BEFORE THE SECURITIES APPELLATE TRIBUNAL MUMBAI Date : 22.10.2019 Appeal No. 281 of 2018

1. Suchitra Dhanani (Suchitra Udar) (Jamila S Dhanani)

2. Bharat Equity Services Ltd.

3. Liberty Construction & Leasing Pvt. Ltd.

4. Habibunisha Dhanani

5. Kayum Dhanani

6. Gulshan I Memon

7. Shamim Dhanani (Shamim Shaikh)

8. Shaji Nair

9. Subhash Pandit

10. Abbas A. Shaikh

11. Abdul Razak Dhanani

12. Sadika Md I Memon (Sadika Md Ismail Memon)

13. Mansoor I Memon

14. Anisha Dhanani

15. Akitabanu Md Ismail Menon

16. Akshay S Udar

17. Rohini S Udar

18. Munawar Garbadwala

19. Aries Hotel Pvt. Ltd.

20. Rabia Razak Dhanani (Rabiabai Dhanani)

21. Nasim R Dhanani (Nasim Desai)

22. Ahilya Hotels Ltd.

23. Bipasha Dhanani

Ahilya Hotesl Ltd. C/o Sayaji Hotels, H-1, Scheme No. 54, Vijay Nagar, Indore, Madhya Pradesh – 452010. ….. Appellants Versus Securities and Exchange Board of India SEBI Bhavan, Plot No. C-4A, G Block, Bandra Kurla Complex, Bandra (East), Mumbai – 400 051. … Respondent Ms. Nidhi Bajpai, Advocate i/b Fortis India Law for the Appellants. Mr. Anubhav Ghosh, Advocate with Ms. Rashi Dalmia, Advocate i/b The Law Point for the Respondent. CORAM : Justice Tarun Agarwala, Presiding Officer Dr. C. K. G. Nair, Member Justice M. T. Joshi, Judicial Member Per : Justice Tarun Agarwala, Presiding Officer (Oral)

1. We have heard the learned counsel for the parties.

2. The present appeal has been filed against the order of the

Adjudicating Officer (hereinafter referred to as, ‘AO’) of Securities and Exchange Board of India (hereinafter referred to as, ‘SEBI’) dated March 28, 2018 imposing a penalty of Rs. 3,15,00,000/- for violation of Regulation 13(3) of Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 1992 and Regulation 11(1) and 11(2) as well as 7(1A) of the Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 1997 (hereinafter referred to as, ‘SAST Regulations’).

3. During the pendency of the appeal, a settlement application was

filed before SEBI under Securities and Exchange Board of India (Settlement Proceeding) Regulations, 2018 (hereinafter referred to as, ‘Settlement Regulations’). It has been stated at the bar that SEBI has allowed the settlement application pursuant to which the settlement amount has also been paid by the appellants.

4. In view of the aforesaid, approval is granted in terms of

Regulation 24(2) of the Settlement Regulations. The appeal is disposed of in terms of the settlement with no order as to costs. Sd/- Justice Tarun Agarwala Presiding Officer Sd/- Dr. C. K. G. Nair Member Sd/- Justice M. T. Joshi Judicial Member 22.10.2019 Prepared & Compared by PTM