Private placement of securities

I have one question that has been troubling me. We all read about the SC verdict in the Sahara case. In any private placement, one has to reach out to atleast 100-200 people as everyone may not be interested in investing. Out of these 100-200 only around 20-30 might invest. Now my question is - if i want to raise money for a private company and send invitation to around 100 people with the condition that i will take money only from <50, would that still be construed as a public issue.