Adjudication Order against 17 entities in the matter of LGS Global Limited

8/11/2019 Adjudication Order against 17 entities in the matter of LGS Global Limited

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BEFORE THE ADJUDICATING OFFICER

SECURITIES AND EXCHANGE BOARD OF INDIA

[ADJUDICATION ORDER NO. EAD-2/AO/DSR/RG/205-221/2014]

UNDER SECTION 15 I OF SECURITIES AND EXCHANGE BOARD OFINDIA ACT, 1992 READ WITH RULE 5 OF SECURITIES AND

EXCHANGE BOARD OF INDIA (PROCEDURE FOR HOLDING

INQUIRY AND IMPOSING PENALTIES BY ADJUDICATING OFFICER)

RULES, 1995

In respect of:

1. Shri Bharat Shantilal Thakkar (PAN:AAZPT9542R)

2. Shri Bipin Jayant Thaker (PAN: ABYPT4984H)3. Shri Bharat G Vaghela (PAN: ADYPV0844N )

4. Shri Chirag Rajnikant Jariwala (PAN: AFMPJ7543L)

5. Shri Kishore Chauhan (PAN: AFPPC9703G)

6. Shri Bhavesh Pabari (PAN: AKGPP8679N)

7. Shri Prem Mohanlal Parikh (PAN: ALHPP3489N )

8. Shri Hemant Madhusudan Sheth (PAN: ANOPS8607E)

9. Ms Mala Hemant Sheth (PAN: AZXPS0694J)

10.Shri Vivek Kishanpal Samant (PAN:BRSPS0294N)

11.Shri Ankit Sanchaniya (PAN: BLNPS3316L )

12.Shri Gaurang Ajit Seth (PAN: BGEPS6596Q)

13.Shri Ketan Babulal Shah (PAN: AACPS0667F)

14.Shri Vasudev Ramchandra Kamat (PAN: ADCPK2552N)

15.Shri Jigar Praful Ghoghari (PAN: ASFPG8598L )

16.Shri Vipul Hiralal Shah (PAN: AZCPS9537P)

17.Arcadia Share & Stock Brokers Pvt. Ltd. (PAN:AAACA4562G)

In the matter of LGS Global Limited

(Now known as Ybrant Digital Limited)

Brought to you by http://StockViz.biz


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1. Securities and Exchange Board of India (hereinafter referred to as SEBI),

pursuant to the detection of a huge rise in the traded volumes and/or price of

the shares of LGS Global Limited (now known as Ybrant Digital Limited

and hereinafter referred to as LGS/company), a company listed at Bombay

Stock Exchange Limited (BSE) conducted an investigation into the alleged

irregularity in the trading in the shares of LGS and into the possible

violation of the provisions of the Securities and Exchange Board of India

Act, 1992 (hereinafter referred to as the Act) and various Rules and

Regulations made there under during the period from February 10, 2009 to

May 07, 2010. It was observed that the price of the scrip unusually

increased from `20.15 to `133.60 and the daily high-low traded volume

was 46 shares to 12, 21, 140 shares.

2. SEBI vide its interim order dated February 02, 2011 had restrained 39

persons/entities from accessing the securities market and further, had

prohibited them from buying, selling or dealing in securities in any manner

whatsoever, till further directions, in various scrips including LGS. The said

order was later confirmed by SEBI vide its order dated July 08, 2011.

3. The investigation, inter alia, revealed that certain entities namely, 1) Shri

Bharat Shantilal Thakkar, 2) Shri Bipin Jayant Thaker, 3) Shri Bharat G

Vaghela, 4) Shri Chirag Rajnikant Jariwala, 5) Shri Kishore Chauhan, 6)

Shri Bhavesh Pabari, 7) Shri Prem Mohanlal Parikh, 8) Shri Hemant

Madhusudan Sheth, 9) Ms Mala Hemant Sheth, 10) Shri Vivek Kishanpal

Samant, 11) Shri Ankit Sanchaniya, 12) Shri Gaurang Ajit Seth, 13) Shri

Ketan Babulal Shah, 14) Shri Vasudev Ramchandra Kamat, 15) Shri Jigar

Praful Ghoghari, 16) Shri Vipul Hiralal Shah (hereinafter referred to as



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Noticee No. 1 to 16 and collectively referred to as the Noticees), connected

to each other by one way or the other,had dealt in the scrip of LGS through

multiple brokers, in a fraudulent and manipulative manner, without real

change in ownership of shares, by indulging in synchronized trades thereby,

creating artificial volumes and price rise in the scrip.

4. It was further observed that Noticee Nos. 1 to 12 had also indulged in

certain trades which were self trades in nature while trading through

multiple brokers one of them being Arcadia Share and Stock Brokers

Private Limited (hereinafter referred to as Noticee No. 17), a registered

intermediary thereby, creating artificial volumes which gave a false and

misleading appearance of trading in the scrip of LGS.

5. SEBI has, therefore initiated adjudication proceedings against Noticee Nos.

1 to 16 for the alleged violation of the provisions of Regulation 3(a), (b),

(c), (d), 4(1) and 4(2)(a), (b), (e) & (g) of the SEBI (Prohibition of

Fraudulent and Unfair Trade Practices relation to Securities market)

Regulations, 2003 (hereinafter referred to as the PFUTP Regulations) and

against Noticee No. 17 for the alleged violation of the provisions of Clause

A(1), (2) & (3) of the Code of Conduct as specified under Schedule II of the

SEBI (Stock Brokers and Sub-Brokers) Regulations, 1992 (hereinafter

referred to as Broker Regulations) read with Regulation 7 of the said

Regulations.



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Appointment of Adjudicating Officer

6. I have been appointed as the Adjudicating Officer, in place of the previous

Adjudicating Officer, vide order dated August 29, 2013 under section 15 I

of the SEBI Act read with Rule 3 of the SEBI (Procedure for Holding

Inquiry and Imposing Penalties by Adjudicating Officer) Rules, 1995

(hereinafter referred to as Rules) to inquire into and adjudge under Section

15HA of the Act against the Noticee Nos. 1 to 16 for the alleged violation

of the provisions of PFUTP Regulations and under Section 15HB of the Act

against Noticee No. 17 for the alleged violation of the Broker Regulations.

Show Cause Notice, Reply and Personal Hearing

7. The Noticees were issued a common show cause notice (hereinafter to as

SCNs) dated October 08, 2013 in terms of Rule 4(1) of the Rules to show

cause as to why an inquiry should not be held and why penalty be not

imposed on them for the aforesaid violations. The SCNs were sent by

Registered Post Ack. Due and were duly delivered to the Noticees except in

case of Noticee Nos. 3 and 11 as the same were returned undelivered.

Therefore, the said SCNs were affixed at the last known addresses of the

said Noticees and the report thereof is available on record.

8. Vide letter dated October 22, 2013 one Ms. Rupal K. Chauhan, wife of

Noticee No. 5 informed that the Noticee No. 5 had passed away on May 29,

2013 and enclosed certified copy of the death certificate of Noticee No. 5 as

issued by the Department of Health and Family Welfare, Government of

Gujarat, in support thereof. In view of the same, the adjudication



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proceedings initiated against Noticee No. 5 stand abated. However, I shall

examine the role of Noticee No. 5 for the limited purpose of examining the

role and findings against the other Noticees in the matter.

9. Further, vide letter dated July 01, 2014, Noticee No. 9 filed her reply to the

SCN. Vide letter dated October 21, 2013, Noticee No. 12 also filed his reply

to the SCN. With regard to Noticee No. 17, vide letter dated October 29,

2013, it requested 3 weeks time to file its reply in the matter. Further, vide

letter dated November 18, 2013, the Noticee No. 17 submitted its reply. The

other Noticees did not file any replies in the matter.

10. Thereafter, in the interest of natural justice and in order to conduct an

inquiry as per Rule 4(3) of the Rules, an opportunity of personal hearing

was granted to the Noticee Nos. 3 and 11 on April 07, 2014 vide separate

notices dated March 07, 2014. The said notices were also affixed at the last

known addresses of the said Noticees and report of affixture is available on

record. However, the Noticee Nos. 3 and 11 did not attend the said hearing

on the scheduled date. Further, all the Noticees were granted an opportunity

of personal hearing on August 11, 2014 vide separate notices dated July 24,

2014. The said hearing notices were duly delivered to the Noticees except

for Noticee Nos. 3 and 11 and therefore, the same were again affixed at the

last known addresses of the said Noticees and report of affixture is available

on record. In the meantime, vide separate letters dated August 08, 2014, the

Noticee Nos. 1, 2, 4, 7, 10 and 11 filed their replies in the matter.

11. Noticee Nos. 6 and 8 attended the hearing on August 11, 2014 and made

oral submissions by denying the allegations levelled against them. Further,



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the Noticee Nos. 6 and 8 filed their separate replies vide letters dated

August 11, 2014 and further sought one week's time to file their detailed

replies in the matter. Accordingly, the said request was acceded to and the

Noticees were advised to file their respective replies on or before August

19, 2014. However, no replies have been received from the said Noticees

till date.

12. With respect to Noticee No. 17, the authorized representative attended the

hearing on the scheduled date and reiterated the submissions made by

Noticee No. 17 vide its reply dated November 18, 2014. The other Noticees

did not attend the hearing on the scheduled date. Noticee No. 12 vide letter

dated August 11, 2014 filed his additional reply and vide separate letters

dated August 11 and 21, 2014, Noticee Nos. 13, 14 and 15 filed their

preliminary replies in the matter and further requested extension of time to

file their detailed replies. However, no replies have been received from the

said Noticees till date.

13. In view of the above, with respect to Noticee Nos. 3 and 16, I note that

ample opportunities and time was granted to them for filing their replies and

presenting their case in the matter. Further, with respect to Noticee Nos. 1,

2, 4, 6, 7, 8, 10, 11, 13, 14 and 15, I note that the said Noticees have been

granted sufficient time to file their replies in the matter as the SCN in the

present case was issued on October 08, 2013 i.e. appx more than 10 months

back. Therefore, I am proceeding further against the said Noticees on the

basis of material available on record in the matter.

Consideration of Issues, Evidence and Findings



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14. I have carefully perused the charges levelled against the Noticees in the

SCN, written submissions made and all the documents available on the

record. In the instant matter, the following issues arise for consideration and

determination:

a)Whether the Noticee Nos. 1 to 4 and 6 to 16 have violated

Regulations 3(a), (b), (c), (d), 4(1) and 4(2)(a), (b), (e) & (g) of the

PFUTP Regulations?

b)Whether the Noticee No. 17 has violated Clauses A(1), (2) and (3) of

the Code of Conduct for Stock Brokers as specified under Schedule

II read with Regulation 7 of Broker Regulations?

c)Does the violations, if any, on the part of the Noticees attract

monetary penalty under Sections 15 HA and 15HB of the SEBI Act?

d)If so, what would be the quantum of monetary penalty that can be

imposed on the Noticees taking into consideration the factors as

mentioned under Section 15J of the SEBI Act?

15. Before proceeding forward, I would like to refer to the relevant provisions

of the PFUTP Regulations and the Brokers Regulations, which read as

under:

Relevant provisions of PFUTP Regulations

3.Prohibition of certain dealings in securities

No person shall directly or indirectly

(a)buy, sell or otherwise deal in securities in a fraudulent manner;

(b)use or employ, in connection with issue, purchase or sale of any security listed

or proposed to be listed in a recognized stock exchange, any manipulative or

deceptive device or contrivance in contravention of the provisions of the Act orthe rules or the regulations made there under;

(c)employ any device, scheme or artifice to defraud in connection with dealing in

or issue of securities which are listed or proposed to be listed on a recognized

stock exchange;



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(d) engage in any act, practice, course of business which operates or would

operate as fraud or deceit upon any person in connection with any dealing in or

issue of securities which are listed or proposed to be listed on a recognized stock

exchange in contravention of the provisions of the Act or the rules and the

regulations made there under.

4.Prohibition of manipulative, fraudulent and unfair trade practices

(1)Without prejudice to the provisions of regulation 3, no person shall indulge in

a fraudulent or an unfair trade practice in securities.

(2)Dealing in securities shall be deemed to be a fraudulent or an unfair trade

practice if it involves fraud and may include all or any of the following, namely:

(a)indulging in an act which creates false or misleading appearance of trading in

the securities market;

(b)dealing in a security not intended to effect transfer of beneficial ownership but

intended to operate only as a device to inflate, depress or cause fluctuations in the

price of such security for wrongful gain or avoidance of loss;

(c).............

(d).............

(e)any act or omission amounting to manipulation of the price of a scrip

(g)entering into a transaction in securities without intention of performing it or

without intention of change of ownership of such security;

Relevant provisions of the Broker Regulations

Stock brokers to abide by Code of Conduct.

7.The stock broker holding a certificate shall at all times abide by the Code of

Conduct as specified in Schedule II.

SCHEDULE II

CODE OF CONDUCT FOR STOCK BROKERS

[Regulation 7]

A. General.

(1) Integrity: A stock-broker, shall maintain high standards of integrity,

promptitude and fairness in the conduct of all his business.

(2)Exercise of due skill and care: A stock-broker shall act with due skill, care

and diligence in the conduct of all his business.



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(3)Manipulation: A stock-broker shall not indulge in manipulative, fraudulent or

deceptive transactions or schemes or spread rumours with a view to distorting

market equilibrium or making personal gains.

16. I find from the SCN that LGS is a company listed on the BSE. On analysis

of the trading activity in the scrip of LGS, it was noticed that a group of

entities identified as the Pabari-Parikh group in the investigation report,

including Noticee Nos. 1 to 16, who were all connected to each other in one

way or the other, had traded heavily in the scrip of LGS through multiple

brokers, one of them being Noticee No. 17. The relationship between the

entities is detailed as under:

ClientName

KYC Relation FundMovement

Sharemovementthroughoffmarket

ClientName

KYC Relation FundMovement

Sharemovementthroughoffmarket

1. BharatShantilalThakkar

Sl. no. 6 is hisnephew.Same address withsl. no.6.Sl. no. 6 is hisnominee.

Joint a/c with sl. no.6.BR* with sl. no. 2, 4,5, 7, 8, 11, 10

Withsl. no.6, 7,11,

With sl.no. 6, 15

10.VivekKishanpalSamant

Sl. no. 6 is thebrother in law &shares common Tel.no. & sl.no. 6 is thenominee of sl. no.10 for trading a/c &

bank a/c.Shares email with sl.no. 8.Shares email with sl.no. 7.

Withsl. no.8,

With sl.no. 6, 8,4, 5, 7,11.

2. BipinJayantThaker

Same Tel. no. with sl.no. 6.BR* with sl. no. 1, 4,5, 6, 7, 8, 11, 10,

Withsl. no.6.

With sl.no. 16, 4,6, 7, 8,

11.Anki tSanchaniya

Same Tel. no. withsl. no. 7 and alsoshares Tel. no. withsl. no. 6 who is thenominee for his a/c.BR* with sl. no.1, 4,5, 6, 7, 8, 10,

Withsl. no.6, 7,

With sl.no. 6, 7,8, 4, 16,10,

3. BharatGVaghela

Sl. No. 4 is nephew

of sl. no. 6 andshares same Tel. no.with sl. no. 6.

With

sl. no.4. 12.

Gaurang AjitSeth

Has common

address & Tel. no.with sl. no. 8. & sl.no. 8 and 6 bothdirectors of RajnandiYarns Pvt. Ltd.

4. ChiragRajnikantJariwala

Same Tel. no. withsl.no.6.Sl. no. 6 is his uncle.BR* with sl. no. 1, 2,

Withsl. no.6, 8, 3

With sl.no.2

13.BhupeshRathod

Introduced sl. no.8,7, 6, 5 for trading a/cand knows sl. No. 9

WithSl. No.11



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5, 6, 8, 11, 10

5.Kishore

Chauhan

Join a/c with sl. no. 6Sl. no. 6 & 8 arewitness for demata/c.BR* with sl. no. 1, 2,

4, 6, 7, 8, 11,

Withsl. no.6, 7, 8

With sl.no. 6, 7,8, 10, 14.

KetanBabulal

Shah

With sl.no.7

6.BhaveshPabari

Sl. no. 1 is his uncle& sl. no. 10 is hisbrother in law.Sl. no. 7 is cousin ofsl. no.6Sl. no. 6 & 8 bothdirectors of RajnandiYarns Pvt. Ltd.Share common Tel.no. with sl. no. 11,10, 2.Sl. no. 13 introducedhim for trading a/c.BR* with sl. no. 2, 4,5, 7, 8, 9, 11

With sl.no. 7, 8,1, 2, 11,10,

15.VasudevRamchandraKamat

Sl. no. 1 shares thesame address withsl. no.6.

With sl.no.1

7. PremMohanlalParikh

Sl. no. 7 is cousin ofsl. no.6Common email withsl. 11, 7 & 10.Sl. no. 8 is nomineeof sl. no.7.BR* with sl. no. 1, 2,4, 5, 6, 8, 11, 10.

Withsl. no.6, 8, 5

With sl.no. 6, 8,5, 1, 2, 8,16, 11,10,

16.JigarPrafulGhoghari

With sl.no. 2, 7,8, 11,

8.HemantMadhusudanSheth

Sl. no. 6 & 8 bothdirectors of RajnandiYarns Pvt. Ltd.

Same email with sl.no. 10.BR* with 13, 1, 7, 11,10, 2, 4, 5, & sl. no.9 is his wife & sl. no.12 is his nephew.

Withsl. no.6, 7, 5

With sl.no. 6, 7,5, 9, 11,

10, 16, 2,

17.VipulHiralalShah

With sl.no.6

9. MalaHemantSheth

Sl. no. 9 is the wife ofsl. no. 8 and sl. no.12 is the nephew.

Withsl. no.6, 7.

With sl.no. 8,

* Business Relations

17. In addition to the above, it was revealed that the Pabari-Paikh Group,including Noticee Nos. 1 to 16, had indulged in certain off-market transfers

for 11,90,750 shares of LGS amongst themselves during the relevant period.

These off-market transfers among the group further allegedly confirmed the

relationship / connection between the said group.



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18. From the trade log analysis, I find that the group of entities, as mentioned in

above paras, had purchased 1,02,42,859 shares accounting for 50.35% of

the total traded volume and sold 88,25,263 shares accounting for 43.38% of

the total traded volume during the relevant period. Out of the said entities,

Noticee Nos. 1 to 16 had traded for 71,94,984 shares (i.e. 35.37% of the

market volume) accounting for 70.24 % of the total purchase of the group

and 81.53% of the total sale of the group within the said Pabari-Parikh

Group entities and 35.37% of the market volume from within the group

entities. Out of the 71,94,984 shares traded within the group entities, the

buy and sell orders for 33,92,951 shares, constituting 16.68% of the market

volume, were placed within one minute time difference. Further, it was

noted that 33,92,951 shares constituted 33.13% of the total purchase of

Pabari-Parikh Group entities and 38.45% of the total sale of the Pabari-

Parikh Group entities.

19. Further, out of 33,92,951 shares, for 5,98,895 shares which accounted for

2.94% of the total market volume, the buy and sell orders were allegedly

placed in synchronised manner (i.e. difference between placement of order

by buyer and seller within one minute and order rate as well as order

quantity of buy side and sale side being the same) by Noticee Nos. 1 to 12.

The volume of 5,98,895 shares constituted 5.85% of the total purchase of

Pabari-Parikh Group entities and 6.79% of the total sale of the Pabari-Parikh Group entities. The summary of the said synchronized trades entered

into by the Noticee Nos. 1 to 12 is as under:



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PANNO ClientName

Synchronised

buytrade

%of

sync

to

total

buy

by

client

%ofMarket

Volume

Synchronised

saletrade

%of

sync

to

total

sale

by

client

%

of

Market

Volume

AAZPT9542R

BharatShantilal

Thakkar

(NoticeeNo.1) 120195 10.21 0.59 77632 6.58 0.38

ABYPT4984H

BipinJayantThaker

(Noticee

No.

2)

49386 7.61 0.24 23177

4.12 0.11

ADYPV0844N

BharatGVaghela

(NoticeeNo.3) 0 0.00 0.00 500 0.24 0.00

AFMPJ7543L

ChiragRajnikant

Jariwala

(NoticeeNo.4) 27000 5.74 0.13 37757 11.71 0.19

AFPPC9703G

KishoreChauhan

(NoticeeNo.5) 69500 7.44 0.34 54997 7.62 0.27

AKGPP8679N

BhaveshPabari

(NoticeeNo.6) 28149 4.02 0.14 24734 3.60 0.12

ALHPP3489N

Prem

Mohanlal

Parikh

(NoticeeNo.7) 57062 6.34 0.28 73036 11.63 0.36

ANOPS8607E

Hemant

MadhusudanSheth

(Noticee

No.

8)

108777 3.67 0.53 213521

8.22 1.05

AZXPS0694J

Mala

Hemant

Sheth

(Noticee

No.

9)

0 0.00 0.00 8500

2.65 0.04

BGEPS6596Q

GaurangAjitSeth

(NoticeeNo.12) 500 2.27 0.00 0 0.00 0.00

BLNPS3316L

AnkitSanchaniya

(NoticeeNo.11) 28101 3.08 0.14 36150 4.13 0.18

BRSPS0294N

VivekKishanpal

Samant

(NoticeeNo.10) 110225 13.58 0.54 48891 8.03 0.24

Grand

Total

598895 5.85 2.94 598895

6.79 2.94

20. I also find that Noticee Nos.1 to 12 had allegedly indulged in certain trades

which were self trades in nature while trading through their multiple brokers



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including Noticee No. 17. The details of the said fictitious trades are as

under:

PANNO ClientName TotalBuy TotalSale

Self

trade

qty

%

of

Total

Buy

%

Total

Sale

%of

Mark

et

Volu

me

No

of

Self

trad

es

AAZPT9542R

BharatShantilal

Thakkar

(NoticeeNo.1) 1176987 1179456 23264 1.98 1.97 0.11 22

ABYPT4984H

Bipin

Jayant

Thaker

(Noticee

No.

2)

648777 562659 26898 4.15

4.78

0.13 26

ADYPV0844N

BharatGVaghela

(NoticeeNo.3) 256572 211799 20 0.01 0.01 0.00 1

AFMPJ7543L

ChiragRajnikant

Jariwala(NoticeeNo.4) 470041 322300 45685 9.72 14.17 0.22 10

AFPPC9703G

KishoreChauhan

(Noticee

No.

5)

934416 722216 1000 0.11

0.14

0.00 1

AKGPP8679N

BhaveshPabari

(Noticeeno.6) 700032 686402 28860 4.12 4.20 0.14 9

ALHPP3489N

PremMohanlal

Parikh

(NoticeeNo.7) 900352 627742 79563 8.84 12.67 0.39 18

ANOPS8607E

Hemant

MadhusudanSheth

(Noticee

No.

8)

2960225 2599035 484619 16.37

18.65

2.38 138

AZXPS0694J

Mala

Hemant

Sheth

(NoticeeNo.9) 320268 320756 8725 2.72 2.72 0.04 2

BGEPS6596Q

GaurangAjitSeth

(NoticeeNo.12) 22000 18000 1565 7.11 8.69 0.01 1

BLNPS3316L

AnkitSanchaniya

(NoticeeNo.11) 912651 875458 43410 4.76 4.96 0.21 9

BRSPS0294N

VivekKishanpal

Samant

(Noticee

No.

10)

811677 608829 51000 6.28

8.38

0.25 9

GrandTotal 10113998 8734652 794609 7.86 9.10 3.91 246

21. For the above fictitious trades, it was noted that the brokers mentioned in

the table below were appearing on both the sides of the trade i.e. acted as

broker and counter party broker. The number of instances wherein the



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Noticee No. 17 had executed self trades on behalf of its clients was

significant and the details of the same are as under:.

Buy

and

Sale

Member

Name

Client

Name

Total

Traded

Qty

No.

of

Trades

Arcadia

Share

&

Stock

BrokersPvt.Ltd.

AnkitRajendraSanchaniya

(Noticeeno.11) 3762 2

BharatGVaghela

(Noticee

no.

3)

20

1

Bharat

Shantilal

Thakkar

(NoticeeNo.1) 12154 19

BhaveshPabari

(NoticeeNo.6) 110 2

BipinJayantThaker


Hemant

Madhusudan

Sheth(NoticeeNo.8) 200 1

Kishore

Chauhan


ArcadiaShare&StockBrokersPvt.Ltd.

(NoticeeNo.17) Total 18745

28

FairwealthSecuritiesP.Ltd.

AnkitRajendraSanchaniya


FairwealthSecuritiesPvt.Ltd. Total 500 1

Globe

Capital

Market

Ltd.

Chirag

Rajnikant

Jariwala

(Noticee

No.

4)

85

1

GlobeCapitalMarketLtd. Total 85 1

GrandTotal 19330 30

22. From the price volume data analysis, I note that the scrip of LGS was traded

on 301 trading days. Out of 301 trading days, the group entities including

the Noticee Nos. 1 to 16 had traded among themselves on 145 days, i.e.

48% of the total number of days the scrip was traded during the period

under investigation. It was noted that the Pabari-Parikh Group entities had

contributed to daily market volume of the scrip in the range from 0.90% on

March 08, 2010 to 95.07% on April 09, 2010. It was further alleged in the

SCN that out of 145 trading days, on 68 trading days the Pabari-Parikh



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Group entities, including the Noticee Nos. 1 to 16, had traded amongst

themselves and thereby had contributed more than 50% to the total market

volume traded in the scrip during the relevant period.

23. On further examination, I find that out of 145 trading days on which the

Pabari-Parikh Group had entered into trades in the scrip of LGS, on 125

trading days both the buy and sell orders were placed within time difference

of one minute. It was, therefore, alleged in the SCN that the Pabari-Parikh

Group entities, including the Noticee Nos. 1 to 16, had contributed to daily

market volume of the scrip in the range from 0.30% on August 31, 2009 to

88.88% on February 15, 2010. Out of 125 trading days, on 11 trading days

the Pabari-Parikh Group entities, including the Noticee Nos. 1 to 16, had

contributed more than 50% to the total market volume by placing both the

buy and sell order within one minute time difference. It was also alleged

that out of 125 trading days, on 41 trading days the trades executed by the

Pabari-Parikh Group entities, including the Noticee Nos. 1 to 16, were

synchronised in nature. By executing synchronised trades among the group

entities, the Pabari-Parikh Group entities had contributed to total market

volume of the scrip in the range from 0.2% on November 20, 2009 to

56.11% on January 14, 2010. Further, on two trading days, by entering into

synchronised trades the group entities had contributed more than 50% to the

total market volume traded in the scrip during the relevant period.

24. It was, therefore, alleged in the SCN that the Noticee Nos. 1 to 16, by

indulging in the manipulative trade practices as mentioned above, had

violated Regulations 3(a), (b), (c), (d), 4(1) and 4(2)(a), (b), (e) & (g) of the

PFUTP Regulations thereby, created artificial volumes and price in the scrip



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of LGS and further alleged that the Noticee No. 17, by executing the

manipulative trades on behalf of Noticees, had violated Clauses A(1), (2)

and (3) of the Code of Conduct for Stock Brokers as specified under

Schedule II read with Regulation 7 of the Broker Regulations.

Submissions made by the Noticees:

Noticee Nos. 1, 2, 4, 6, 7, 8, 10 and11:

25. Vide separate but identical letters dated August 08, 2014, the Noticee Nos.

1, 2, 4, 7, 10 and 11 submitted that they have been debarred from buying,

selling and dealing in the securities market vide SEBI order dated February

02, 2011. Further, the said Noticees stated that as the investigation period is

4 years old, they are in a process of collating the data and file their detailed

reply in the matter. They further sought 25 to 35 days time for filing

detailed reply in the matter. With respect to Noticee Nos. 6 and 8, vide

separate but identical letters dated August 11, 2014, denied all the charges

levelled against them in the SCN and further sought 30 days time for filing

detailed reply in the matter. However, it is noted that the said Noticees have

not filed any further replies in the matter till date.

Noticee No. 9:

26. The Noticee No. 9 vide her reply dated July 01, 2014 submitted that vide

SEBI order dated July 08, 2013 the Noticee is still debarred from trading in

the securities market and her demat account stands frozen. The Noticee

states that initiation of adjudication proceedings in the matter (although the

earlier debarment being still in force) is a "double jeopardy". She further

submits that she had traded in many scrips during and prior to the relevant

period and LGS was one of the scrips. The Noticee No. 9 admits that she is



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the wife of Noticee No. 8 i.e. Shri Hemant Madhusudhan Sheth however,

denied having any business or professional connection with him and stated

that she takes independent trading decisions. The Noticee has denied having

made any monetary transactions with Noticee Nos. 6 and 7 (Shri Bhavesh

pabari and Shri Prem Mohanlal Parikh).

27. The Noticee No. 9 submitted that she is not connected with any of the

entities forming part of the Pabari-Parikh Group and had dealt in the shares

of LGS independently. Further, she confirmed that she had bought 3,20,368

shares and sold only 3,20,756 shares. However, she stated that the said

purchase and sale of shares accounted only for 1.57% and 1.58%

respectively of the total traded volume in LGS during the relevant period

which is very miniscule quantity to arrive at a conclusion that the said

transactions created artificial volumes in the scrip. The Noticee No. 9 has

admitted the fact that she had received 37,000 shares of LGS in an off

market transaction from Noticee No. 8 and were borrowed by her from

Noticee No. 8 to meet her pay in obligations but she denies having any

professional connection with Noticee No. 8. She submits that only 0.33% of

the market volume traded by her on the buy side was in the form of

synchronised trading and only 0.72% of the market volume traded by her on

the sell side was in the form of synchronised trading. The volume of

synchronised trades as alleged in the SCN i.e. 1.57% on the buy side and

1.58% on the sell side is a miniscule volume and cannot impact the

equilibrium of the scrip. Further, there are very few trades out of her total

trading wherein the time difference was less than 1 minute and she

submitted that majority of trading was ranging in the time difference of



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more than 1 minute to more than 4 hours for the shares purchased by her

and from one minute to more than 42 minutes for the shares bought by her.

28. While trading within the group, Noticee No. 9 submitted that the trades

wherein she had sold shares to the persons belonging to the group

constituted only 0.46% of the total market volume of the scrip and the

trades wherein she had bought shares from the group entities constituted

slightly more than 1% of the total market volume traded in the scrip of

LGS. Further, one of the sale transaction for 10000 shares executed by

Noticee No. 9 through broker, Sunidhi Securities and Finance Limited had

matched with the buy transaction of Noticee No. 6 i.e. Shri Bhavesh Pabari.

The Noticee submitted that the said transaction cannot be said to have

created artificial volumes in the said scrip. With respect to the self trades

allegation, the Noticee No. 9 denied having entered into any self trades. She

stated that the orders were given to broker well in advance and the broker

by analysing the trading pattern in the scrip punched the orders in the

system. The Noticee states that the volume contributed by the so called self

trades was only 0.04% to the total market volume.

Noticee No. 12:

29. The Noticee No. 12 vide his reply dated October 21, 2013 denies being

connected/ related with Noticee No. 8 by way of having same address and

telephone numbers. Further, the Noticee submitted that he has not dealt in

any off market transactions in the scrip of LGS and had traded

independently. The Noticee states that the synchronised trades which have

alleged in the SCN are miniscule in quantity. Further, with regard to self

trades, the Noticee No. 12 stated that the same were done unintentionally



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and were done to adjust his financial position with one of his brokers. Vide

letter dated August 11, 2014, the Noticee No. 12 submitted his detailed

reply in which he reiterated the submissions made by him in his earlier

reply. The Noticee inter-alia submitted that he is not staying with Noticee

No. 8 i.e. Shr Hemant Madhusudan Sheth and also is not sharing a common

telephone number. The Noticee further stated that he has not entered into

any fund or off market transactions with Noticee No. 6 i.e. Shri Bhavesh

Pabari.

Noticee No. 13:

30. Vide letter dated August 11, 2014 the Noticee No. 13 submitted his reply in

the matter. He submitted that he is in a business of buying and selling gold

and silver readymade ornaments and that he does his business from his

office. The decision of trading and investment is completely taken

independently by the Noticee and is not influenced by any other person.

The Noticee denies being part of the Pabari-Parikh Group. The Noticee

states that all the trades were executed by him through one broker viz.

Globe Capital Market Limited and were delivery based and therefore, there

is no question of the said trades being synchronised or circular in nature.

The Noticee also denies the off market transactions alleged to have entered

by him in the SCN. He submitted that he had bought and sold 13,000 shares

of LGS during the relevant period on the market and had traded in his own

account through the above mentioned broker. The Noticee states that none

of his trades have been found to have been self or synchronised in nature

and therefore, the charge of executing manipulative trades against him

cannot stand.



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Noticee No. 14:

31. The Noticee No. 14 submitted his reply in the matter vide letter dated

August 11, 2014. The Noticee stated that he is a doctor by profession and

Noticee No. 1 (Bharat Shantilal Thakkar), being one of his patients, had

advised him to deal in capital markets. Noticee No. 14 and 1 were clients of

the broker Angel Share Broking but the Noticee submits that the investment

decisions were independent. The Noticee No. 14 denies being a part of the

alleged Pabari-Parikh Group. The Noticee submitted that he had received

500 shares of LGS in off market transaction from Noticee No. 1 against

which consideration was paid by Noticee No. 14 to Noticee No. 1. The

details of cheque payments done have been listed by the Noticee. During

the relevant period, the Noticee No. 14 states that he had bought and sold

14,800 shares of LGS which were 0.07% of the market volume. In the SCN

it has been alleged that out of the buy volume of 12,000 shares, 2000 shares

were matched on May 22, 2009 with one of the group entities which the

Noticee submits is a negligible volume. The Noticee states that he has done

all trading in the scrip of LGS on delivery basis and were not self or

synchronised in nature and therefore, the charge of creating artificial

volume in the scrip against him cannot stand.

Noticee No. 15:

32. The Noticee No. 15 vide his letters dated August 08, 2014 and August 21,

2014 submitted that he is into jobbing and arbitrage trading activities.

Further, the Noticee submitted that as no query was raised by his stock

broker or the exchange for the transactions executed by him in LGS shares,

he had carried on trading in the shares in the routine manner. Additionally,



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the Noticee states that there are no investor complainants against the

Noticee for executing the said transactions in the shares of LGS. As regards

volume created in the shares of LGS during the investigation period, the

Noticee No. 15 submitted that he had bought 90750 shares (0.45%) and sold

50000 shares (0.02%) of LGS and that the said quantity was insignificant if

compared to the total volume traded in the said scrip. As regards his

connection with the Pabari Parikh Group, the Noticee while denying the

connection with the group entities submitted that he had paid/ received

consideration for the execution of off market dealings with Noticee Nos. 2

and 8 i.e. Shri Bipin Kumar Thaker and Shri Hemant Madhusudhan Sheth

and had no further connection with the group.

33. As regards the allegation of synchronized trades, the Noticee submitted that

the said trades were coincidental as the Noticee was not aware of the

counter party broker or client, also that the same did not have any impact on

the market equilibrium. As regards the allegation of self-trades, the Noticee

submitted that none of the trades executed by him have been listed out in

Annexure to the SCN which were self trades. Therefore, the Noticee No. 15

states that all his transactions were genuine and bonafide, as they had

neither caused any harm/damage to anyone nor had any impact on the

market equilibrium.

Noticee No. 17:

34. Noticee No. 17 submitted its reply vide letter dated November 18, 2013.

The Noticee submitted that it is a stock broker and had traded in the scrip of

LGS in the normal and ordinary course of the stock broking business. The

trades were executed in the then existing clients account on receipt of their



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instructions and authorization. The Noticee submitted that it had no

knowledge of any pattern or method of placing orders and that the clients

were inter connected with each other. As on date, the Noticee submitted that

it is not dealing for the stated clients and have improved their monitoring,

control and surveillance systems to ensure that no such activities are carried

out by its clients through any of its terminals. The Noticee further vide letter

dated September 02, 2014 stated that the transactions mentioned in the SCN

were carried out through SEBI registered sub broker Mr. Chirag R Jariwala

affiliated with the Noticee since March 2008.

35. Further, vide the said letter the Noticee requested for an opportunity of

inspection of documents in the matter. However, I note that SCN was

issued on October 08, 2013 i.e. almost a year back and vide letter dated

October 29, 2013 the Noticee had sought for 3 weeks time to submit its

reply. Further, vide letter dated November 18, 2013 the Noticee submitted

its preliminary reply in the matter but did not request for any specific

documents to be provided. I also note that an opportunity of personal

hearing was granted to the Noticee on August 11, 2014 wherein the

Authorised Representative appeared for the Noticee and reiterated its earlier

submissions without requesting for any specific documents or inspection

thereof. A request for inspection being made vide letter dated September

02, 2014 is nothing but a delaying tactic adopted by the said Noticee to

prolong the present proceedings. Therefore, I find that all the relevant

documents relied upon were already provided to the Noticee along with the

SCN (in a CD) and I don't find any merit in the request for inspection of

documents in the matter at this stage i.e. after the conclusion of personal

hearing.



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FINDINGS:

36. I find from the SCN and the material available on record that during the

relevant period, the Noticee Nos. 1 to 16 along with one more entity, who

were all connected to each other and referred to as the Pabari-Parikh Group

entities in the investigation report, had traded significantly in the shares of

LGS i.e. purchased 1,02,42,859 shares constituting 50.35% and sold

88,25,263 shares constituting 43.38% , respectively, of the total traded

volume in the scrip. I find that the relationship table as mentioned in para 16

above clearly shows that the said Noticees were connected to each other

either by way of having similar addresses / telephone numbers, relatives,

business associates and/or having fund movements between themselves.

Further, the relationship of the Noticee Nos. 1 to 16 is further established by

way of off market transactions between them as mentioned in para 17

above. I note that the Noticee Nos. 1 to 16 had traded for 71,94,984 shares

(i.e. 35.37% of the market volume) accounting for 70.24 % of the total

purchase of the group entities and 81.53% of the total sale of the said group

within the said Pabari-Parikh Group entities and constituted 35.37% of the

total market volume traded in the scrip of LGS on the exchange platform.

Out of the 71,94,984 shares traded within the group entities,the buy and sell

orders for 33,92,951 shares, constituting 16.68% of the market volume,

were placed within one minute time difference. Further, I find that

33,92,951 shares constituted 33.13% of the total purchase of group entities

and 38.45% of the total sale of the said Group entities. The quantity of

shares and the pattern of trading indulged into by the Noticee Nos. 1 to 16

within the group further substantiate the fact that they all had a meeting of

minds and traded in the scrip of LGS in collusion with each other.

Therefore, I do not find any merit in the submissions made by the Noticees



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that they had no relationship with each other and had traded in the scrip of

LGS independently and in the ordinary course of business.

37. I further find that the Noticee Nos. 1 to 12 had indulged in certain

synchronised trades in the shares of LGS thereby, creating false and

misleading appearance of trading in the scrip. I note that out of 33,92,951

shares traded by the Noticee Nos. 1 to 16, for 5,98,895 shares, which

accounted for 2.94% of the total market volume, the buy and sell orders

were placed in synchronised manner. 5,98,895 shares constituted for 5.85%

of the total purchases made by Pabari-Parikh Group entities and for 6.79%

of the total sales done by the said Group entities. On perusal of the details of

synchronised trades as given in para 19 above and the order and trade log, I

find that the Noticee Nos. 1 to 12 did indulge in manipulative activities in

the said scrip and traded in a synchronised manner within the group without

any intention of change in beneficial ownership of shares and I don't find

merit in the contentions made by the Noticees.

38. I find that during the relevant period the shares of LGS were traded on 301

trading days. Out of 301 trading days, the group entities including the

Noticee Nos. 1 to 16 had traded among themselves on 145 days, i.e. 48% of

the total number of days the scrip. The said group entities had by trading

among themselves contributed to daily market volume of the scrip in the

range from 0.90% on March 08, 2010 to 95.07% on April 09, 2010. Further,

out of the 145 days, I find that on 68 trading days, the Noticee Nos. 1 to 16

by trading amongst themselves had contributed for more than 50% to the

total traded volumes in the scrip.



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39. Also, I find that out of 145 trading days on which the Pabari-Parikh Group

entities had entered into trades in the scrip of LGS, on 125 trading days both

the buy and sell orders were placed within time difference of one minute.

By executing trades in the said manner, the Pabari-Parikh Group entities,

including the Noticee Nos. 1 to 16, had collectively contributed to daily

market volume of the scrip in the range from 0.30% on August 31, 2009 to

88.88% on February 15, 2010. Further, out of 125 trading days, on 11

trading days the Pabari-Parikh Group entities, including the Noticee Nos. 1

to 16, had contributed more than 50% to the total market volume by placing

both the buy and sell order within one minute time difference. On further

analysis, out of 125 trading days, on 41 trading days the trades executed by

the Pabari-Parikh Group entities, including the Noticee Nos. 1 to 16, were

synchronised trades by which they had contributed to total market volume

of the scrip in the range from 0.2% on November 20, 2009 to 56.11% on

January 14, 2010.

40. In view of the above, I do not find any merit in the contention of the

Noticees that the Noticees had entered into trades individually and

synchronised trades indulged into by the Noticees were insignificant /

miniscule in volume if compared to the total volumes traded in the scrip of

LGS. I find that the manipulative trading practices indulged in by the

Noticees cannot be viewed independently and have to be viewed

collectively as the overall impact of the synchronised trading done by the

Noticee Nos. 1 to 16 on the market in the scrip of LGS was quiet

significant. Further, I also find that such pattern of trading cannot be

executed without prior meeting of minds and prior understanding between

the Noticee Nos. 1 to 16.



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41. I find from paras 20 and 21 above that Noticee Nos. 1 to 12 had even

entered into certain trades which were self trades in nature i.e. totally

fictitious trades wherein the entity appears on both the buy and sell side of

the trade. The said Noticees had executed a total of 246 self trades for a

quantity of 7,94,609 shares thereby, inflated the volumes in the scrip by

3.91%. The Noticee Nos. 1 to 12 had executed the said fictitious trades

through multiple brokers. However, the Noticee No. 17 was the broker who

had executed significant number of self trades i.e. 28 self trades for 18,745

sharesfor the Noticee Nos. 1, 2, 3, 5, 6, 8 and 11. I do not find any merit in

the submissions of the Noticee No. 17 that the said trades were executed on

behalf of the clients without any knowledge of manipulation and were only

done upon the instructions of the clients. I find that the number of occasions

on which the Noticee No. 17 appeared as the broker and counter-party

broker in the fictitious trades during the period under investigation was

significant and cannot be said to be an innocent act. Therefore, I find that by

executing the self trades, Noticee Nos. 1 to 12 had further created a false

market and gave a misleading trading appearance in the scrip and Noticee

No. 17 had not acted in accordance with the code of conduct as prescribed

under the Broker Regulations.

42. I note that certain Noticees have in their submissions stated that they have

been restrained from trading in the securities market vide SEBI order dated

February 02, 2011 confirmed on July 08, 2011 and the said debarment order

is still in force. Further, I also note that the Noticee No. 9 in her submissions

has contended that the present adjudication proceedings are double jeopardy

as SEBI has already vide its order, debarred the Noticee from trading in the



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market for the same violations. At this juncture, I rely on judgement of the

Hon'ble High Court of Bombay in the case of SEBI Vs. Cabot International

Capital Corporation (2004)wherein it was observed that "the adjudication for

imposition of penalty by Adjudication Officer, after due inquiry, is neither a

criminal nor a quasi criminal proceeding. The penalty leviable under this Chapter

or under these sections, is penalty in cases of default or failure of statutory

obligation or in other words, breach of civil obligation. The provisions and

scheme of penalty under SEBI Act and the regulations, there is not element of

criminal offence or punishment as contemplated under criminal proceedings."In

view of this, i do not find merit in the contention of the Noticee no. 9.

43. From the foregoing, I find that the Noticee Nos. 1 to 16 by trading amongst

themselves had indulged in synchronised trades on numerous occasions,

resulting in no change of beneficial ownership thereby, created artificial

volume in the scrip of LGS which gave a false and misleading appearance

of trading in the said scrip. Further, I also conclude that the Noticee Nos. 1

to 12 had entered into self trades and inflated the volumes in the market

thereby, giving a false and misleading appearance of trading in the scrip of

LGS. I find from para no. 4.5.17 of the investigation report that the buy

order rate in respect of the Noticees was close to the best available sell

orders and as such the price rise on account of the said trades cannot be

attributed to the Noticees and the counter party clients (sale side) are not

from the Pabari- Parikh group. In view of the above, the Noticee Nos. 1 to

16 cannot be held guilty of violating the provisions of Regulation 4(2)(e) of

the PFUTP Regulations. Therefore, I conclude that the Noticee Nos. 1 to 16

have violated the provisions of Regulation 3(a), (b), (c), (d), 4(1) and

4(2)(a), (b) & (g) of the PFUTP Regulations thus, liable for monetary

penalty as prescribed under Section 15HA of the Act which reads as under:



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Penalty for fraudulent and unfair trade practices

15HA. If any person indulges in fraudulent and unfair trade practices

relating to securities, he shall be liable to a penalty of twenty-five crore

rupees or three times the amount of profits made out of such practices,

whichever is higher.

44. I note that the code of conduct prescribed under the Broker Regulations

mandates that a stock broker shall maintain high standards of integrity,

promptitude and fairness and shall act with due skill, care and diligence in

the conduct of his business. The code further mandates that the Broker shall

not, inter alia, indulge in manipulative transactions with a view to distort the

market equilibrium. Therefore, I conclude that the Noticee No. 17 by

executing fictitious trades, in the nature of self and synchronised trades, on

behalf of its clients has violated the provisions as mentioned under Clause

A(1), (2) & (3) of the Code of Conduct as specified under schedule II

prescribed under Regulation 7 of the Broker Regulations thus, liable for

monetary penalty as prescribed under Section 15HB of the Act which reads

as under:

Penalty for contravention where no separate penalty has been provided

15HB.Whoever fails to comply with any provision of this Act, the rules or

the regulations made or directions issued by the Board thereunder for

which no separate penalty has been provided, shall be liable to a penalty

which may extend to one crore rupees.

45. Here, it is important to refer to the observation of the Honble Supreme

Court of India in the matter of SEBI Vs. Shri Ram Mutual Fund [2006] 68

SCL 216(SC)wherein it was held that:



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In our considered opinion, penalty is attracted as soon as the

contravention of the statutory obligation as contemplated by the Act and the

Regulations is established and hence the intention of the parties committing

such violation becomes wholly irrelevant.

46. While determining the quantum of penalty under Sections 15HA and 15HB,

it is important to consider the factors stipulated in section 15J of SEBI Act,

which reads as under:-

15J -Factors to be taken into account by the adjudicating officer

While adjudging quantum of penalty under section 15-I, the adjudicating

officer shall have due regard to the following factors, namely:-

(a) the amount of disproportionate gain or unfair advantage, wherever

quantifiable, made as a result of the default;

(b) the amount of loss caused to an investor or group of investors as a result

of the default;

(c) the repetitive nature of the default.

47. I observe that from the material available on record, it is not possible to

quantify any gain or unfair advantage accrued to the Noticees or the extent

of loss suffered by the investors as a result of the default of the Noticees.

However, I find that the defaults were repetitive in nature. Further, the

Noticees traded in the scrip in a manner meant to create artificial volumes

and liquidity which is an important criterion capable of misleading the

investors while making an investment decision. In fact, liquidity/volumes in

particular scrip raise the issue of demand in the securities market. The

greater the liquidity, the higher is the investors attraction towards investing

in that scrip. Hence, anyone could have been carried away by the unusual



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fluctuations in the volumes and induced into investing in the said scrip.

Besides, this kind of activity seriously affects the normal price discovery

mechanism of the securities market. People who indulge in manipulative,

fraudulent and deceptive transactions should be suitably penalized for the

said acts of omissions and commissions.

ORDER

48. In view of the above, after considering all the facts and circumstances of the

case and exercising the powers conferred upon me under Section 15-I (2) of

the SEBI Act read with Rule 5 of the Adjudication Rules, I conclude that

the proceedings against Noticee No. 5 i.e. Shri Kishor Chauhan stand

abated. Further, I hereby impose the following monetary penalties on the

other Noticees:

Sr.

No.

Name of the Noticee Penal

provisions as

per the SEBIAct, 1992

Penalty Amount

(in `

1. Shri Bharat Shantilal

Thakkar (Noticee No. 1)

15HA 5,00,000/-

(Rupees Five Lakh Only)

2. Shri Bipin Jayant Thaker

(Noticee No. 2)

15HA 5,00,000/-


3. Shri Bharat G Vaghela

(Noticee No. 3)

15HA 5,00,000/-


4. Shri Chirag RajnikantJariwala (Noticee No. 4)

15HA 5,00,000/-(Rupees Five Lakh Only)

5. Shri Bhavesh Pabari

(Noticee No. 6)

15HA 5,00,000/-


6. Shri Prem Mohanlal

Parikh (Noticee No. 7)

15HA 5,00,000/-




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7. Shri Hemant Madhusudan

Sheth (Noticee No. 8)

15HA 5,00,000/-


8. Ms Mala Hemant Sheth

(Noticee No. 9)

15HA 5,00,000/-


9. Shri Vivek Kishanpal

Samant (Noticee No. 10)


10. Shri Ankit Sanchaniya

(Noticee No. 11)

15HA 5,00,000/-


11. Shri Gaurang Ajit Seth

(Noticee No. 12)

15HA 5,00,000/-


12. Shri Ketan Babulal Shah

(Noticee No. 13)

15HA 5,00,000/-


13. Shri Vasudev RamchandraKamat (Noticee No. 14)


14. Shri Jigar Praful Ghoghari

(Noticee No. 15)

15HA 5,00,000/-


15. Shri Vipul Hiralal Shah

(Noticee No. 16)

15HA 5,00,000/-


16. Arcadia Share & Stock

Brokers P. Ltd

(Noticee No. 17)

15HB 2,00,000/-

(Rupees Two Lakh Only)

TOTAL 77,00,000/-

(Rupees Seventy Seven

Lakh Only)

49. In my view, the penalties imposed on the Noticees are commensurate with the

defaults committed by them.

50. The penalty amounts as mentioned above shall be paid by the Noticees through

duly crossed demand drafts drawn in favour of SEBI Penalties Remittable to

Government of India and payable at Mumbai, within 45 days of receipt of this

order. The said demand drafts should be forwarded to the Division Chief, IVD-



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9, Securities and Exchange Board of India, SEBI Bhavan, Plot No. C4-A, G

Block, Bandra Kurla Complex, Bandra (E), Mumbai 400 051.

51. In terms of Rule 6 of the Rules, copies of this order are sent to the Noticees

and also to the Securities and Exchange Board of India.

Date: September 23, 2014 D. SURA REDDY

Place: Mumbai ADJUDICATING OFFICER

Documents

Adjudication Order against 17 entities in the matter of LGS Global Limited