Wednesday, 15 March 2017

Is it right to forcefully takeover the Board of 63 Moons?

The government had filed a petition under Section 397 & 398 read with Sections 388D, 388C, 401, 402, 403, 406 and 408 of the Companies Act, 1956 before the Principal Bench of the Company Law Board, now National Company Law Tribunal (NCLT), in New Delhi seeking removal and super session of the Board of Directors of 63 moons on the following two grounds:

1. Attempts to thwart the Amalgamation Process



    The MCA has alleged that although the 63 moons Board is attempting to frustrate the ultimate object of proposed merger, which if affected, would provide suitable recompense to the victims of the defaults. 63 moons Board is also accused of diverting funds from 63 moons and illegally selling valuable assets of 63 moons. It has also alleged that 63 moons Board is attempting to sell/dispose/alienate/ hive off valuable assets of 63 moons: i.e. approval of postal ballots notice for shareholder to sell Bourse Africa and attempt to hive off 63 moon's most popular software, ODIN.


     2. Mismanagement & Oppression Perpetrated By 63 Moons – Mcx Was Sold At Loss


     Though the MCA had applied for restraint on sale of Bourse Africa, ODIN and other assets by way of an application in Section 396 Petition, the Hon’ble Bombay High Court did not grant that relief. It must be noted however that the sale of stake in Bourse Africa has been promulgated due to regulatory issues that arose as a result of the FMC order. In fact the process for sale of stake in Bourse Africa commenced long before the Draft Order dated 21st October, 2014 for amalgamation of NSEL with 63 moons was even passed. In affidavit in reply MCA stated that MCA do not have objection for sale of investments if it is directed by the regulators.  With respect to ODIN, the information was in the public domain prior to filing of the Writ Petition by 63 moons challenging the Draft Order.


The MCA says that 63 moons’ current Board is opposing the merger hence justify taking over 63 moons’ management, conveniently setting aside the fact that the merger of NSEL with 63 moons is still sub-judice. Again, the MCA’s draft order invoking Section 396 of the Act doesn’t anywhere say why a merger of NSEL with 63 moons is in public interest. The MCA also ignored that 63 moons has the fiduciary responsibility to protect the interest of 63,000 shareholders, over 1,000 employees and other stake holders. 63 moons has been lawfully opposing the merger with humble submission to restrain from any hasty decision when the matter is sub-judice.


The MCA has alleged that due to mismanagement of NSEL by 63 moons and its directors, the FMC passed an order and 63 moons had to divest in a number of commodity exchanges in India and overseas, which caused a loss of investment, which raises a serious doubt on the viability of 63 moons. It has also alleged that 63 moons’ divestment in MCX is in complete contravention to the FMC order which only stated that 63 moons is not “Fit & Proper’ (but didn’t direct divestment), but 63 moons sold its entire stake (26%) at a loss of Rs. 290 crore. Such actions by the 63 moons Board raise serious apprehensions of the continuance of Board.


The MCA itself in its petition states that FMC directed 63 moons is not fit & proper to continue to hold 2% or more paid-up equity capital in MCX and therefore to salvage the value of MCX, without prejudice 63 moons divested its shareholding in MCX.  The FMC and other regulators forced 63 moons to exit, despite the FMC Order being sub-judice and despite 63 moons contesting the same vigorously in the relevant regulatory / appellate authority. It is absurd that compliance with regulatory orders by 63 moons to salvage value of its investments in time – before they are rendered worthless by regulatory wrath such as cancellation of license, renewal of contracts, issuance of new contracts or putting shares in escrow followed by auction etc. – is being used against 63 moons and its Board.
63 moons, without prejudice to its rights, divested its holdings in companies as a result of regulatory directions to do so. In the case of MCX, there have been numerous letters from MCX insisting that 63 moons divest its holdings in short time as a result of the FMC Order. Pertinently, those letters also say that the regulator, i.e. FMC is not permitting launch of any new contracts to MCX unless compliance of divestment is made. Accordingly, FMC had threatened to bring down the value of 63 moons’ holding to almost nil had it not complied with the direction of divestment. The Board of 63 moons divested from MCX in manner where the loss caused to 63 moons and its shareholders was significantly reduced.

None of the members of 63 moons have made an application that the Company’s affairs in a manner oppressive to any member or members; however MCA invoked the Section under Sec 408 without validating how the affairs of the Company being conducted either in a manner which is oppressive to any members of the Company or in a manner which is prejudicial to the interests of the Company or to public interest. 

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