Justice J.P. Devadhar, Presiding Officer - Appellants in these two appeals are aggrieved by orders passed by the Adjudication Officer ("AO" for short) of Securities and Exchange Board of India ("SEBI" for short) on July 31, 2013 and August 6, 2013 respectively. By the said orders penalty is imposed upon appellants under Section 23E of the Securities Contracts (Regulation) Act, 1956 ("SCRA" for short) and Section 15HA of the Securities and Exchange Board of India Act, 1992 ("SEBI Act, 1992" for short) for allegedly violating clause 35 of the Listing Agreement and Regulations 3(d) and 4(2)(f) of Securities and Exchange Board of India (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003 ("PFUTP Regulations" for short) respectively. Since common question of law is involved in these two appeals, both these appeals are heard together and disposed of by this common decision.

2. Common question of law raised in these two appeals is:—

"Whether a listed Company under the format annexed to clause 35 of the Listing Agreement is required to disclose to the Stock Exchange, details of 'otherwise encumbered' shares of that listed Company held by