Statement in lieu of prospectus vs listing

Hi all,

An unlisted public company (Pvt co. converted to a public co.) wishes to raise funds from prospective investors. A Statement in Lieu of Prospectus (SLP) is to be filed as per section 44 of companies act. It is assessed that the number of prospective shareholders will be more than 50.

Question - Is it necessary that the company should get itself listed, if the no. of shareholders is more than 50 (since section 67 deems any invitation for offer of shares to 50 or more persons as an Offer to public). Can't the company raise funds from more than 50 investors by filing a SLP without getting itself listed? Please guide.