This appeal is against the order made by the Adjudicating Officer on 31-1-2002 imposing monetary penalty against the Appellants, holding them guilty of violating the provision of sections 15A and 15H of the Securities and Exchange Board of India Act, 1992 (the Act) read with regulations 7(1) and 11(1) of the Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 1997 (the 1997 Regulations). The impugned order is in respect of the acquisition of nine lakh shares of Aftek Infosys Ltd. (the company) from the Industrial Development Bank of India (IDBI) some time in November 1999. The said nine lakh shares account for 15.68 per cent of the total shares of the company. The Appellants are the promoters of the company. According to the Adjudicating Officer, since the acquisition of the said shares by the Appellants was in excess of the 5 per cent bench mark provided in regulation 11(1), public announcement to acquire shares from other shareholders of the company was required to be made by them, which they failed to comply with. With reference to the finding of the failure to comply with the requirements of regulation 7(1), the Adjudicatio