WTM/PS/MRD/DSA/61/JAN/2015

BEFORE THE SECURITIES AND EXCHANGE BOARD OF INDIA

CORAM : PRASHANT SARAN, WHOLE TIME MEMBER
ORDER
Under sections 12 A and 11 of the Securities Contracts (Regulation) Act, 1956 read with section
11 of the Securities and Exchange Board of India Act, 1992
In respect of Vadodara Stock Exchange Limited

1.

Securities and Exchange Board of India (hereinafter referred to as "the SEBI") had issued a

Show Cause Notice dated March 22, 2013 (hereinafter referred to as "the SCN") to the Vadodara Stock
Exchange Limited (hereinafter referred to as "the VSE") through its Chairman. The SCN alleged that
the conduct of VSE lacked transparency, due diligence and appeared to be arbitrary in nature. The SCN
advised the said stock exchange to show cause as to why appropriate directions under sections 12A and
11 of the Securities Contracts (Regulation) Act, 1956 ("the SCRA") and section 11 of the Securities and
Exchange Board of India Act, 1992 ("the SEBI Act") should not be issued for securing proper
management of the assets and other properties of VSE including supersession of the governing body of
the stock exchange. VSE was advised to submit its reply along with supporting documents and also to
indicate whether it desired to avail the opportunity of personal hearing before SEBI.
2.

The aforesaid SCN was issued on the basis of the observations and findings of an inspection

conducted on VSE by SEBI during the year 2009. The facts and allegations, as stated in the SCN, are
summarized below:
(a)

The Board of VSE, in a meeting held on May 11, 2009, had decided to sell six of its properties

at Paradise Complex, Sayajigunj, Vadodara, viz., the Basement, Basement Office no. 46, First Floor
Office Nos. 149 and 150, Second Floor Office Nos. 227 and 228.
(b)

An advertisement was issued on June 22, 2009 in the regional daily 'Sandesh', inviting offers

within 10 days of the date of advertisement for such proposed sale.

(c)
Sr.
No

The details of bidders who had applied, the date of offer, offer price, are:
Property
offered for
sale

Area
Sq.ft/carpet
area

Name and address of the

people who placed bid to
buy the property

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Offer Price
(Rs.) per
Sq.ft/ Carpet
Area

Date of Offer

Stat us of
allotment
price

Basement

2181 sq ft
carpet area

Basement
Office No.
46

325 sq ft
carpet area

1st Floor
Office No.
149 & 150

835 sq ft
carpet area

Mr. Pravin Naik

1011/(On
behalf
of
Jain
International
Trade
Organization)
13, Chinar Woods
Akota, Vadodara
Mr. Pravin Naik
1001/(On
behalf
of
Jain
International
Trade
Organization)
13, Chinar Woods
Akota, Vadodara
Z.A. Amiri
1400/139-B, Paradise Complex
1st Floor, Sayajigunj,
Vadodara

July 1, 2009

Allotted at
Rs. 1100/-

July 1, 2009

Offer
withdrawn

July 1, 2009

Allotted at
Rs 1400/-

July 1, 2009

Allotted at
Rs 1200/-

Mr. Pravin Naik

1021/(On
behalf
of
Jain
International
Trade
Organization)
13, Chinar Woods
Akota, Vadodara
4

2nd Floor
Office No.
227 & 228

930 sq ft
carpet area

Sitar S. Shah
1200/5, Harinagar Society
Opp. Anand Vidhyavihar
School,
Race Course, Vadodara

Mr. Pravin Naik

951/(On
behalf
of
Jain
International
Trade
Organisation)
13, Chinar Woods
Akota, Vadodara

(d)

The bids were opened by VSE on July 01, 2009 in the presence of Managing Director of VSE

and Mr. Sudhir Shah, Chairman, VSE.

(e)

Thereafter, the Board of VSE had resolved in its meeting held on August 12, 2009 to allot

properties to the highest bidders.

(f)

The properties mentioned at serial nos. 3 {first floor offices nos. 149 and 150} and 4 {second floor

offices nos. 227 and 228} in the above table were allotted to the highest bidder.

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(g)

However, irregularities were observed in respect of allotment of properties at serial nos. 1

(Basement) and 2 (Basement office no. 46).

(h)

Alleged irregularities in the allotment of Basement (property mentioned at sr. no. 1 of the above

table):
It was observed from the details submitted by VSE that Mr. Pravin Naik, vide letter dated July 1, 2009,
had applied for properties on behalf of Jain International Trade Organization ("JITO") and the price
quoted for the 'Basement' property measuring 2181 sq. ft. area was Rs.1011/- per sq.ft.. The SCN had
also stated that Mr. Pravin Naik was the sole bidder for this property. However, the said property was
allotted to JITO at Rs.1100/- per sq.ft., which price was higher than the bid offered on record by Mr.
Pravin Naik. Therefore, it was alleged that "the allotment price (of Rs.1,100/-) for the basement was different
from the bid price (Rs. 1011/-) which is in deviation from the decision of the Board to allot to highest bidder". The
SCN also alleged " Further, no reasons have been recorded as to how Mr. Pravin Naik agreed to pay a price higher
than the bid price and that too when he was the sole bidder for the property. No record of such negotiation are included in
the submissions of VSEL".
(i)

Withdrawal of offer for property (basement office no. 46) by Mr. Pravin Naik:

The SCN has mentioned that Mr. Pravin Naik, vide letter dated July 1, 2009 had applied for all the four
properties. As per the letter, these bids were made for and on behalf of JITO. The SCN stated that
Mr. Pravin Naik had withdrawn his offer for property no. 46 vide letter dated July 30, 2009. On perusal
of the said letter, it was observed that the same was a letter from VSE to Mr. Pravin Naik advising him
to arrange for the stamp papers and cheque towards purchase of properties from VSE. On the said
letter, handwritten comments of Mr. Pravin Naik are present with his signature, but without any date.
VSE had stated that it considered such hand written comments of Mr. Pravin Naik as his withdrawal
for property no. 46. Such comments are as follows:
As already informed, it is not viable for me to accept allotment of 1 small basement office only & therefore I would not
be able to accept the same since my offer was for all offices.
Sd/Pravin Naik".
Except the above, there is no letter from Mr. Pravin Naik on record with respect to his withdrawal of
offer for property no. 46. The SCN has observed that "In the absence of same, date when offer has been
withdrawn is not ascertainable".

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The SCN had also stated "From the above, it is noted that Pravin Naik was interested in allotment of all properties
instead of one small basement office (property no. 46 measuring 325 Sq. Feet) and therefore, it cannot be concluded that
withdrawal offer was only for property no. 46 as submitted by exchange".
(j)

Alleged irregularities in the allotment of property - Basement office no. 46 (mentioned at serial

no. 2 of the above table):

The Board of VSE in its meeting held on August 12, 2009 had noted that there are no buyers for the
Basement Office no. 46 and had accordingly authorized the Chairman to accept offer from any person
at the minimum offer price of Rs.1000/- per sq. ft..
Subsequently, one Viken Shah, vide letter dated August 31, 2009 (received by VSE on the next day i.e., on
September 01, 2009), informed VSE that he proposes to purchase the said property at Rs.900/- per sq.
ft.. The offer of Mr. Viken Shah was accepted and a Board Resolution was passed on September 01,
2009 (the same day of receipt of the proposal) for disposal of the property. The decision was communicated
to Mr. Viken Shah and the token amount of Rs.11,000/- was received from Mr. Viken Shah vide
cheque dated September 02, 2009.
The SCN alleged that the decision taken on September 01, 2009 was materially different to its earlier
decision taken by VSE on August 12, 2009. Though, there was no material changes between the
period, it was alleged that the decision of the Board of VSE to dispose off the said property below
Rs.1000/- without any reasons clearly indicated lack of transparency, diligence and fairness on the part
of the Board of VSE.
The SCN also observed and alleged the following :
"...............
12. Further, as per the valuation report (Annexure III) of Shanti Consulting Engineers dated June 26, 2007, valuation
of property no. 46 was Rs 3,65,625/- (Rs 1125/- per sq. Feet). However, it is noted that Board of VSEL on
September 1, 2009 (same day of receipt of offer) has decided to sell the property no. 46 at a price of Rs 900 which is
10% less than its earlier decision dated August 12, 2009 and also 20% less than the valuation of the property as
per valuation report of Shanti Consulting Engineers.
13. It is alleged that entire process starting from the withdrawal of offer by Pravin Naik (though no letter received), receipt
of offer from Viken Shah, passing of Board resolution on same day of receipt of offer, deviation from its own decision
taken earlier, clearly indicates lack of transparency and fairness in allotment of property no. 46 especially when it was
allotted at the price which is 10% less than the minimum price of Rs 1000 as decided by Board on August 12,

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2009. Further, there is nothing to show that VSEL examined the feasibility to go for retender and fresh bids for the
captioned property.
14. It is also alleged that VSEL failed to carry out any due diligence to ascertain whether the persons whom properties
have been allotted (including property number 46) are related in any way to the Board/Management of VSEL.
............."
3.

VSE (vide letter dated April 02, 2013), while acknowledging the receipt of the SCN, informed

that an urgent meeting of the Board of Directors of VSE was scheduled on April 11, 2013 to discuss
the subject matter and that the reply would be submitted thereafter. Thereafter, vide letter dated April
15, 2013, VSE submitted its explanations to the allegations in the SCN. Such submissions inter alia are
the following :
a) Background of the property situated at Paradise Complex and the circumstances that lead the
Board of VSE to sell the said property:
i.

The property was virtually unused since the year 1995.

ii.

VSE had incurred an expenditure of Rs.5,88,574/- (approx. from the period 19952008) towards municipal tax, electricity bill etc.

iii.

Though the governing board of VSE tried to lease this property by giving
advertisement in the newspaper in the year 2008, there was no response from the
public.

iv.

The property is situated on the bank of river Vishwamitri and as the property is located
in the basement, the property gets damaged during the floods. The condition was
deteriorating day by day. This situation led to the reduction of its market value. VSE
felt that before the condition would worsen and reduce the value, it was commercially
prudent to dispose off the property .

v.

The area in which the property is situated has been declared as communally disturbed
area by the relevant authority. This factor also has a negative impact and VSE found it
difficult to get buyers.

vi.

The building management where this property was situated was not providing adequate
facilities like lift, water etc., therefore, some offices did not fetch good rates.

vii.

Further, there is no proper ventilation as the property is situated in the basement. The
building has no adequate parking facilities.

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Other submissions:
b) Mr. Pravin Naik had made an offer in his personal capacity. JITO, another bidder, had also
made a separate offer on its letter head which was considered by VSE. The offer of Mr. Pravin
Naik in respect of property mentioned at Sr. no. 1 of the above table was not accepted as his
quote was not the highest.
c) As regards the withdrawal of offer by Pravin Naik, VSE stated that when its official went to the
office of Mr. Pravin Naik for hand delivering its letter dated July 30, 2009, he withdrew his
offer by writing his comments on the said letter.

Therefore, the

Board of VSE

had

considered the date of withdrawal as the date of VSE's letter.

d) The bids provided by Mr. Pravin Naik for all offices of Paradise Complex was lower than the
other bidders except for office no. 46. Accordingly, VSE accepted his bid only for office no.
46. Although, Mr. Pravin Naik offered bids for all properties, he had not specified that his offer
shall be accepted in toto for all properties and he was not interested in any one of the
properties. Therefore, under the circumstances the Board of VSE has taken cognizance of his
withdrawal for office no. 46 only, as acceptance of offer by VSE was only for property no. 46.
e) As regards acceptance of offer from Mr. Viken Shah, VSE submitted that as a matter of
normal process, the notice dated August 28, 2009, convening the Board Meeting of VSE on
September 1, 2009 was sent to all the directors of VSE and accordingly the said Board Meeting
was held. The date of receipt of offer by Mr. Viken Shah and the date of Board Meeting being
on the same day was a coincidence. As VSE was not having any other offer in its hand, the
Board after considering all aspects decided to accept the offer given by Mr. Viken Shah at Rs.
900 per sq.ft. VSE also submitted that it felt that it was business prudence to accept the offer
of Mr. Viken Shah and sell the property to him instead of re-tendering or inviting fresh bids.
f) VSE requested SEBI to consider the background and circumstances under which the Board of
VSE arrived at a decision to sell the property.
g) As regards, the valuation of the property as mentioned in the SCN, VSE submitted that the
said valuation was done by the Valuers in the year 2007 and thereafter the value of the property
had diminished because of various reasons mentioned above. VSE also stated "it would further be

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evident from the Jantri of this particular Area which mentions value @ 4.9% and the property was sold by the
Exchange @ Rs.900 per sq.ft.".
h) VSE had sold the property strictly as per the Jantri prevailing at that time and executed the sale
deed on Stamp Paper of Rs. 15,000/- and the Office of Sub Registrar, Division 1-A, had
registered the documents without any objection. It was also mentioned "325 sq.ft x 900 rate =
292500 and jantri @ 4.9% comes to Rs. 14332.50".
i) VSE submitted that its Board has taken all due care and diligence while taking this decision to
dispose of the property in question and acted in a transparent and fair manner.
j) VSE further submitted that in the absence of any specific procedure and oversight, it had not
obtained any related party undertaking from the purchaser. VSE undertook that it would
henceforth take undertaking from purchasers at the time of selling any of its assets to the effect
that the person is not a relative of any of the members of the Board of Directors of VSE.
k) VSE also submitted that SEBI had in the past observed that VSE had made all possible efforts
to comply with provisions of various rules, regulations from time to time. VSE submitted that
it strongly believes in transparency, trust and safety at all levels and by which it has earned
prestigious image in the market. According to VSE, the public have shown their confidence by
opening more than 77,000 DP accounts with it.
l) VSE further submitted that it has always remained compliant of relevant guidelines and
protecting the interest of all stakeholders including investors and would remain committed in
future also.
VSE also sought for an opportunity of a personal hearing and stated that majority of the directors of
the present governing board were not the directors on the governing Board of VSE during the relevant
period. It requested SEBI to consider its submissions and further requested not to issue any directions.
4.

VSE, vide letter dated June 29, 2013, also provided clarifications with respect to certain queries

of SEBI (sought vide e-mail dated June 03, 2013). Such queries and their responses from VSE are
mentioned below :

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(a) SEBI had stated that the value of the property as on July 28, 2009 was Rs. 656600 and the sale was
to be executed on a Stamp Paper of Rs. 32174, whereas VSE had stated in its reply that the property
was sold as per the prevailing 'jantri' for Rs. 292500.
To this query, VSE reiterated its earlier submissions that it had sold the property strictly as per
the 'Jantri' prevailing at that time and executed the sale on a stamp paper of Rs. 15000 and the
Registrar's Office had registered the documents without any objection.
(b) SEBI had advised VSE to provide supporting documents in respect of its submission that 'the area
in which the property was situated was declared as communally disturbed area'.
VSE had submitted a 'Schedule- Areas of Vadodra City and Police Commissionerate area declared as
disturbed areas' issued by State Government of Gujarat. As per this schedule, three areas falling
under the Police Station of Sayajigunj were notified as 'disturbed areas'.
(c) SEBI sought clarification from VSE in respect of its submission that Mr. Pravin Naik and JITO
made separate bids. SEBI noted that as per letter dated July 1, 2009 from Mr. Pravin Naik to VSE, Mr.
Pravin Naik had applied for all the four properties on behalf of JITO.
In this regard, VSE had reiterated its earlier submission and annexed copies of bids made by
Mr. Pravin Naik and JITO
5.

VSE was also afforded an opportunity of personal hearing on August 02, 2013, when Mr.

Jayeshkumar N. Shah (Deputy Manager, VSE), Dr. Markand Parikh (Shareholder Director) and Mr.
Himanshu Parekh (Shareholder Director) appeared and submitted VSE's letter dated August 1, 2013
enclosing documents claiming to be the supportive documents for valuation of basement office no. 46
of Paradise Complex. The representative requested SEBI to consider the same and the replies already
filed in the matter.
6.

Vide the above said letter dated August 1, 2013, VSE stated that it enclosed copy of Annual

Statement of Rates along with Guidelines for implementation of Annual Statement of Rates with effect
from 2006 published by the Superintendent of Stamps and Valuation Department, Gandhinagar,
Gujarat and the same was in implementation upto 2011.

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VSE stated that as per the Guidelines, if any basement is used for commercial use, then it is to
be valued at 60% of the applicable rate. As per the 'zone', its property fell under "V.V1/8, Sayajigunj
area and the rate quoted is Rs.25,000/- per sq.mt." and after deducting the discount of 40%, the rate comes
to Rs.15,000/- per sq.mtr.

According to VSE, the valuation is Rs.4,53,000/- (30.20 sq.mtr x

Rs.15,000/-).
VSE also submitted that the property no. 46 has no frontage on Road and hence 20% discount
was considered as per the valuation guidelines. Accordingly, 20% (Rs.90,600/-) is deducted from the
above valuation and the resultant figure was Rs.3,62,400/-.
VSE further stated that as per Guidelines, 1% of total construction cost is to be considered as
depreciation per year. As per permission letter, the same was granted in the year 1986 and the
agreement for purchase of office no. 46 in Paradise Complex was executed in the year 2010. Hence,
depreciation for 24 years i.e. from 1986-2010 is to be considered which comes to Rs.86,976/-.
Accordingly, the net valuation was Rs.2,75,424/-.
VSE also submitted that in the special note to 'jantri', it is mentioned that the 'jantri' valuation is
approximate and the actual valuation will be considered at the time of registration of agreement with
sub registrar will be final. It also contended that all benefits available under the Guidelines are not
shown in the jantri and such benefits are availed at the time of registration of documents. Further, as
per the directives of Government of Gujarat and as per the rules at that time, if Jantri valuation shows
lesser stamp duty the Sub-Registrar registering the agreement will not accept.

It was therefore

contended that in the case of VSE, the sale deed for property comprised in office no. 46 is executed
vide Sr.. no. 1896 dated March 16, 2010. As per the above statement, total net valuation comes to
Rs.2,75,424/- and that stamp duty paid was Rs.15,000/- on the net value of Rs.2,92,200/-.
7.

I have considered the SCN, the submissions made by VSE and the documents available on

record. The allegations against VSE are in respect of allotment of properties mentioned at serial nos. 1
(i.e. Basement comprising 2181 sq.ft. carpet area) and 2 (i.e., Basement office no. 46 comprising 325
sq.ft. carpet area).
8.

As regards the Basement, the SCN has alleged that the same was allotted to JITO and that as

per record the sole bidder was Mr. Pravin Naik. VSE has contended that it has allotted to JITO as its

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bid was higher and in support of the same had forwarded the letter of JITO wherein it has made the
offer. I have perused the letters of Mr. Pravin Naik and JITO. Mr. Pravin Naik, vide his letter dated
July 01, 2009 had mentioned his bids for all properties. Further, this letter mentions that it is made for
'Jain International Trade Organization (Vadodara)' . JITO (Vadodara), vide a separate letter dated July
01, 2009 has placed bid only for the Basement office measuring 2181 sq.ft. carpet area at a price of
Rs.1100/- per sq.ft. carpet area. The bid placed by JITO (at Rs.1100/- per sq. ft.) is higher than the bid
placed by Mr. Pravin Naik (at Rs.1011/- per sq. ft.). The SCN has alleged "Further, no reasons have been
recorded as to how Mr. Pravin Naik agreed to pay a price higher than the bid price and that too when he was the sole
bidder for the property. No record of such negotiation are included in the submissions of VSEL". If VSE had placed
such separate bids received from JITO and Mr. Pravin Naik during SEBI Inspection or thereafter, this
issue could have been clarified. As there are two separate bids from Mr. Pravin Naik and JITO and as
JITO has made placed its bid only for the Basement property, VSE's submission could be accepted that
it allotted the property to the highest bidder, which was JITO. However, it becomes difficult to
comprehend as to why VSE did not disclose the fact regarding the separate bid placed by JITO for the
said property during the SEBI Inspection or thereafter. On receipt of an offer separately from JITO
for the Basement property, VSE should have ideally clarified with Mr. Pravin Shah and JITO regarding
the same and documented such events. This would have ensured better transparency and fairness.
9.

The next allegation is regarding the withdrawal of offer for basement office no. 46 by Mr.

Pravin Naik. The SCN has mentioned that the offers/bids were opened on July 01, 2009. It appears
that when VSE communicated to Mr. Pravin Naik regarding acceptance of his offer for Basement
office no. 46, Mr. Pravin Naik, has indicated in the letter of VSE that his bids were for all properties
and he would not be able to take only a small office. Accordingly, VSE has construed the same as his
withdrawal of his offer. The SCN has alleged that except for the hand written comments of Mr. Pravin
Naik, there was no other letter regarding his withdrawal and therefore the date when offer has been
withdrawn is not ascertainable. However, considering the fact that Mr. Pravin Naik has made his
comments on the letter dated July 30, 2009 and also as VSE has informed that the said letter was
forwarded to Mr. Pravin Naik by hand-delivery, the date of VSE's letter could be considered as the date
of withdrawal by Mr. Pravin Naik.
10.

The other allegation against VSE is the irregular manner in which the property - Basement

office no. 46 was allotted to Mr. Viken Shah. The SCN has stated that the Board of VSE in its meeting

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held on August 12, 2009 had noted that there were no buyers for the said property and the Board had
authorised the Chairman to accept the offer from any person at the minimum offer price of Rs.1000/per sq.ft. The allegation is that VSE had allotted the property to Mr. Viken Shah at a price of Rs.900/per sq. ft. which was lower than the minimum price resolved in the above said Board meeting. VSE, in
its defense, has argued that it accepted the offer from Mr. Viken Shah as it did not have any offers for
the property. According to VSE, the decision to sell the property to Mr. Viken Shah at the offer price
was taken in the meeting of VSE's Board of Directors held on September 01, 2009.
11.

I have perused the letter dated August 31, 2009 from Mr. Viken Shah. This letter was received

in VSE on September 01, 2009. According to VSE, it was a coincidence for the Board meeting and the
receipt of letter to happen on the same day i.e., September 01, 2009. VSE has also contended that the
Board meeting scheduled on September 01, 2009 was informed to its directors vide VSE's notice dated
August 28, 2009.

It is alleged that VSE had sold its property at a price less than 10% of the Board

decided minimum price at Rs.1000/- per sq. ft. and 20% less than the price as per the Valuation
Report.
12.

As per documents, Basement Office no. 46 was sold to Mr. Viken Shah for a consideration of

Rs.2,92,500/- and a stamp duty of Rs.15,000/- was paid for such sale. VSE had tried to justify the
consideration amount by its contentions mentioned in its letter dated August 01, 2013. According to
VSE, discounts on the consideration amount could be availed as the (i) property was situated in
basement for which 40% discount was available and (ii) depreciation at 1% per year was available for 24
years. Therefore, according to VSE, from the valuation of Rs.4,53,000/- discounts under these heads
were available and after deductions, the net amount was Rs.2,75,424/-. It further stated that it has paid
stamp duty of Rs.15,000/- on a consideration of Rs.2,92,200/-. However, these factors and the reasons
have not been documented in its Board meetings to ensure transparency and fairness in the allotment
process. All that exercise that has been carried out by VSE in defending itself in this matter, the
documents submitted, the reasons brought out, could have been deliberated and documented during
the allotment and sale of the said properties.
13.

I am also of the considered opinion that the Valuation Report, as mentioned in the SCN, would

have ideally considered the factors and circumstances including those (reasons why there were no
buyers and the diminishing value of property) submitted by VSE, while arriving at a guideline value of

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the said property. VSE has not produced any material to show that it conducted an inquiry to find
whether any related party is purchasing the property to his advantage. However, VSE states that it
would henceforth take an undertaking that the purchaser is not a 'related party'. It appears that VSE is
still not serious in exercising due diligence as it wishes to rely only on such an undertaking. By not
inviting fresh bids and selling the property for a value less than the guideline value and the value
decided in an earlier Board meeting, the same may have caused loss to VSE and its shareholders.
Therefore, the charge that the decision making in VSE lacked 'transparency' and 'fairness in allotment'
may therefore sustain.
14.

In view of the foregoing observations, I, in exercise of the powers conferred under section 19

of the Securities and Exchange Board of India Act, 1992 read with section 11 thereof and section 12A
of the Securities Contracts (Regulation) Act, 1956, hereby caution the Vadodara Stock Exchange
Limited for its conduct observed in this Order. The Stock Exchange is advised to ensure transparency
and fairness in its dealings in future and also ensure compliance with all statutory provisions that
govern its activities in the securities market.
15.

The SCN dated March 22, 2013 issued to Vadodara Stock Exchange Limited is accordingly

disposed of.

Sd/PRASHANT SARAN
WHOLE TIME MEMBER
SECURITIES AND EXCHANGE BOARD OF INDIA
Date : January 07, 2015
Place: Mumbai

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