Ann: Change in substantial holding - Mankar, page-128

It certainly would be harder to infer he was trying to be fraudulent. As someone pointed out he has sold over this period without regard it would seem to day to day fluctuations selling on down days as well as normal trading range days.

There is an underlying principle in the criminal law that states an "honest and reasonable belief based on reasonable grounds" can be a complete defence. In circumstances where someone has permission from the Board and sells as you have suggested it is reasonable to expect they could rely upon this defence to be found innocent however in such circumstances I would like to think that a competent investigation revealing these facts would not see a prosecution launched in the first instance.

My opinion only DYOR
FF.

AKIDA Ballista