SEBI Circular Not Applicable to Pre-October 13, 2020 Defaults; Applies Post-Incorporation in Debenture Trust Deeds.

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....SEBI Circular applicability - We have already held that the SEBI Circular cannot be applied to defaults committed prior to 13th October, 2020. This being so, the subsequent incorporation of the SEBI Circular to the DTDs by virtue of the Supplementary Debenture Trust Deed(s) executed on 11th March, 2021 could only logically apply the SEBI Circular to defaults occurring post such incorporation or at best, to defaults post 13th October, 2020. - HC....