Ronak Ltd. is a public company listed on BSE. Its share capital is ₹ 2,75,00,000 consisting of 27,50,000 shares of ₹ 10 each. The public holding in the company is 47% of the total shares and rest of 53% shares are held b

Regulation 3 (2) of the SEBI (Substantial Acquisition of Shares and Takeovers) Regulation 2011 (Takeover Regulations) provides that - No acquirer, who together with persons acting in concert with him, has acquired and holds in accordance with these regulations shares or voting rights in a target company entitling them to exercise twenty-five percent (25%) or more of the voting rights in the target company but less than the maximum permissible non-public shareholding, shall acquire within any financial year additional shares or voting rights in such target company entitling them to exercise more than five percent (5%) of the voting rights, unless the acquirer makes a public announcement of an open offer for acquiring shares of such target company in accordance with these regulations: Provided that such acquirer shall not be entitled to acquire or enter into any agreement to acquire shares or voting rights exceeding such number of shares as would take the aggregate shareholding pursuant to the acquisition above the maximum permissible non-public shareholding. Therefore, since the shareholding of the acquirer is between twenty-five percent (25%) of the total shares and the maximum permissible non-public shareholding limit, hence they can acquire five percent (5%) additional shares in the F.Y. 2013-14. Disclosure of Acquisition and Disposal 29. (1) Any acquirer who acquires shares or voting rights in a target company which taken together with shares or voting rights, if any, held by him and by persons acting in concert with him in such target company, aggregating to five percent (5%) or more of the shares of such target company, shall disclose their aggregate shareholding and voting rights in such target company in such form as may be specified. (2) Any person, who together with persons acting in concert with him, holds shares or voting rights entitling them to five percent (5%) or more of the shares or voting rights in a target company, shall disclose the number of shares or voting rights held and change in shareholding or voting rights, even if such change results in shareholding falling below five percent (5%), if there has been change in such holdings from the last disclosure made under sub-regulation (1) or under this sub-regulation; and such change exceeds two percent (2%) of total shareholding or voting rights in the target company, in such form as may be specified. (3) The disclosures required under sub-regulation (1) and sub-regulation (2) shall be made within two working days of the receipt of intimation of allotment of shares, or the acquisition of shares or voting rights in the target company to, - Every stock exchange where the shares of the target company are listed; and The target company at its registered office. (4) For the purposes of this regulation, shares taken by way of encumbrance shall be treated as an acquisition, shares given upon release of encumbrance shall be treated as a disposal, and disclosures shall be made by such person accordingly in such form as may be specified: Provided that such requirement shall not apply to a scheduled commercial bank or public financial institution as pledgee in connection with a pledge of shares for securing indebtedness in the ordinary course of business.