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    <description>Non-disclosure of the rejection of forest and environmental clearances for a mining project central to the issuer&#039;s business was a material, price-sensitive omission because the prospectus had to contain true and adequate disclosures and merchant bankers had a due-diligence duty to verify them. General risk-factor language and later attempts to seek reconsideration did not cure the defect, so the disclosure violation was upheld. On penalty, the violations were established but mitigating circumstances justified reduction of the sanctions for the issuer and merchant bankers; the penalty on the listed company was sustained because the statutory listing penalty applied to companies as well and was not excessive.</description>
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