BEFORE THE ADJUDICATING OFFICER

SECURITIES AND EXCHANGE BOARD OF INDIA

(ADJUDICATION ORDER NO: OIAE/EAD-3/AO/DRK-ASR/686/11-2015)
____________________________________________________________________
UNDER SECTION 15 - I OF THE SECURITIES AND EXCHANGE BOARD OF
INDIA ACT, 1992 READ WITH RULE 5 OF THE SECURITIES AND EXCHANGE
BOARD OF INDIA (PROCEDURE FOR HOLDING INQUIRY AND IMPOSING
PENALTIES BY ADJUDICATING OFFICER) RULES, 1995.
In respect of:

Hotline Teletube & Components Ltd

52-A, Okhla Industrial Estate,
Pha se III
New Delhi 110 020

BACKGROUND:
1. Securities and Exchange Board of India (hereinafter referred to as SEBI)
observed that Hotline Teletube & Components Limited (hereinafter referred to as
'the Noticee / the Company / HTCL") had not redressed the investor grievance.
APPOINTMENT OF ADJUDICATING OFFICER:
2. I was appointed as Adjudicating Officer under section 15-I of the Securities and
Exchange Board of India Act 1992 (hereinafter known as 'SEBI Act') read with
Rule 3 of the SEBI (Procedure for Holding Inquiry and Imposing Penalties by
Adjudicating Officer) Rules, 1995 (hereinafter referred to as Adjudication Rules)
to inquire into and adjudge under Section 15C of the SEBI Act, alleged violation by
the noticee and the same was communicated vide communiqu dated May 21,
2013.

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SHOW CAUSE NOTICE, REPLY AND PERSONAL HEARING:

3. A Show Cause Notice No. A&E/EAD-3/DRK-VVK/18968/2013 dated July 30, 2013

(hereinafter referred to as SCN) was sent to the noticee by Speed Post AD, to
show cause as to why an inquiry should not be held against the noticee in terms of
Rule 4 of the Adjudication Rules read with Section 15-I of the SEBI Act and why
penalty, if any, should not be imposed under Section 15C of the SEBI Act, for the
alleged non redressal of one investor grievance against the noticee in SEBI
Complaints Redress System (hereinafter referred to as "SCORES") that was
pending for more than two years. The complaint was filed by Shri Madan Mohan
Malhotra (hereinafter referred to as Malhotra) for nonreceipt of shares sent for
transfer.
4. The following was alleged in the aforesaid SCN
(a) Vide letter dated January 22, 2013, SEBI had earlier directed the noticee to
resolve the investor grievance of Malhotra. It was also mentioned in the said letter
that if the noticee fails to redress the complaint, SEBI may take action against the
noticee under Sections 15C and 24 of the SEBI Act.

(b) SCN also refers to SEBI's letter dated February 15, 2013 wherein the noticee was
once again directed to resolve the aforesaid investor grievance of Malhotra failing
which SEBI may initiate Regulatory Actions against the noticee which includes
debarring from securities market and or / imposing penalty.
(c) It was also alleged in the SCN that as on May 24, 2013, noticee has not
approached SEBI for SCORES authentication.
5. The aforesaid SCN was returned undelivered. Thereafter, the SCN was forwarded
to the noticee,

as per the address available on the website of Ministry of

Corporate Affairs, on November 21, 2013. The copy of the SCN was also
forwarded to Bombay Stock Exchange Ltd to serve on the noticee. The proof of
service of the SCN on the noticee is on record.

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6. The noticee vide its reply dated December 12, 2013 made the following
submissions:

(a) The company had redressed the complaint of the investor and the complaint has
been finally disposed on May 03, 2013. A copy of the SCORES ATR was also
provided by the noticee along with its reply.

(b) The company has activated SCORES on May 23, 2012 and submitted the
requisite Action Taken Report (hereinafter referred to as "ATR"). The company
has been actively replying and resolving grievances of its shareholders.

7. Vide hearing notice dated April 11, 2014, noticee was granted an opportunity of
hearing on May 05, 2014 at SEBI Bhavan, Mumbai. The proof of service of the
hearing notice sent by Registered Post AD is on record. From the records, it is
noted that the noticee had failed to attend the personal hearing granted to it
inspite of service of the hearing notice as stated above.
CONSIDERATION OF EVIDENCE AND FINDINGS:
8. I have taken into consideration the facts and circumstances of the case and the
material available on record.
9. From the material available on record, it is noted that as stipulated in various SEBI
circulars, the noticee was required to obtain SCORES authentication latest by
September 14, 2012 whereas the noticee obtained SCORES authentication on
May 23, 2012 i.e. before the timeline stipulated by the SEBI. Therefore, the
allegation in this regard does not stand established against the noticee.
10. In respect to the allegation of non redressal of one investor grievance of Malhotra
for non-receipt of shares after transfer, the noticee stated that it took appropriate
steps for redressal of the said complaint and its submissions are already
mentioned at pre para no. 6.

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11. It is noted from the available records / SCORES printout as provided by the
noticee that the complaint of Malhotra was forwarded by the concerned
department of SEBI to the noticee for redressal of grievance on May 31, 2012. It is
relevant to mention that efforts were made by the noticee to redress the said
grievance on the same day i.e. May 31, 2012 (as shown in SCORES printout). The
noticee filed ATR regarding the said complaint stating that the company had asked
Malhotra to furnish details of shares and the address to which they were posted so
that his complaint regarding non-receipt of shares sent for transfer could be
redressed by the noticee.
12. As there was no response from the complainant to the letter sent by noticee, SEBI
advised noticee to send further reminders to the complainant. As advised by SEBI,
notice sent three reminders to the complainant by Speed Post vide letters dated
February 14, 2013, April 01, 2013 and April 16, 2013.
13. From the available records, it is observed that initiative / effort was taken by the
noticee to redress the said investor grievance on the same date it was forwarded
by SEBI to the noticee viz, May 31, 2012. The complaint was finally disposed of on
May 03, 2013 since there was no response from the complainant despite repeated
reminders sent to him.

14. In view of the above facts and circumstances of the case and material made
available on record, it is difficult to conclude that the noticee had failed to resolve
investor grievance, hence, the noticee has not violated Section 15C of the SEBI
Act, 1992, as alleged in the SCN.

ORDER:

15. Considering the facts and circumstances, submission of the noticee and the
material made available on record, the violation of Section 15C of the SEBI Act,
1992 is not established against Hotline Teletube & Components Ltd in the present
adjudication proceeding and accordingly the present adjudication proceeding is
disposed of.

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16. In terms of the provisions of Rule 6 of the Securities and Exchange Board of India
(Procedure for Holding Inquiry and Imposing Penalties by Adjudicating Officer)
Rules 1995, copy of this order is being sent to Hotline Teletube & Components
Ltd, having address at 52-A, Okhla Industrial Estate, Phase III, New Delhi 110
020, and also to the Securities and Exchange Board of India, Mumbai.

Date: February 16, 2015

D. RAVI KUMAR

Place: Mumbai

CHIEF GENERAL MANAGER &

ADJUDICATING OFFICER

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