It is alleged in the complaint that the promoters of NDTV - Dr. Prannoy Roy, Smt Radhika Roy and M/s RRPR Holdings Pvt Ltd, acting in criminal conspiracy with unknown officials of ICICI bank, violated section 19(2) of the Banking Regulation Act, the Master Circular DBOD No. Dir B90/13.07.05/98-99 dated 28.08.1998 of the Reserve Bank of India and in furtherance of the conspiracy, ICICI bank took the entire shareholding of the promoters in NDTV(nearly 61 %) as collateral and then accepted prepayment of the loan by reducing the interest rate from 19 % p.a to nearly 9.5 % p.a and as a consequence thereof, causing a wrongful loss of Rs 48 crore to ICICI bank and a corresponding wrongful gain to the promoters of NDTV - Dr. Prannoy Roy, Smt Radhika Roy and M/s RRPR Holdings Pvt Ltd.”