An unlisted public company ("Acquirer") doing business of exporting steel and it is a part of the Promoter Group of Maurya Hotels (India) Ltd. (MHIL), a company listed on stock exchange. In view of improving its efficien

Regulations 3, 4 and 5 of the SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 2011 set out the events that trigger an obligation to make an open offer on the acquirer (along with persons acting in concert). The said triggers points are as follows: Acquisition (directly or indirectly) of such shares or voting rights in an Indian listed company whereby the acquirer becomes entitled to exercise 25% or more of the voting rights in such Indian listed company; Where an acquirer (along with persons acting in concert with him) is already entitled to exercise 25% or more of the voting rights in an Indian listed company, and acquires (directly or indirectly) additional shares or voting rights entitling an acquirer to exercise more than 5% voting rights in an Indian listed company, in a financial year; and Acquisition (directly or indirectly) of control. Since the Acquirer, in the above facts, does not attract any of the triggers set out above, the transfer of shares will not impose any obligation on the Acquirer to make an open offer under the SEBI (SAST) Regulations.