Consentia on Law

INSIDER TRADING- ITS ILLEGALITY AND LEGALITY

ABSTRACT

Insider trading is the trading of a corporation‘s stock or other securities (e.g. bonds or stock options) by individuals with potential access to non-public information about the company. In most countries, trading by corporate insiders such as officers, key employees, directors, and large shareholders may be legal, if this trading is done in a way that does not take advantage of non-public information.

However, the term is frequently used to refer to a practice in which an insider or a related party trades based on material non-public information obtained during the performance of the insider’s duties at the corporation, or otherwise in breach of a fiduciary or other relationship of trust and confidence or where the non-public information was misappropriated from the company.

Insider trading can be illegal or legal depending on when the insider makes the trade: it is illegal when the material information is still non public–trading while having special knowledge is unfair to other investors who don’t have access to such knowledge.

 Insider trading is legal once the material information has been made public, at which time the insider has no direct advantage over other investors. The SEC, however, still requires all insiders to report all their transactions. So, as insiders have an insight into the workings of their company, it may be wise for an investor to look at these reports to see how insiders are legally trading their stock.

In the contemporary scenario securities markets around the world are competing for the fixed pool of capital. Investors will surely prefer markets where the regulatory agencies are most effective. Protecting the investors, enforcing securities laws and creating confidence in the system by ensuring the fairness and integrity of the market should therefore be a priority. Investor confidence is extremely fragile and should be maintained with care. The securities markets should therefore be treated like Caesar’s wife; they must not only be above suspicion but must also be perceived to be so.

 

 

Introduction

The Company is a legal entity with perpetual succession and a common seal. The BOD and its staffs and employees are the main hands of the company which makes the Company works and helps it to attain its objectives. The Board of Directors, its staffs and its employees  as being the left and right hands of the Company are under a duty to not to get involved in any activities which to harm the company and in case they case involved in any fraudulent activities they are solely responsible for the loss suffered by the Company.

Insider trading is one of the activities which is a form of corporate crime where any insider  get involved in illegal stuffs thus violating the principle of utmost good faith thus affecting the Company to the huge extent. Insider trading is the trading of a corporation‘s stock or other securities (e.g. bonds or stock options) by individuals with potential access to non-public information about the company.[1] In most countries, trading by corporate insiders such as officers, key employees, directors, and large shareholders may be legal, if this trading is done in a way that does not take advantage of non-public information.

However, the term is frequently used to refer to a practice in which an insider or a related party trades based on material non-public information obtained during the performance of the insider’s duties at the corporation, or otherwise in breach of a fiduciary or other relationship of trust and confidence or where the non-public information was misappropriated from the company.[2]

 Insider trading can be illegal or legal depending on when the insider makes the trade: it is illegal when the material information is still non public–trading while having special knowledge is unfair to other investors who don’t have access to such knowledge.
Insider trading is legal once the material information has been made public, at which time the insider has no direct advantage over other investors.[3]

The primary focus of this article is on the insider trading regulations which are applicable to the offending transaction. An attempt has been made to analyze the Indian insider dealing provisions as they stand. The paper includes a comparative study between the Indian laws and the various other prevailing laws in other countries. The purpose of such a comparison is to point out the international trends and standards in connection with the control of this pernicious practice. The paper also deals with the legality or illegality of the insider trading.

Meaning of Insider & Insider Trading as Defined:

Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 1992, does not directly define the term “insider trading”. But defines the terms:

  • insider” or who is an “insider;
  • Who is a “connected person.
  • What is “price sensitive information”.

Insider

According to the Regulations “insider”[4] means any person who, is or was connected with the company or is deemed to have been connected with the company, and who is reasonably expected to have access, connection, to unpublished price sensitive information in respect of securities of a company, or who has received or has had access to such unpublished price sensitive information.

Connected person

The Regulation defines that a “connected person” means any person who-
(i) is a director, as defined in clause (13) of section 2 of the Companies Act, 1956 (1 of 1956) of a company, or is deemed to be a director of that company by virtue of sub-clause (10) of section 307 of that Act or

(ii) occupies the position as an officer or an employee of the company or holds a position involving a professional or business relationship between himself and the company whether temporary or permanent and who may reasonably be expected to have an access to unpublished price sensitive information in relation to that company;

Price Sensitive Information[5] means any information, which relates directly or indirectly to a company and which if published, is likely to materially affect the price of securities of company.

Insider Trading-

“Insider” means any person who, is or was connected with the company or is deemed to have been connected with the company, and who is reasonably expected to have access, connected, to unpublished price sensitive information in respect of securities of a company, or who has received or has had access to such unpublished price sensitive information[6].

Insider definition as amended by SEBI vides its Notification No. LAD – NRO/GN/2008/29/44801 dated 19-11-2008 means any person, who

(i) Is or was connected with the company or is deemed to have been connected with the company and who is reasonably expected to have access to unpublished price sensitive information in respect of securities of a company, or

(ii) Has received or has had access to such unpublished price sensitive information

There are several “do’s” and “don’ts” with reference to these “insiders”. The effect of the regulatory measure adopted by SEBI to prevent the insider trading in the shares of the company to earn an unjustified benefit for himself and to the disadvantage of the bona fide common shareholders

Insider trading is a term subject to many definitions and connotations and it encompasses both legal and prohibited activity. Insider trading takes place legally every day, when corporate insiders – officers, directors or employees – buy or sell stock in their own companies within the confines of company policy and the regulations governing this trading.[7] In simple terms ‘insider trading’ buying or selling a security, in breach of a fiduciary duty or other relationship of trust, and confidence, while in possession of material, non public information about the security.

The misuse of confidential information is frowned upon for several reasons as:[8]

  • It involves taking a secret, unfair advantage.
  • It gives rise to a potential conflict of interests in which the company’s best interest may wrongfully take second place to the insider’s self interest, and
  • It brings the market into disrepute and may be a disincentive to investment.
  • It is unethical as it amounts to breach of fiduciary position of trust and confidence.

Public confidence in directors and others closely associated with companies requires that such people do not use inside information to further their own interests. Furthermore, if they were to do so, they would frequently be in breach of their obligations to the companies, and could be held to be taking an unfair advantage of the people with whom they are dealing.[9]

The nature of the offense is such that no piece of legislation, however carefully drafted, can hope to cover and thereby suppress this practice in its entirety. Even if legislation is not entirely successful in suppressing improper transactions, a high standard of conduct should be maintained, and it should generally be realized that a speculative profit made as a result of special knowledge not available to the general body of shareholders in a company is improperly made.[10]

Examples of Insider Trading-

Corporate officers, directors and employees who traded the company’s securities after learning of significant, confidentiality corporate developments Employees of law, banking , brokerage and printing firms- who were given such information to provide services to corporation whose securities they traded;  Government employees who learned of such information because of their employment by the government.

Therefore, preventing such transactions is an important obligation for any capital market regulatory system, because insider trading undermines investor confidence in the fairness and integrity of the securities markets.

The first country to tackle insider trading effectively however was the United States. In the USA, the Securities and Exchange Commission is empowered under the Insider Trading Sanctions Act, 1984 to impose civil penalties in addition to criminal proceedings. Most countries have in place suitable legislation to curb the menace of insider trading.

In India, SEBI (Insider Trading) Regulations 1992, framed under Section 11 of the SEBI Act, 1992, are intended to prevent and curb the menace of insider trading in Securities. Now SEBI has with effect from 20th February 2002 amended these Regulations and rechristened them as SEBI Prohibition of Insider Trading Regulation, 1992. These Regulations have been further amended in November 2002.

Insider trading leads to loose of confidence of investors in securities market as they feel that market is rigged and only the few, who have inside information get benefit and make profits from their investments. Thus, process of insider trading corrupts the ‘level playing field’

Hence the practice of insider trading is intended to be prohibited in order to sustain the investor’s confidence in the integrity of the security market. In Samir C Arora Vs SEBI[11] it was observed that activities like insider trading fraudulent trade practices and professional misconduct are absolutely detrimental to the interests of ordinary investors and are strongly deprecated under the SEBI Act, 1992 and the Regulations made there under. No punishment is too severe for those indulging such activities.

 Various Laws Prevailing in Different Countries in Regard to Insider Trading

 

  1. 1.      Protection Under General Law

Insider dealing under the general law the general law has proved ineffective in controlling insider dealing. The protections available under general law may be summarized as follows:

  1. Where a trader makes an affirmative misrepresentation about the security to his counter party, he may be liable for misrepresentation under normal rules.
  2. Where a trader omits to disclose a material factor about a security, he may in exceptional circumstances are liable for non-disclosure. Generally, however, there is no liability for non-disclosure.
    1. 2.      American insider trading law

The United States has been the leading country in prohibiting insider trading and the first country to tackle insider trading effectively.  Thus it is important to discuss insider trading in American perspective. While Congress gave us the mandate to protect investors and keep our markets free from fraud, it has been our jurists, albeit at the urging of the Commission and the United States Department of Justice, who have played the largest role in defining the law of insider trading.

The market crash in 1929 due to prolonged lack of investors confidence in the securities market followed by Great Depression of US Economy , led to the enactment of Securities Act of 1933 in which Section 17 of the contained prohibitions of fraud in the sale of securities which were greatly strengthened by the Securities Exchange Act of 1934The 1934 Act addressed insider trading directly through Section 16(b) and indirectly through Section 10(b).Section 16(b) of the Securities Exchange Act of 1934 prohibits short-swing profits (from any purchases and sales within any six month period) made by corporate directors, officers, or stockholders owning more than 10% of a firm’s shares. Under Section 10(b) of the 1934 Act, SEC Rule 10(b) prohibits fraud related to securities trading. Further the Insider Trading Sanctions Act of 1984 and the Insider Trading and Securities Fraud Enforcement Act of 1988 provide for penalties for illegal insider trading to be as high as three times the profit gained or the loss avoided from the illegal trading.

In United States v. Carpenter (1986)[12] the U.S. Supreme Court cited an earlier ruling while unanimously upholding mail and wire fraud convictions for a defendant who received his information from a journalist rather than from the company itself. The journalist R. Foster Winans was also convicted.

“It is well established, as a general proposition, that a person who acquires special knowledge or information by virtue of a confidential or fiduciary relationship with another is not free to exploit that knowledge or information for his own personal benefit but must account to his principle for any profits derived there from.” However, in upholding the securities fraud (insider trading) convictions, the justices were evenly split.

In 1997 the U.S. Supreme Court adopted the misappropriation theory of insider trading in United States v. O’Hagan,[13] O’Hagan was a partner in a law firm representing Grand Met, while it was considering a tender offer for Pillsbury Co. O’Hagan used this inside information by buying call options on Pillsbury stock, resulting in profits of over $4 million. O’Hagan claimed that neither he nor his firm owed a fiduciary duty to Pillsbury, so that he did not commit fraud by purchasing Pillsbury options.

The Court rejected O’Hagan’s arguments and upheld his conviction.

The “misappropriation theory” holds that a person commits fraud “in connection with” a securities transaction, and thereby violates 10(b) and Rule 10b-5, when he misappropriates confidential information for securities trading purposes, in breach of a duty owed to the source of the information. Under this theory, a fiduciary’s undisclosed, self-serving use of a principal’s information to purchase or sell securities, in breach of a duty of loyalty and confidentiality, defrauds the principal of the exclusive use of the information. In lieu of premising liability on a fiduciary relationship between company insider and purchaser or seller of the company’s stock, the misappropriation theory premises liability on a fiduciary-turned-trader’s deception of those who entrusted him with access to confidential information.

The Court specifically recognized that a corporation’s information is its property:[14]

 “A company’s confidential information…qualifies as property to which the company has a right of exclusive use. The undisclosed misappropriation of such information in violation of a fiduciary duty…constitutes fraud akin to embezzlement – the fraudulent appropriation to one’s own use of the money or goods entrusted to one’s care by another.”

In 2000, the SEC enacted Rule 10b, which defined trading “on the basis of” inside information as any time a person trades while aware of material non public information — so that it is no defence for one to say that she would have made the trade anyway. This rule also created an affirmative defence for pre-planned trades.

In May of 2007, representatives Brian Baird and Louise Slaughter introduced a bill entitled the “Stop Trading on Congressional Knowledge Act, or STOCK Act.” that would hold congressional and federal employees liable for stock trades they made using information they gained through their jobs. The bill would also seek to regulate so called “Political Intelligence” firms that research government activities and sell the information to financial managers.

  1. 3.      The law in UK

In the UK insider dealing was made a specific criminal offense in 1980 and was incorporated in the Company Securities Insider Dealing Act 1985 which was re enacted in 1993 and is contained in Part V of the Criminal Justice Act of 1993 (CJA).

Under the UK regulation “inside information” means information which relates to particular securities or the issuer of particular securities and is specific or precise and has not been made public and if it were made public would have a significant effect on the price of any securities.

Interestingly, under the law as it exists in the UK only individuals can be held liable. In India individuals as well as corporations can be guilty of the offense. In this regard the law in India is similar to the law in the US where corporate liability is recognized under certain circumstances.

UK regulations state that information can be said to have been made public if:[15]

  • It is published in accordance with the rules of a regulated market for the purpose of    informing investors and their professional advisors;
  • It is contained in records which by virtue of any enactment are open to inspection by the  public;
  • It can be readily acquired by those likely to deal in securities (a) to which information

      relates (b) or an issuer to which the information relates; or

  • It is derived from information which has been made public.

 

Indian regulations are silent on when and how information is considered to be public. Unlike the Indian regulations, the UK enactment also provides for defences available to an individual against action for insider trading. An individual is not guilty of insider dealing if he shows:[16]

  • He did not at the time of dealing expect the deal to result in profit attributable to the fact that the information in question was price sensitive information in relation to the securities.
  • That he believed on reasonable ground that information had been disclosed widely enough to ensure that none of those taking part in the dealing would be prejudiced by not having information.
  • That he would have done what he did even if he did not have the information. Defences on the same lines are available to persons who are considered guilty of encouraging other persons to deal in securities or disclosing price sensitive information to others.

In the UK insider trading is considered a criminal offense and hence, the standard of proof required for conviction is high. Knowledge is an essential ingredient to be proved in an insider trading case, which under criminal law must mean more than constructive knowledge. The mens rea or the intent therefore assumes significance. Indian laws do not seem to take the ‘intent’ of the offender into account.[17]

As a result, there has been a broadening of the scope of the regulations and a visible shift in the burden of proof from the prosecutors to the defendants. This trend is in tune with the changes observed internationally.

  1. 4.      Laws in India.

In India Regulation 3 of the SEBI Regulations seeks to prohibit dealing, communication and counselling on matters relating to, insider trading. Regulation 3[18] provides that no insider shall either on his own behalf of any other person deal in securities of a company when in possession of any unpublished price sensitive information on communicate, counsel or procure, directly or indirectly any unpublished price sensitive information to any person, who while in possession of such unpublished price sensitive information shall not deal in securities. However, these restrictions are not applicable to any communication required ordinary, course of business or profession or employment or any law.[19]

Further 3A[20] prohibits any company from dealing in the securities of another company or associate of that other company while in possession of any unpublished price sensitive information. Insider Trading Regulations have been tightened by SEBI during February 2002. New rules cover ‘temporary insiders’ like lawyers, accountants, investment bankers etc.

Directors and substantial shareholders have to disclose their holding to the company periodically. The New Regulations have added relatives of connected persons, as well as, the companies, firms, trust, etc .in which relatives of connected persons, bankers of the company and of persons deemed to be connected persons hold more than 10% .[21]The definition of relative under the New regulations is in line with that of the Companies Act, 1956, which ranges from parents and siblings to spouses of siblings and grandchildren. The term “connected person” is defined to mean either

i)                    a director or deemed to be a director,

 ii) occupies the position as an officer or an employee or having professional or business relationship whether temporary or permanent, with the company. Thus, there are two categories of insiders:

Primary insiders, who are directly connected with the company and secondary insiders who are deemed to be connected with the company since they are expected to have access to unpublished price sensitive information. The jurisprudential basis for the ‘person-connected’ approach seems to be founded in the equitable notions of fiduciary duty.

The secondary insider, who would have traded with an unfair informational advantage, may escape from being caught simply because there can be no trace of how he derived this information in the first place. insider by reason of his connection with the company. In reality, much of the flow of the price-sensitive information often does not operate by way of such established networks of relational links between individuals. Very often, such price-sensitive information is communicated and spread out through very loosely connected and informal networks of brokers, clients and even between friends and through electronic networks etc. or an elaborate nexus of company official, brokers, traders. These individuals are very often privy to strategic policy decisions or developments that may influence the valuation of a company’s scrip on the bourses.

Duties/ Obligations of the Company:

  • Every listed company has the following obligations under the SEBI (Prohibition of Insider trading) Regulations, 1992.
  • To appoint a senior level employee generally the Company Secretary , as the Compliance Officers;
  • To set up an appropriate mechanism and to frame and enforce a code of conduct for internal procedures,
  • To abide by the Code of Corporate Disclosure practices as specified in Schedule ii to the SEBI (Prohibition of Insider Trading)Regulations , 1992
  • To initiate the information received under the initial and continual disclosures to the Stock Exchange within 5 days of their receipts;
  • To specify the close period;
  • To identify the Price Sensitive Information
  • To ensure adequate data security of confidential information stored on the computer;
  • To prescribe the procedure for the pre- clearance of trade and entrusted the Compliance Officers with the responsibility of strict adherence of the same.

Penalties
Following penalties /punishments can be imposed in case of violation of SEBI (Prohibition of Insider Trading) Regulations, 1992

  • SEBI may impose a penalty of not Rs 25 Crores or three times the amount of profit made out of insider trading; whichever is higher.
  • SEBI may initiate criminal prosecution.
  • SEBI may issue orders declaring transactions in securities based on unpublished price sensitive information.
  • SEBI may issue orders prohibiting an insider or refraining an insider from dealing in the securities of the company.

Thus, the new 2002 regulations in India have further fortified the 1992 regulations and have increased the list of persons that are deemed to be connected to Insiders. Listed companies and other entities are now required to frame internal policies and guidelines to preclude insider trading by directors, employees, partners, etc. In the past, it has been observed that insider trading legislation is ineffective and difficult to enforce and has little impact on securities markets. Low enforcement rates and few convictions against insiders have been cited as evidence of this ineffectiveness. Irrespective of whether or not the SEBI was bestowed with wide ranging powers, it has been a clear failure when it came to the task of administering the law.

The importance of policing insider trading has also assumed international significance as overseas regulators attempt to boost the confidence of domestic investors and attract the international investment community. So, SEBI now should take the role of a regulator only. Special Courts could be set up for faster and efficacious disposal of cases.

 The Legal Aspect of Insider Trading

Legal trades by insiders are common, as employees of publicly traded corporations often have stock or stock options. These trades are made public in the United States through Securities and Exchange Commission filings, mainly Form 4. Prior to 2001, U.S. law restricted trading such that insiders mainly traded during windows when their inside information was public, such as soon after earnings releases.

 SEC Rule 10b (5-1)[22] clarified that the prohibition against insider trading does not require proof that an insider actually used material non public information when conducting a trade; possession of such information alone is sufficient to violate the provision, and the SEC would infer that an insider in possession of material non public information used this information when conducting a trade.

However, SEC Rule 10b(5-1) also created for insiders an affirmative defence if the insider can demonstrate that the trades conducted on behalf of the insider were conducted as part of a pre-existing contract or written binding plan for trading in the future.[23] For example, if an insider expects to retire after a specific period of time and, as part of his or her retirement planning, the insider has adopted a written binding plan to sell a specific amount of the company’s stock every month for two years and later comes into possession of material non public information about the company, trades based on the original plan might not constitute prohibited insider trading.

Some economists and legal scholars argue that laws making insider trading illegal should be revoked. They claim that insider trading based on material non public information benefits investors, in general, by more quickly introducing new information into the market.

Milton Friedman, laureate of the Nobel Memorial Prize in Economics, said: “You want more insider trading, not less. You want to give the people most likely to have knowledge about deficiencies of the company an incentive to make the public aware of that.”[24] Friedman did not believe that the trader should be required to make his trade known to the public, because the buying or selling pressure itself is information for the market.

Other critics argue that insider trading is a victimless act:[25] A willing buyer and a willing seller agree to trade property which the seller rightfully owns; with no prior contract (according to this view) having been made between the parties to refrain from trading if there is asymmetric information. The Atlantic has described the process as “arguably the closest thing that modern finance has to a victimless crime”.

Legalization advocates also question why “trading” where one party has more information than the other is legal in other markets, such as real estate, but not in the stock market. For example, if a geologist knows there is a high likelihood of the discovery of petroleum under Farmer Smith’s land, he may be entitled to make Smith an offer for the land, and buy it, without first telling Farmer Smith of the geological data. Nevertheless, circumstances can occur when the geologist would be committing fraud if, because he owes a duty to the farmer, he did not disclose the information; e.g., if he had been hired by Farmer Smith to assess the geology of the farm.

Advocates of legalization make free speech arguments. Punishment for communicating about a development pertinent to the next day’s stock price might seem to be an act of censorship. If the information being conveyed is proprietary information and the corporate insider has contracted to not expose it, he has no more right to communicate it than he would to tell others about the company’s confidential new product designs, formulas, or bank account passwords.[26] These are a few arguments placed on behalf of legality of insider trading.

Conclusion

In nutshell , insider trading is the buying , selling or dealing in securities of a listed company by a director , member of management , employee of the company , or by any other person such as internal auditor , advisor , consultant , analyst etc, who has knowledge of material inside information which is not available to general public.

Insider dealing is seen as an abuse of an insider’s position of trust and confidence and as harmful to the securities markets because outsiders can be cheated by insiders who are not able to deal on equal terms: as a result the ordinary investor loses confidence in the market. The rules are more important in relation to equities where prices are more sensitive to financial conditions. But the principles could impact upon bonds and of course upon convertibles or other bonds with an equity element.

Essentially insider trading involves the deliberate exploitation of unpublished price sensitive information obtained through or from a privileged relationship to make profit or avoid loss by

dealing in securities of a company when the price of securities would be materially altered if the information was disclosed.

In other words, insider dealing is understood broadly to cover situations where a person buys or sells securities when he, but not the other party to the transaction, is in possession of confidential information because of some connection and such information would affect the value of those securities. Furthermore, the confidential information in question will generally be in his possession because of some connection which he has with the company whose securities are being dealt in or are to be dealt in by him (e.g. he may be a director, employee or professional adviser of that company) or because someone in such a position has provided him, directly or indirectly, with the information.

The rationale behind the prohibition of insider trading is “the obvious need and understandable concern about the damage to public confidence which insider dealing is likely to cause and the clear intention to prevent, so far as possible, what amounts to cheating when those with inside knowledge use that knowledge to make a profit in their dealings with others.


[1] www.investopedia.com, Accessed on 9 November 2012, IST 12:30

[2] http://www.IndiaCorpLaw.co.in, Accessed on 12 November 2012, IST 16:12

 

[3] www. IndiaCorpLaw.co.in, Accessed on 12 November 2012, IST 18:30

[4] SEBI (Prohibition of Insider trading) Regulations, 1992

[5] SEBI (Probihition of Insider trading) Regulations, 1992

[6] Regulation 2(e) of the SEBI (Probihition of Insider trading) Regulations, 1992

[7] http://economictimes.indiatimes.com, Accessed on 17 October 2012, IST 20:30

[8] http://www.seclaw.com, Accessed on 17 October 2012, IST 20:30

[9] http://www.brefigroup.co.uk, Accesed on 1 December 2012, IST 12:50

[10]http://www.brefigroup.co.uk, Accesed on 1 December 2012, IST 12:50

 [11] 2005 59 SCL 96 SAT

[12] 484 U.S. 19 (1987)

[13] 521 U.S. 642, 655 (1997),.

[14] http://works.bepress.com, Accessed on 2 December 2012 IST 18:40

[15] http://en.wikipedia.org/wiki/Insider_trading, Accessed on 3 December 2012, IST 15:30

[16] http://en.wikipedia.org/wiki/Insider_trading, Accessed on 3 December 2012, IST 15:30

[17] http://en.wikipedia.org/wiki/Insider_trading, Accessed on 3 December 2012, IST 15:30

[18] SEBI (Probihition of Insider trading) Regulations, 1992

[19] http://en.wikipedia.org/wiki/Insider_trading, Accessed on 3 December 2012, IST 15:30

[20] SEBI (Probihition of Insider trading) Regulations, 1992

[21] http://www.econlib.org/library/Enc/InsiderTrading.html, Accessed on 3 December 2012, IST 15:30

[22]http://pohara.homestead.com, Accessed on 10 November 2012, IST 20:00

[23] http://www.secform4.com, Accessed on 10 November 2012, IST 20:00

[24] http://www.Legal Service India.com, Accessed on 14 November 2012, IST 23:12

 

[25]http://www.IndiaCorpLaw.co.in, Accessed on 14 November 2012, IST 23:15

 

[26]http://www.IndiaCorpLaw.co.in, Accessed on 14 November 2012, IST 23:15

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