Supreme Court of India (Division Bench (DB)- Two Judge)

Appeal (Civil), 5275 of 2006, Judgment Date: Nov 24, 2015

                                                                  REPORTABLE

                        IN THE SUPREME COURT OF INDIA

                        CIVIL APPELLATE JURISDICTION

                        CIVIL APPEAL NO.5275 OF 2006


Securities & Exchange Board of India                            …..Appellant

                                  Versus

ICAP India Pvt. Ltd.                                           …..Respondent



                               J U D G M E N T

SHIVA KIRTI SINGH, J.

This appeal under Section 15Z of the Securities & Exchange  Board  of  India
Act,  1992  (for  brevity,  ‘the  SEBI  Act’)  has  been  preferred  by  the
Securities & Exchange Board of India (for brevity, ‘the SEBI’) to  challenge
the judgment and order dated 14.08.2006 passed  by  the  learned  Securities
Appellate Tribunal (hereinafter referred to as ‘the SAT’)  in  Appeal  No.56
of 2004.
The  substantial  question  of  law  falling  for   determination   involves
interpretation of the term ‘annual turnover’ as  it  finds  mention  in  the
Explanation after paragraph 3 of Schedule III to the Securities  &  Exchange
Board  of  India  (Stock  Brokers  &  Sub-brokers)  Regulations,  1992  (for
brevity, ‘the Regulations’).  The aforesaid Explanation reads as follows :

“Explanation. – For the purpose of paragraphs 1, 2 and 3, “annual  turnover”
means the aggregate of the sale and purchase prices of  securities  received
and receivable by the stock broker on his own account as well as on  account
of his clients in respect of sale and  purchase  or  dealing  in  securities
during any financial year.”

The factual matrix may be noted only in brief.  The respondent  is  a  stock
broker in the wholesale debt market segment of the National  Stock  Exchange
and deals in debt market securities.  The stand of the  respondent  is  that
the price of the dealt with securities would not form part of the  concerned
broker’s ‘annual turnover’ and the same cannot be the  basis  for  computing
the registration fee of stock brokers like the respondent.   This  stand  is
based on a circular of Reserve Bank of  India  (for  brevity,  ‘RBI’)  dated
June 20, 1992, issued with a view to regulate  the  wholesale  debt  market.
The dispute in respect of quantum of registration fee demanded by  the  SEBI
was brought before the SAT  by  way  of  challenge  to  SEBI’s  order  dated
November 28, 2003 directing the respondent to pay Rs.33,51,45,620/-  towards
principal and Rs.3,78,29,623/- towards interest as  on  November  30,  2003.
As noticed above the SAT allowed the appeal of the respondent and set  aside
the order passed by SEBI vide its judgment and order under appeal.
The circular dated June 20, 1992  issued  by  RBI  as  a  regulator  of  the
wholesale debt market is the  basis  for  the  SAT  to  hold  that  for  the
permissible  activity  of  bringing  the  parties  together,  no  amount  is
received or receivable by the stock broker when he deals  in  the  wholesale
debt  segment  of  the  market  and  therefore  the  definition  of  “annual
turnover” for the purpose of paragraphs 1, 2 and  3,  as  contained  in  the
Explanation to Paragraph 3  of  Schedule  III  to  the  Regulations  is  not
satisfied.  Before adverting to other relevant facts it is useful to  notice
the relevant part of this circular which reads as under :

“III. DEALINGS THROUGH BROKERS

(i)   If a deal is put through with the help of a broker, the  role  of  the
broker should be restricted to that of bringing the two parties to the  deal
together.

(ii)  While negotiating the deal, the broker is not obliged to disclose  the
identity of the counterparty to the deal.  However,  on  conclusion  of  the
deal, he should disclose the counter party  and  his  contract  note  should
clearly indicate the name of the counterparty.

(iii) On the  basis  of  the  contract  note  disclosing  the  name  of  the
counterparty, settlement of deals between banks, viz., both fund  settlement
and delivery of security, should be directly  between  the  banks,  and  the
broker should have no role to play in the process.

(iv)  With the approval of their top managements,  banks  should  prepare  a
panel of approved brokers which should be reviewed annually, or  more  often
if so warranted.  Clear-cut criteria should be laid down for empanelment  of
brokers,  including   verification   of   their   creditworthiness,   market
reputation, etc.  A record of broker wise details of deals put  through  and
brokerage paid, should be maintained.

(v)   A disproportionate part of  the  business  should  not  be  transacted
through only one or a few brokers.  Banks should consider  fixing  aggregate
contract limits for each of the approved  brokers,  and  ensure  that  these
limits are not exceeded.”

The stand of  the  appellants  is  that  the  SAT  has  mis-interpreted  the
Explanation to paragraph 3 to hold that the “turnover” for  purpose  of  fee
will not be the value of the stocks under transaction but only the value  of
brokerage earned by the stock brokers like  the  respondent.   According  to
Mr. C.U. Singh, learned senior counsel for the SEBI the respondent is  bound
by the provisions of the SEBI Act, the rules framed thereunder  as  well  as
the Regulations.  The law does not permit any one to act as a  stock  broker
either in respect of shares  in  the  equities  segment  or  the  Government
securities in the wholesale debt segment until he  is  registered  with  the
SEBI. Such registered broker has to pay the prescribed fee as  per  Schedule
III of the Regulations.  He highlighted clause  1(bb)(ii)  of  Schedule  III
which was inserted by the Amendment Regulations of 2002 w.e.f. February  20,
2002.  It is the case of the appellant that clause 1(bb)(ii) was  introduced
in  the  Regulations  because  the  SEBI  accepted  the  Bhatt   Committee’s
recommendations for fixing a lower rate of fees for  transactions  in  bonds
and securities.  The lower rate for transactions  in  bonds  and  Government
securities was on account of comparative higher value of  such  transactions
leading to higher turnover and that justified imposition of  lower  rate  of
fees.  The grievance of the appellant is that the SAT did not consider  such
clear  substantive  provision  and  its  history  while   interpreting   the
Explanation in a  manner  which  amounts  to  doing  violence  to  the  main
provision itself.  Learned  counsel  for  the  appellant  also  referred  to
judgment of this Court in the case of B.S.E. Brokers’ Forum v. Securities  &
Exchange Board of India (2001) 3 SCC 482 and pointed out that  in  paragraph
43 the Court noted that the petitioners of that  case  had  strongly  relied
upon the Report submitted by the Bhatt Committee.  Further in  paragraph  47
the Court rejected the contention of  the  petitioners  after  noticing  the
recommendations of the Bhatt Committee to the  effect  that  “on  Government
securities, PSU bonds and units, the turnover will  have  to  be  calculated
separately and a fee of 1000th of 1% may be charged on  such  turnover  than
the present scale of 100th of 1%.”  Thereafter the Court observed  that  the
Board was bound to bring about the corresponding changes  so  as  to  remove
the anomalies pointed out by the Committee.  It also noted  that  the  Board
or the SEBI had accepted the recommendations and they would be  incorporated
in  the  Regulations.    The   Court   concluded   that   subject   to   the
recommendations  of  the  Bhatt  Committee  to  be   incorporated   in   the
Regulations, the challenge  made  to  the  levy  based  on  the  measure  of
turnover had to be rejected.
On behalf of appellant it was further pointed out that through  Notification
No.S.O. 184(E) issued by the SEBI  and  Notification  No.S.O.(E)  issued  by
RBI, both dated March 01, 2000 it was made  clear  that  all  contracts  for
sale  or  purchase  of  Government  securities  when  entered  into  through
recognized stock exchanges, would be subject to  the  SEBI  Act,  Securities
Contracts (Regulation) Act, 1956 as well  as  rules,  regulations,  bye-laws
and circulars made under those Acts.  It was also pointed out  that  Section
2(h)  of  the  Securities   Contracts   (Regulation)   Act,   1956   defines
“securities” to include not only Government securities but  also  rights  or
interests in securities. Hence, according to appellant the physical  receipt
of securities or payments is not necessary.  It  was  further  contended  on
behalf of appellant that the circular of  RBI  of  1992  cannot  affect  the
statutory regime governing fees payable by a registered broker to  the  SEBI
as per provisions in the Regulations.  Lastly  it  was  submitted  that  the
appellant has calculated and demanded the fee as per clause 1(b) instead  of
clause 1(bb)  because  the  respondent  did  not  disclose  details  of  its
different transactions.
On behalf of appellant reliance was placed upon judgment of  this  Court  in
the case of K.P. Varghese v. Income-tax Officer, Ernakulam (1981) 4 SCC  173
to highlight various principles relating to interpretation of statutes.   In
particular, reliance was placed upon the principle  that  plain  meaning  or
literal construction may not be relied upon  if  it  results  in  absurdity,
injustice  and  unconstitutionality.   In  such  a  situation  Court  should
construe the real meaning having regard to the  object  and  purpose  behind
enacting the provision as well as the context of the  setting  in  which  it
occurs and with a view to suppress the mischief sought  to  be  remedied  by
the Legislature.
In reply Mr. Jayant Bhushan, learned senior advocate submitted that  in  the
case of B.S.E.  Brokers’  Forum  this  Court  upheld  the  validity  of  the
registration fees levied by the SEBI but there was no occasion in that  case
to interpret the term ‘turnover’ as defined  through  the  Explanation.   He
also referred  to  an  Explanation  to  clause  2  of  Schedule  IV  of  the
Regulations only for comparing the two Explanations and  pointing  out  that
while laying down the Schedule  of  Fees  to  be  paid  by  the  Trading  or
Clearing Member or Self Clearing Member  the  expression  ‘annual  turnover’
has been defined differently so as  to  take  into  account  “the  aggregate
value of all trades  executed  by  the  trading  member  …..”.   By  placing
reliance upon pleadings of the SEBI, the  view  taken  by  the  SAT  in  the
impugned judgment was sought to be supported further on the ground  that  in
respect of wholesale  debt  market  SEBI  merely  ‘monitors’  and  does  not
‘regulate’ and therefore there  can  be  no  justification  to  include  the
entire value of stocks in the  turnover  for  calculating  the  registration
fee.   It  was  conceded  however  that  the  wholesale  debt   market   was
considerably widened in 2003 and SEBI may  claim  that  it  is  required  to
regulate the wholesale debt market from 2003 onwards  but  that  should  not
affect the present case which is related to an  earlier  period,  only  upto
December 2002.  Mr. Bhushan took us through the documents and  pleadings  to
counter the allegation that respondent did  not  disclose  the  details  and
particulars of  its  business  deals/accounts.   According  to  him,  it  is
admitted in the inspection report that the  respondent  dealt  only  in  the
wholesale debt market segment.
On behalf  of  respondent  reliance  was  placed  upon  case  of  Income-tax
Officer,  Alleppey  v.  I.M.C.  Ponnoose  AIR  1970   SC  385  and  case  of
Government of Andhra Pradesh v. P. Laxmi Devi (2008) 4 SCC  720  in  support
of a well established proposition of law that unless  the  Statute  empowers
the concerned authority to make a  rule  or  regulation  with  retrospective
effect, such authority cannot  make  a  rule,  regulation  or  bye-law  with
retrospective effect.
Lastly it was pointed out from the materials on record that  respondent  had
raised several other grounds for objecting to the  impugned  action  of  the
SEBI but the SAT allowed respondent’s appeal on the basis of  interpretation
of the term ‘annual turnover’ and did not deal with other grounds.
We do not find any merit  in  the  contention  advanced  on  behalf  of  the
respondent that the Explanation under clause 2 of Schedule IV  can  be  used
in contradistinction of differently worded Explanation under paragraph 3  of
Schedule III to support the interpretation of  the  term  ‘annual  turnover’
given by the SAT.   While  Schedule  III  relates  to  Regulation  10  which
governs fees to be paid by the  stock  broker  or  sub-broker,  Schedule  IV
relates to Regulation 16G(1) which governs fees to be paid  by  the  Trading
or  Clearing  Member  or  Self  Clearing  Member  of  Derivatives  Exchange/
Derivatives Segment/  Clearing  Corporation/  Clearing  House.   In  such  a
situation, in our view, the term ‘annual  turnover’  has  to  be  understood
only in the light of Schedule III and its contents  including  the  relevant
Explanation.
On a careful analysis of the Explanation  occurring  after  paragraph  3  of
Schedule III and the definition of ‘annual turnover’  contained  therein  as
also the reasonings in the impugned order we are constrained  to  hold  that
the SAT has erred in limiting the annual turnover of the respondent only  to
the amount of brokerage earned by it.   The  earning  by  way  of  brokerage
represents only the part of  price  of  securities  received  by  the  stock
broker on his own account.  The other  and  more  significant  part  of  the
‘annual turnover’ as per the Explanation is the aggregate of  the  sale  and
purchase prices of securities, received or receivable by  the  stock  broker
on account of his clients in respect of sale  and  purchase  or  dealing  in
securities during the financial year.  The view taken by the SAT that  since
in the wholesale debt market segment the broker has a limited  role  as  per
the RBI circular and since the broker does not receive the sale or  purchase
price because the payment is directly made to the seller,  the  broker  will
be saved from inclusion of the  sale  and  purchase  prices  in  his  annual
turnover,  suffers  from  an  apparent  error.   The  error  lies   in   not
appreciating that the component of aggregate of  sale  and  purchase  prices
which is receivable by the stock broker even on account of  his  clients  is
included in the annual turnover.  Such sale and  purchase  price  receivable
by the stock broker on account of his clients, under the directions  of  the
RBI through the circular dated June 20, 1992 presently goes directly to  the
seller but it is of no significance.  Even if such sale and  purchase  price
had actually been received by the stock broker not on his  own  account  but
on account of his clients, it could not belong to the broker and had  to  be
passed on to the seller  because  such  amount  was  receivable  clearly  on
account of his  clients  in  contradistinction  to  any  part  of  sale  and
purchase price received or  receivable  by  the  stock  broker  on  his  own
account.  Thus viewed, the annual turnover of the stock broker  as  per  the
Explanation must include the value of entire transaction for the purpose  of
computing the registration fee as per Schedule III of the  Regulations.   In
no case the term ‘annual turnover’ can be so interpreted  as  to  mean  only
the amount earned by the stock broker by way of brokerage.
The same conclusion will  emerge  on  considering  the  legislative  history
leading to insertion of clause 1(bb) in Schedule  III  whereby  transactions
in Government securities, bonds issued by any public sector undertaking  and
the units, traded in a similar manner were placed  in  a  separate  category
for which the fee is kept at a much lower  rate  of  1000th  of  1%  of  the
turnover.  The SAT erred in not considering the obvious purpose  of  such  a
provision brought through an amendment in the light  of  recommendations  of
the Bhatt Committee which had received not only approval  of  the  SEBI  but
also of this Court as per judgment in the case of B.S.E. Brokers’ Forum.
So far as defence of the  respondent  that  in  the  wholesale  debt  market
segment, at least prior to 2003, the SEBI was  required  only  to  ‘monitor’
and not to ‘regulate’ such market cannot cut any ice because the  provisions
relating to registration fee by the SEBI have already been  held  valid  and
in the present proceedings there is no challenge to the relevant  provisions
including those in Schedule III of the Regulations.  As  already  noted,  in
the  case  of  B.S.E.  Brokers’  Forum  this  Court  directed  the  SEBI  to
incorporate the relevant recommendations  of  the  Bhatt  Committee  in  the
Regulations and as a result the rate of fee on  Government  securities  etc.
dealt in the wholesale debt market was  lowered  and  pegged  at  1/10th  in
comparison to fees payable by the stock brokers in other segment.
In view of the above discussions and the interpretation of the term  ‘annual
turnover’ indicated by us earlier, we are constrained to hold  the  impugned
order passed by the SAT as erroneous in law.  It is accordingly  set  aside.
There is a consensus that in case the impugned judgment  and  order  is  set
aside, the matter deserves  to  be  remanded  back  so  that  other  grounds
earlier raised by the respondent  may  now  be  considered  by  the  SAT  in
accordance with law.  For that purpose the matter is remitted  back  to  the
SAT for deciding the other relevant issues and grounds  as  per  law  at  an
early date, preferably within six months.  The appeal  thus  stands  allowed
to the extent indicated above.  In the facts of the case there shall  be  no
order as to costs.  The amount of Rs.2.9 crores deposited by the  SEBI  with
the Registry has been invested in an interest bearing account  and  the  FDR
is due to mature on 30.11.2015.  As soon as the  amount  matures,  the  same
should be refunded to the SEBI without any delay.

                                                           …………………………………….J.
                                                            [VIKRAMAJIT SEN]


                                                         ..…………………………………..J.
                                                        [SHIVA KIRTI SINGH]
New Delhi.
November 24, 2015.

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