An acquirer holds 22% of the voting rights of a listed company and acquires a further block of shares which takes his holding to 27%. Under the SEBI (SAS

Regulation 3 of the SEBI (SAST) Regulations, 2011 provides that an acquirer who acquires shares or voting rights which take his holding to TWENTY-FIVE PER CENT or more of the target company must make a public announcement of a mandatory OPEN OFFER to acquire a minimum of 26% of the shares. Crossing 25% is the trigger; the acquisition at 27% accordingly obliges a public offer. Because the acquirer had crossed the threshold in a single acquisition taking him to 27%, the open-offer requirement applies, subject to the exemptions in Regulation 3(4). Disclosure-only obligations arise at the 5%/10% levels, not beyond 25%.