to rescind the contract. It is irrelevant that the promoter has made
no profit from the contract.S17 Contracts Act states that non-disclosure amounts to a fraud and by Sect 19
the Contract becomes voidable.

Under Sec 34(1) Specific relief Act 1950 the Company can apply to the Court to rescinded the contract.
Once the contract is rescinded, restitution has to take place. This is where the Company has to return
whatever it received from the Promoter and the Promoter has to return all monies received from the
company.

ERLANGER v NEW SOMBRERO PHOSPHATE CO14

In this case, Erlanger bought an island containing phospates for 55,000 pounds. Later, Erlanger promoted
a Company and sold the property to it for 110,000 pounds. All the Directors of that Company were
nominees of Erlanger and two of them were directly under his control. Later the old board was replaced
by a new board which brought an action to rescind the contract with Erlanger.

13
[1998] 1 MLJ 110
14
(1878) 3 App Cas 1218

11
The Court held that there had been no adequate disclosure of the circumstances of the sale and the
Company was entitled to rescind the contract.

2. RECOVERY OF THE SECRET PROFIT

GLUCKSTEIN Vs BARNES15

In this case the Defendants bought debentures cheaply in a Company at a time when the Company was
faring very badly. Later they bought over the Company for 140,000 pounds. The debentures were
redeemed at full value and they made a good profit. Here they made a profit of 20,000 pounds. Later still,
they formed another company and sold the Company to a new Company at a profit of 40,000 pounds.
This profit was disclosed in the prospectus but not the amount of profit they made on the redemption of
the debentures. (20,000 pounds)

The Court held that there were in breach of their duties as promoters and the Company was entitled to
recover the profit from them. The Company can recover the secret profit even though they chose not to
rescind the contract. The liability of the promoters is “joint or several”. A Promoter who is found liable
may recover contributions from the other promoters.

3. DAMAGES FOR BREACH OF FIDUCIARY DUTIES.

In the case of RE LEEDS & HANLEY THEATRES OF VARIETIES LTD16 the Court ordered the
Promoter to pay damages to the Company. The Court held that the Promoters had fraudulently omitted to
disclose the profit made by them on the sale of the property to the Company. The amount of damages was
equivalent to the amount of profit made by the promoters.

 POSITION OF A PROMOTER17

A promoter is not an agent for the company, which he is forming because a company cannot have an
agent before it comes into existence. For the same reason he cannot be the trustee of the company.
However from the moment he acts with the company in mind, a promoter stands in a fiduciary position
towards the company. Lord cairns had correctly stated the position of a promoter in Erlanger v. new
sombrero phosphate co.18 “The promoters of a company stand undoubtedly in a fiduciary position. They

15
[1900] AC 240
16
[1902] 2 Ch 809. 210
17
COMPETETION LAW at a glance By: Amitabh Kumar

18
Supra no 12

12
have in their hands the creation and molding of the company. They have the power of defining how, and
when, and in what shape and under what supervision, it shall start into existence and begin to act as a
trading corporation.”

 REMUNERATION

The nature of the promoters work in the formation of a company calls for considerable skill for which he
should be adequately remunerated. A promoter has no right against the company for his remuneration
unless there is a contract to that effect. In the absence of such a contract, he cannot even recover from the
company payments he has made in connection with the formation of the company.

 GENERAL DUTIES19

A promoter’s general duties are:

1. Initiator
The promoter originates the scheme for the formation of the company, he gets memoranda and articles
prepared, executed and registered and he deals with merchant bankers, brokers and legal advisors.

2. Fiduciary Agent
Promoter stands as a fiduciary agent of a company. As a fiduciary agent, a promoter should fulfill the
following duties:

i) He should make all disclosures regarding accounts and formation so as to maintain transparency at the
time of transfer of management to the director.

ii) He should not make any secret profit out of promotion of the company.

iii) He should make all disclosures regarding transactions entered by him on behalf of the company as
promoter.

In case of default on the part of the promoter in fulfilling the above duties, the company may:-

19
COMPETETION LAW at a glance By: Amitabh Kumar

13
1. Rescind or cancel the contract made and if he has made profit on any related transaction, that profit
also may be recovered.

2. Retain the property paying no more for it then what the promoter has paid for it depriving him of the
secret profit.

3. If these are not appropriate, the company can sue him to for breach of trust. Damages upto the
difference between the market value of the property and the contract price can be recovered from him.

 LIABLITY FOR PRE INCORPORATION CONTRACTS

Generally under common law, if a promoter entered into a contract before the incorporation of the
company for the company, the promoter will be held personally responsible for the contract. This rule was
laid down on the concept that, a company cannot be held liable for an act done before its coming into
existence. However today there are many exceptions to his rule under Indian law, American law and the
English law (to a very little extent).

a) Comparison of laws
Although under the English Common Law, the American law and the Indian Law recognize the rule that
promoter is personally liable for pre-incorporation contract, American Laws and Indian laws are much
more innovative and effective to solve the problem of Pre-incorporation Contract. Whereas the English
Courts still follow the principle of Kelner v. Baxter20. Although in UK, Contracts (Rights of Third
Parties) Act 1999 brought some relief, but it is not as broad as the American and Indian Laws are.

Under English Common Law, the ratification or adoption, after the incorporation, did not release the
promoter from liability of pre-incorporation contract. Whereas in American Court recognize that if the
after the incorporation company can ratify or adopt the contract, and this would bound the company and
not the promoter. Indian Law the rule of Kelner v Baxter21 is applicable but under the Specific Relief
Act 1963, section 15(h) and 19(e) promoter can shift his right and responsibility to the company, if it is
warranted by the terms of incorporation. The principle of novation of pre-incorporation contract is
applicable in above three counties, the reason behind is that, the novation replace the old contract with the
new contract, so there is not problem of non-existence of company. Now after the Contracts (Rights of

20
(1866) LR 2 CP 174

21
Ibid

14
Third Parties) Act 1999, English laws may also allow company to become the part of pre-incorporation
contract, when it acquire its legal existence.

 REWARDS

For the efforts put in by the promoters in promoting the company, the promoters may be rewarded in the
following ways:

 The company may to pay some remuneration for the services rendered.
 The promoter may make profits on transactions entered by him with the company after making
full disclosure to the company and its members.
 The promoter may sell his property for fully paid shares in the company after making full
disclosures.
 The promoter may be given an option to buy further shares in the company.
 The promoter may be given commission on shares sold.
 The articles of the Company may provide for fixed sum to be paid by the company to him.
However, such provision has no legal effect and the promoter cannot sue to enforce it but if the
company makes such payment, it cannot recover it back.

15
  INDIAN LAW

The Indian law i.e., the Companies Act 1956 does not define a promoter. It mentions only the liabilities of
a promoter. Sections 56, 62, 63, 203, 478, 542 and schedule II of the Act speak about promoters.

1. Section 56 lays down matters to be stated and reports to be set out in the prospectus. He may be
held liable for the non-compliance of the provisions of this section.
2. Under section 62, a promoter is liable for any untrue statement in the prospectus to a person who
has subscribed for any shares or debentures on the faith of the prospectus. Such a person may sue
the promoter for compensation for any loss or damage sustained by him.
3. Besides civil liability, the promoters are criminally liable under section 63 for the issue of
prospectus containing untrue statements. Section 68 imposes severe penalty on promoters who
make untrue and deceptive statements in a prospectus with a view to obtaining capital.
4. Section 478 says that a promoter may be liable to public examination like any other director or
officer of the company if the court so directs on a liquidators report alleging fraud in the
promotion or formation of the company.
5. A company may proceed against a promoter on action for deceit or breach of duty under section
543, where the promoter has misapplied or retained any property of the company or is guilty of
misfeasance or breach of trust in relation to the company.
6. If any promoter is found to be involved in an activity which amount to an offence regarding
promotion, management or formation of a company, the court can bar such a promoter from
taking part in the administration of the company for five years-Section 203.
7. In the course of winding up a company, if it appears that any business of the company has been
carried on with an intention of defrauding the creditors, the court can declare those people who
were knowingly parties to the carrying of that business shall be personally liable – Section 542.

a) Specific Relief Act 1963

There is some scope for the promoter to shift his liability to company in a pre- incorporated contract. He
can shift to company his liability under the Specific Relief Act 1963 or he can go for novation under
contract law.

Under the Specific Relief Act 1963, section 15(h) and 19(e) are the two important sections for pre-
incorporation contract. Section 15 is about stranger's right to sue if he entitled to a benefit or has any
interest under the contract, although it has certain limitation. Section 15(h) talks about the company, being
a stranger to pre-incorporation contract, has the right to sue to the other contracting party.

16
But the necessary condition is that the contract should be warranted by the terms of its incorporation. This
provision clearly negates the common law doctrine, which says that the company cannot ratify or adopt
the pre-incorporation contract. Under this provision promoter can give his right to sue to sue to the
company.

Section 19(e) states that the company can be sued by the other party of pre-incorporation contract, if the
terms of incorporation warrant and adopt the contract. This provision reduces the promoter of liability of
pre-incorporation contract.

b) Novation Of Contract
In the situation of Novation of Contract, the Company can replace the promoter from the pre-
incorporation contract. But one might say that such contract would not be called pre-incorporation
contract, but it should be called post-incorporation contract; because novation of contract result into a new
contract.

 ENGLISH LAW

The word promoter is not defined under the English law also. Sec 43, 51 of the Companies Act, 2006
talks about promoters. They talk about execution and pre incorporation contracts respectively. According
to Chitty on Contract, even in equity the company cannot be held liable for pre-incorporation contract.
Generally, any person who plays a major part in forming a company or establishing its business (usually
the prospective owners or directors of the company). Where any trading takes place on behalf of the
company, before the certificate of incorporation is issued, any person who purports to act for or as agent
of a company before the company has been formed will be personally liable for any contract they make
on behalf of the company (section 51, Companies Act 2006).

 U.S LAW

According to Securities Exchange Commission Rule 405(a) a promoter is a person who, acting alone or in
conjunction with another person directly or indirectly takes the initiative in founding or organizing the
business enterprise. Delaware General Corporation Law (Delaware Code 1956 amended), Ch. 339 section
101(6) – Promoters contract-corporations can adopt contracts made by promoters for its benefit, although

17
such contract antedates corporation’s existence22. Sec 101(7) Promoters liabilities-Promoters must
account to secret profits obtained at its expense and surrender for cancellation of shares representing
secret profits23.

22
Commissioner of Lewes v Breakwater Fisheries Co. 117 A 823 (Ch Ct 1922)
23
RE Bribeck v Am Toll Bridge Co Cal A2d 158 (Ch Ct 1938)

18
 CONCLUSION

Hence, it’s very clear that, for a company to prosper and develop, establishment is just not enough. Its
promotion is also equally important. The promotion of the company should be done in such a way as to
benefit the company. But that does not mean than the company members of promoters falsify facts with a
mala fide intention of securing investments in the company. A promoter of a company holds a very prime
position in the company and is expected to be in a fiduciary relationship with the company. He must be
extremely honest and loyal the company and must work for the profits of the company pushing aside his
personal profits with company money. For any development made to the company, he can be rewarded by
the company and for any default activities, he can be made liable for those activities and his contract can
be rescinded. In the case of Pre-incorporated contracts, he is personally liable for all those contracts
entered into on behalf of the company without its knowledge and not ratified later by the company.

Therefore a promoter is a key player in the game of corporate business whose every step is counted as a
lifeline of the company and every bad move can collapse the entire edifice of the company or him
personally.

19
 References : Books and Websites

 Company Law and Practices – by D.P Mittal 2nd Edition

 Mannual of SEBI ,2000
 Competition Law in India – by Oxford T. Ramappa
 The Company Law 10th Edition Vol 1- Wadhwa and Company
 Guide to Companies Act- by A. Ramaya 15th Edition 2001
 Taxmann‟s Companies act with case laws reffered [1913- 2007] 5th Edition 2008
 COMPETETION LAW at a glance By: Amitabh Kumar
 Securities And Exchange Board of India (INTERMEDIARIES)Regulations, 2008
 Securities Contract(REGULATION) ACT, 1956

20