Held, that the plea of the Appellant company that it had changed its Registrar and Transfer Agent due to which the data base of the shareholders could not be shifted to the new agent on account of lack of coordination between the two was unconvincing and unacceptable. The shareholders of the company were denied the right to trade in the shares for no fault of theirs. The Appellant was guilty of culpable negligence in dealing with the requests from the investors. The adjucating officer was justified in passing such order penalizing the Appellant company..