Adjudication Order against 20 entities in the matter of Spectacle Infotek Limited

8/10/2019 Adjudication Order against 20 entities in the matter of Spectacle Infotek Limited

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BEFORE THE ADJUDICATING OFFICERSECURITIES AND EXCHANGE BOARD OF INDIA

[ADJUDICATION ORDER NO. EAD-2/DSR/RG/PU/320 -339/2014] ________________________________________________________________

UNDER SECTION 15-I OF SECURITIES AND EXCHANGE BOARD OF

INDIA ACT, 1992 READ WITH RULE 5 OF SEBI (PROCEDURE FORHOLDING INQUIRY AND IMPOSING PENALTIES BY ADJUDICATINGOFFICER) RULES, 1995.

In respect of

1. Labh Share and Stock Private Limited [PAN: AABCL7637A]

2. Shri Ketan Babulal Shah [PAN: AACPS0667F]

3. Shri Bharat Shantilal Thakkar [PAN: AAZPT9542R]

4. Shri Bipin Jayant Thaker [PAN: ABYPT4984H ]

5. Shri Vasudev Ramchandra Kamat [PAN: ADCPK2552N]

6. Shri Bharat G Vaghela [PAN: ADYPV0844N]

7. Shri Chirag Rajnikant Jariwala [PAN: AFMPJ7543L]

8. Shri Kishore Chauhan [PAN: AFPPC9703G]

9. Shri Bhavesh Pabari [PAN: AKGPP8679N]

10. Shri Prem Mohanlal Parikh [PAN: ALHPP3489N]

11. Shri Hemant Madhusudan Sheth [PAN: ANOPS8607E]

12. Shri Jigar Praful Ghoghari [PAN: ASFPG8598L]

13. Ms. Mala Hemant Sheth [PAN: AZXPS0694J]

14. Shri Ankit Sanchaniya [PAN: BLNPS3316L]

15. Shri Vivek Kishanpal Samant [PAN: BRSPS0294N]

16. Rajnandi Yarns Private Limited [PAN: AADCR0099J]

17. Shri Bipin Kumar Gandhi [PAN: AJHPG6989J]

18. Shri Gaurang Ajit Seth [PAN: BGEPS6596Q]

19. Shri Santosh Maruti Patil [PAN: AMAPP2722N]

20. Arcadia Share & Stock Brokers Pvt. Ltd. [PAN: AAACA4562G]

In the matter of

SPECTACLE INFOTEK LIMITED

________________________________________________________________

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

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

the shares of Spectacle Infotek Limited (hereinafter referred to as

Brought to you by http://StockViz.biz


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'SIL/company'), a company listed at the Bombay Stock Exchange limited

(BSE) and the National Stock Exchange (NSE), conducted an investigation into

the alleged irregularity in the trading in the shares of SIL 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 Regulationsmade there under during the period from May 01, 2010 to January 31, 2011. It

was observed that the price of the scrip unusually increased from ` 21.75 to

` 162.80 and the daily high and low traded volume was 31 shares to 79,68,043

shares.

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

persons/entities from accessing the securities market and further, hadprohibited them from buying, selling or dealing in securities in any manner

whatsoever, till further directions. The said interim order was later confirmed

by SEBI vide order dated July 08, 2011.

3. The investigation, inter alia, revealed that certain entities namely, 1) M/s.

Labh Share and Stock Private Limited, 2) Shri Ketan Babulal Shah, 3) Shri

Bharat Shantilal Thakkar, 4) Shri Bipin Jayant Thaker, 5) Shri VasudevRamchandra Kamat, 6) Shri Bharat G. Vaghela, 7) Shri Chirag Rajnikant

Jariwala, 8) Shri Kishore Chauhan, 9) Shri Bhavesh Pabari, 10) Shri Prem

Mohanlal Parikh, 11) Shri Hemant Madhusudan Sheth, 12) Shri Jigar Praful

Ghoghari, 13) Ms. Mala Hemant Sheth, 14) Shri Ankit Sanchaniya, 15) Shri

Vivek Kishanpal Samant, 16) Rajnandi Yarns Private Limited, 17) Shri Bipin

Kumar Gandhi, 18) Shri Gaurang Ajit Seth and 19) Shri Santosh Maruti Patil

(hereinafter referred to as Noticee Nos. 1 to 19 and collectively referred to asthe Noticees), connected to each other by one way or the other, had dealt in

the scrip of SIL through multiple brokers in a fraudulent and manipulative

manner, without real change in ownership of shares, by indulging in number

of synchronized trades and heavily traded amongst themselves thereby,

creating artificial volumes and price rise in the scrip. The Noticee Nos. 1 to 19

were also observed to have done off-market transactions among themselves

for the purpose of meeting the settlement obligations of one another.



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4. It was further observed that certain Noticees had also indulged in trades

which were self trades in nature, while trading on both the exchanges i.e. BSE

and NSE, through multiple brokers one of them being Arcadia Share & Stock

brokers Private Limited (hereinafter referred to as Noticee No. 20), a

registered intermediary with SEBI thereby, creating artificial volume whichgave a false and misleading appearance of trading in the scrip of SIL on the

exchanges.

5. SEBI has, therefore, initiated adjudication proceedings against Noticee Nos. 1

to 19 for the alleged violation 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

relating to Securities Market) Regulations, 2003 (hereinafter referred to as thePFUTP Regulations) and against Noticee No. 20 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 (herein after referred to as the Broker Regulations) read with Regulation

7 of the said Regulations.

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

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

the 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 15 HA of the Act

against Noticee Nos. 1 to 19 for the alleged violation of the provisions of

PFUTP Regulations and under Section 15 HB of the Act against Noticee No. 20

for the alleged violation of the Broker Regulations.

Show Cause Notice, Reply and Personal Hearing

7. All the Noticees were issued a common show cause notice (hereinafter

referred to as 'SCN') dated December 04, 2013 in terms of Rule 4(1) of the

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

should not be imposed on them for the aforesaid violations. The SCNs were



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sent by Speed Post Ack. Due and were duly delivered to the Noticees except

in the case of Noticee Nos. 6, 14, 16, 17 & 19 as the same were returned

undelivered. In view of the same, vide letter dated March 03, 2014, the SCNs

were affixed at the last known address of the said Noticees, reports thereof are

available on record.

8. Vide letter dated April 30, 2014, one Ms. Rupal K. Chauhan, wife of Noticee

No. 8 informed that the said Noticee had passed away on May 29, 2013 and

enclosed a copy of the certified death certificate of Noticee No. 8 as issued by

the Department of Health and Family Welfare, Government of Gujarat, in

support thereof. In view of the same, the adjudication proceedings initiated

against Noticee No. 8 stand abated. However, I shall examine the role ofNoticee No. 8 for the limited purpose of examining the role and findings

against the other Noticees in the matter.

9. The Noticee No. 1 submitted its reply in the matter vide letter dated January

10, 2014. Further, Noticee No. 3 vide letter dated October 16, 2014 filed his

reply in the matter. The Noticee Nos. 4 & 7 vide their separate but identical

letters dated April 21, 2014 filed their reply in the matter and furtherrequested for 4 weeks time to file their detailed reply. Accordingly, vide

separate letters dated November 13, 2014, and November 12, 2014, the said

Noticees filed their detailed replies in the matter. Further, the Noticee Nos. 9

and 13, vide separate letters dated August 17, 2014 and August 19, 2014,

respectively, filed their replies in the matter. Further, the Noticee No. 20, vide

its letter dated December 20, 2013, requested for 3 weeks time to file its reply

in the matter and accordingly, vide letter dated January 09, 2014 filed its reply

in the matter. 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. 6, 14, 16 and 17 on April 07, 2014 and Noticee Nos. 10, 12

and 19 on April 10, 2014 vide separate notices dated March 12, 2014. The said

notices were sent by hand delivery to Noticee No. 10 and by hand delivery &



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affixed to Noticee Nos. 6, 12, 14, 16, 17 and 19, affixture reports thereof are

available on record. A common Authorized Representative (AR) appeared on

behalf of the Noticee Nos. 10 & 12 on the scheduled date and made oral

submissions. Further, the said AR requested for 2 weeks time to file replies for

the said Noticees in the matter. Accordingly, the Noticee Nos. 10 and 12 wereadvised to file their replies on or before April 24, 2014. Vide separate but

identical letters dated April 21, 2014 filed their replies in the matter and

further requested 4 weeks time file their detailed replies. The Noticee Nos. 6,

14, 16, 17 and 19 did not attend the hearing on the scheduled date. However,

vide letter dated November 13, 2014 the Noticee No. 14 filed his reply in the

matter. Further, vide letter dated August 28, 2014, the Noticee No. 16 also

filed its reply in the matter.

11. Subsequently, in the interest of natural justice an opportunity of personal

hearing was granted to the Noticee Nos. 1, 2, 3, 4, 5, 9, 10, 11, 12 13, 15, 16 and

20 on November 17, 2014 and Noticee Nos. 7 and 18 on November 18, 2014

vide separate notices dated November 03, 2014. The Noticee No. 20 filed its

additional reply dated November 15, 2014 (i.e. before the scheduled date of

hearing) in the matter. A common AR appeared on behalf of Noticee Nos. 1 &

20 on the scheduled date and reiterated the submissions made by the said

Noticees in their replies. Further, a common AR attended the scheduled

hearing on behalf of Noticee Nos. 5, 11, 12 and 18 and made oral submissions.

With respect to Noticee Nos. 5 and 18, the AR, vide separate letters dated

November 17, 2014, submitted their individual replies in the matter. I find that

the Noticee Nos. 11, 15 and 14 did not attend the hearing on the scheduleddate. However, vide letters dated November 09, 2014, November 09 & 11,

2014 and November 13, 2014, the said Noticees filed their replies in the matter.

The other Noticees did not attend the hearing on the scheduled date.

12. In view of the above, with respect to Noticee Nos. 2, 6, 17 and 19 I note that

the said Noticees have neither filed any replies nor availed the opportunity of

personal hearing granted to them (November 17, 2014 and April 7 & 10, 2014)



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in the matter. 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

December 04, 2013 i.e. appx 1 year ago. 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

13. I have carefully perused the charges leveled against the Noticees in the SCN,

written submissions made and all the documents available on record. In the

instant matter, the following issues arise for consideration and determination:

a. Whether Noticee Nos. 1 to 7 and 9 to 19 have violated Regulation3 (a), (b), (c), (d), 4 (1) and 4 (2) (a), (b), (e) & (g) of the PFUTPRegulations?

b. Whether Noticee No. 20 has violated Clause A (1), (2) & (3) of theCode of Conduct specified under Schedule II read withRegulation 7 of the Broker Regulations?

c. Do the violations, if any, on the part of the Noticees attractmonetary penalty under Section 15HA and 15HB of the Act?

d. If so, what should be the quantum of monetary penalty that canbe imposed on the Noticees taking into consideration the factorsas mentioned under Section 15 J of the Act?

14. Before proceeding forward, I would like to refer to the relevant provision of

the PFUTP Regulations and the Broker Regulations, which read as under:

PFUTP Regulations3. 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 securitylisted or proposed to be listed in a recognized stock exchange, anymanipulative or deceptive device or contrivance in contravention of the

provisions of the Act or the rules or the regulations made there under;



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(c) employ any device, scheme or artifice to defraud in connection withdealing in or issue of securities which are listed or proposed to be listed on arecognized stock exchange;(d) engage in any act, practice, course of business which operates or wouldoperate as fraud or deceit upon any person in connection with any dealing inor 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 andthe regulations made there under.

4. Prohibition of manipulative, fraudulent and unfair trade practices

(1) Without prejudice to the provisions of regulation 3, no person shallindulge 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 oftrading in the securities market;(b) dealing in a security not intended to effect transfer of beneficial ownershipbut intended to operate only as a device to inflate, depress or cause

fluctuations in the price of such security for wrongful gain or avoidance ofloss;

(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 itor without intention of change of ownership of such security;

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.



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(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.

(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.

15. I find from the SCN that SIL is a company listed on the BSE and NSE. On

analyzing the trading activity in the scrip of SIL on BSE, it was noticed that a

group of 19 entities identified as the Pabari-Parikh Group in the investigation

report, who were all connected to each other in one way or the other, had traded

heavily in the scrip of SIL through multiple brokers, one of them being Noticee

No. 20. The relationship between the 19 entities is detailed as under:ClientName

KYC Relation FundMovement

Sharemovementthroughoff market

ClientName


Sharemovementthroughoffmarket

1.LabhShare andStockPrivateLimited

Sl. no. 1 has traded with6, 7, 8, 9, 10, 12, 14, 15, 18& 19, who all haveconnection withBhavesh Pabari through,KYC relation, fundmovement or off marketshare transfer.

11.BipinkumarGandhi

With sl.no. 12.

2.BhupeshRathod

Introduced sl. no.14, 13,12, 10 for trading a/cand knows sl. No. 16

With Sl.No. 18.

12.Bhavesh Pabari

Sl. no. 5 is his uncle &sl. no. 19 is his brotherin law.Sl. no. 13 is cousin ofsl. no.12Sl. no. 12 & 14 bothdirectors of RajnandiYarns Pvt.Ltd.(sl.no.4)Share common Tel.no. with sl. no. 18, 19,

6.Sl. no. 2 introducedhim for trading a/c.BR* with sl. no. 6, 9,10, 13, 14, 16, 18.

With sl.no. 13, 14,4, 5, 6, 18,19, 11.

3.KetanBabulalShah

With sl.no.13.

13.PremMohanlalParikh

Sl. no. 13 is cousin ofsl. no.12.Common email withsl. 18, 13 & 19.Sl. no. 14 is nomineeof sl. no.13.BR* with sl. no. 5, 6, 9,10, 12, 14, 18, 19.

With sl.no. 12,14, 10.

With sl.no. 12, 14,10, 4, 5, 6,14, 15, 18,19.

4.RajnandiYarnsPrivate

Sl. no. 12 & 14 bothdirectors of RajnandiYarns Pvt. Ltd.

With sl.no. 5, 6, 9,10, 12, 13,

14.HemantMadhusu

Sl. no. 12 & 14 bothdirectors of RajnandiYarns Pvt. Ltd.

With sl.no. 12,13, 10.

With sl.no. 12, 13,10, 4, 16,



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Limited 14, 15, 18,19.

dan Sheth Same email with sl.no. 18.BR* with 2, 5, 13, 18,19, 6, 9, 10, & sl. no.16 is his wife & sl. no.17 is his nephew.

18, 19, 15,6,

5.BharatShantilal

Thakkar

Sl. no. 12 is his nephew.Same address with sl.

no.12.Sl. no. 12 is his nominee. Joint a/c with sl. no. 12.BR* with sl. no. 6, 9, 10,13, 14, 18, 19.

With sl.no. 12,

13, 18.

With sl.no. 12, 7,

4.

15.JigarPraful

Ghoghari

With sl.no. 4, 6,

13, 14, 18.

6.Bipin JayantThaker

Same Tel. no. with sl. no.12.BR* with sl. no. 5, 9, 10,12, 13, 14, 18, 19.

With sl.no. 4,12.

With sl.no. 4, 15,9, 12, 13,14.

16.MalaHemantSheth

Sl. no. 16 is the wife ofsl. no. 14 and sl. no. 17is the nephew.

With sl.no. 12,13.

With sl.no. 14.

7.VasudevRamchandra Kamat

Sl. no. 5 share the sameaddress with sl. no.12.

With sl.no.5

17.Gaurang AjitSeth

Has common address& Tel. no. with sl. no.14. & sl. no. 14 and 12both directors of

Rajnandi Yarns Pvt.Ltd.(sl.no.4)8.Bharat GVaghela

Same address & Tel.no.as sl. no. 11 who hasshare movement withsl.no. 12.Sl. No. 9 is nephew of sl.no. 12 and shares sameTel. no. with sl. no. 12.

With sl.no. 9.

18.AnkitSanchaniya

Same Tel. no. with sl.no. 13 and also sharesTel. no. with sl. no. 12who is the nomineefor his a/c.BR* with sl. no.5, 6, 9,10, 12, 13, 14, 18.

With sl.no. 12,13.

With sl.no. 4, 12,13, 14, 9,15, 19.

9.ChiragRajnikant Jariwala

Same Tel. no. withsl.no.12.Sl. no. 12 is his uncle.BR* with sl. no. 5, 6, 10,12, 14, 18, 19.

With sl.no. 12,14, 8, 4.

With sl.no. 4, 6.

19.VivekKishanpalSamant

Sl. no. 12 is thebrother in law &shares common Tel.no. & sl.no. 12 is thenominee of sl. no. 19for trading a/c &bank a/c.Shares email with sl.no. 14.Shares email with sl.no. 13.

With sl.no. 14.

With sl.no. 4, 12,14, 9, 10,13, 18.

10.KishoreChauhan

Join a/c with sl. no. 12Sl. no. 12 & 14 arewitness for demat a/c.BR* with sl. no. 5, 6, 9,12, 13, 14, 18.

With sl.no. 12,13, 14.

With sl.no. 4, 12,13, 14, 19.

* BR - Business Relation

16. Additionally, it was revealed that the Pabari-Parikh Group entities, had indulged in

certain off-market transfers for 5,53,54,390 shares of Spectacle amongst

themselves during the period January 01, 2009 and January 31, 2011. These off -

market transfers among the group further confirmed the relationship/connection

between the said group.

17. I find from the trade log analysis that, the Pabari-Parikh Group entities had

purchased 57638998 shares accounting for 61.89% of the total volume traded and



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sold 63596198 shares accounting for 68.29% of the total volume traded of SIL

during the relevant period. Out of 19 Pabari-Parikh group entities, 18 Pabari-

Parikh group entities traded for 50482429 shares (i.e. 54.21% of the market

volume) accounting for 87.58 % of the total purchase of the group and 79.38% of

the total sale of the group within Pabari-Parikh group entities and 54.21% of themarket volume from within the group entities. Out of 50482429 shares within the

group entities, the buy and sell orders for 22539876 shares accounting for 24.20%

of the market volume, were placed within one minute time difference. Further, it

was noted that 22539876 shares constituted for 39.11% of the total purchases and

35.44% of the total sales of the Pabari-Parikh Group entities.

18. Further, o ut of 22539876 shares, for 3179058 shares which accounted for 3.41% of

the total market volume, the buy and sale orders were placed in synchronized

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 same) by Noticee Nos. 1 to 15. The volume of 3179058 shares constituted for

5.52% of the total purchases and 5.00% of the total sales of the Pabari-Parikh

group entities. The summary of the said synchronized trades entered into by the

by Noticee Nos. 1 to 15 while trading on BSE is as under:

PANNO Client NameSynchronisedBuy

% ofMarketVolume

% ofsynctototalbuybyclient

SynchronisedSale

% ofMarketVolume

% ofsynctototalsalebyclient

AABCL7637A

Labh Share and StockPrivate Limited

(Noticee No. 1) 180671 0.19 25.71 10040 0.01 17.76AACPS0667F

Ketan Babulal Shah(Noticee No. 2) 700 0.00 70.00 0 0.00 0.00

AAZPT9542RBharat Shantilal Thakkar(Noticee No. 3) 24451 0.03 1.75 41115 0.04 2.71

ABYPT4984HBipin Jayant Thaker(Noticee No. 4) 123874 0.13 2.57 211685 0.23 3.69

ADCPK2552NVasudev RamchandraKamat (Noticee No. 5) 0 0.00 0.00 5000 0.01 47.39

ADYPV0844NBharat G Vaghela(Noticee No. 6) 1124246 1.21 12.35 454205 0.49 4.96

AFMPJ7543L

Chirag Rajnikant

Jariwala(Noticee No. 7) 232387 0.25 4.91 186213 0.20 4.57



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AFPPC9703GKishore Chauhan(Noticee No. 8) 32156 0.03 1.46 1300 0.00 0.05

AKGPP8679NBhavesh Pabari(Noticee No. 9) 394745 0.42 4.45 403261 0.43 3.98

ALHPP3489NPrem Mohanlal Parikh(Noticee No. 10) 268146 0.29 5.98 338972 0.36 7.39

ANOPS8607E

Hemant Madhusudan

Sheth (Noticee No. 11) 233072 0.25 3.38 748019 0.80 7.67

ASFPG8598L Jigar Praful Ghoghari(Noticee No. 12) 78496 0.08 4.40 163566 0.18 9.17

AZXPS0694JMala Hemant Sheth(Noticee No. 13) 0 0.00 0.00 12560 0.01 24.19

BLNPS3316LAnkit Sanchaniya(Noticee No. 14) 303168 0.33 5.89 202345 0.22 4.23

BRSPS0294NVivek Kishanpal Samant(Noticee No. 15) 182946 0.20 2.47 400777 0.43 4.30

Grand Total 3179058 3.41 5.52 3179058 3.41 5.00

19. I also find that Noticee Nos. 3, 4, 6, 7, 8, 9, 10, 11, 12, 14 & 15 had indulged incertain trades which were self trades in nature (while dealing through their

multiple brokers including Noticee No. 20) and the details of the said fictitious

trades indulged into on BSE by the said Noticees are as under:

PAN Name of the entity Total buy Total sale

Selftradeqty

% ofTotalBuy

%TotalSale

% ofMarketVolume

No ofSelftrades

AAZPT9542R

Bharat Shantilal

Thakkar(Noticee No. 3) 1395519 1518102 2263 0.16 0.15 0.00 6

ABYPT4984HBipin Jayant Thaker(Noticee No. 4) 4817677 5740151 102739 2.13 1.79 0.11 26

ADYPV0844NBharat G Vaghela(Noticee No. 6) 9104535 9150961 41019 0.45 0.45 0.04 62

AFMPJ7543L

Chirag Rajnikant Jariwala(Noticee No. 7) 4731650 4077019 190575 4.03 4.67 0.20 34

AFPPC9703GKishore Chauhan(Noticee No. 8) 2208192 2540507 1100 0.05 0.04 0.00 2

AKGPP8679N

Bhavesh Pabari

(Noticee No. 9) 8861360 10144037 190735 2.15 1.88 0.20 77

ALHPP3489NPrem Mohanlal Parikh(Noticee No. 10) 4480527 4587734 87193 1.95 1.90 0.09 31

ANOPS8607EHemant MadhusudanSheth (Noticee No. 11) 6890281 9754318 393404 5.71 4.03 0.42 78

ASFPG8598L Jigar Praful Ghoghari(Noticee No. 12) 1785017 1784362 36384 2.04 2.04 0.04 11

BLNPS3316LAnkit Sanchaniya(Noticee No. 14) 5145520 4787916 222268 4.32 4.64 0.24 61

BRSPS0294N

Vivek KishanpalSamant(Noticee No. 15) 7411826 9323368 228562 3.08 2.45 0.25 70

Grand Total 56832104 63408475 1496242 2.63 2.36 1.61 458



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

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

counter party broker. The number of instances wherein the Noticee No. 20 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 Brokers Pvt.Ltd.

Ankit Sanchaniya(Noticee No. 14) 3000 1Bharat G Vaghela(Noticee No. 6) 41019 62Bharat Shantilal Thakkar(Noticee No. 3) 2263 6Bipin Jayant Thaker(Noticee No. 4) 2530 6

Arcadia Share & Stock Brokers Pvt. Ltd. (Noticee No. 20)Total 48812 75

Arch Finance Ltd.Prem Mohanlal Parikh(Noticee No. 10) 4398 1

Arch Finance Ltd. Total 4398 1

Fairwealth Securities Ltd.

Ankit Sanchaniya(Noticee No. 14) 10 1Bhavesh Pabari(Noticee No. 9) 7378 11

Hemant Madhusudan Sheth(Noticee No. 11) 5000 1Kishore Chauhan(Noticee No. 8) 1100 2Prem Mohanlal Parikh(Noticee No. 10) 1511 7Vivek Kishanpal Samant(Noticee No. 15) 785 1

Fairwealth Securities Ltd. Total 15784 23

IFCI Financial Services Ltd.

Hemant Madhusudan Sheth

(Noticee No. 11) 3300 3 IFCI Financial Services Ltd. Total 3300 3Grand Total 72294 102

21. From the price volume data analysis at BSE, I note that the scrip of SIL was

traded on 192 trading days. Out of the 192 trading days, the group entities

had traded among themselves on 167 days, i.e. for 86.97% of the total number

of days the scrip was traded during the relevant period under investigation. It

was noted that the Noticee Nos. 1 to 19 contributed to the daily market



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volume of the scrip in the range from 83.74% on May 03, 2010 to 0.22% on

January 31, 2011. It was further alleged that out of 167 trading days, on 140

trading days the said Noticees had traded among themselves, thereby,

contributing more than 50% to the total market volume in the scrip during the

relevant period.

22. On further examination, I find that out of 167 trading days on which the

Pabari-Parikh Group had entered into trades in the scrip of SIL, on 158 trading

days both buy and sell orders were placed within time difference of one

minute. It was, therefore, alleged in the SCN that the Noticee Nos. 1 to 19 had

contributed to daily market volume of the scrip in the range from 7.42% on

May 04, 2010 to 7.44% on January 25, 2011. Out of 158 trading days, on 32trading days, the trades executed by the Noticee Nos. 1 to 19 contributed more

than 50% of the total market volume of the scrip. Also out of 158 trading days,

on 98 trading days the trades executed by the Noticee Nos. 1 to 19 were

synchronized in nature. By executing synchronized trades among themselves,

the Noticee Nos. 1 to 19 contributed to total market volume of the scrip in the

range from 2.75% on May 03, 2010 to 13.02% on December 08, 2010. In

addition, the group entities contributed to more than 40% of the market

volume of the scrip by entering into synchronized trading on 2 trading days.

23. I further find that the price of the scrip opened at ` 119.90 and touched a high

of ` 178.00 i.e. there was an increase of ` 58.10. Thus, on 192 trading days and

on 226 occasions a new high price was discovered. Further I note that, out of

226 occasions, on 117 occasions (i.e. on 25 days out of 28 days), Noticee Nos. 3,

6, 7, 9, 11, 14, 15 & 18 contributed to increase in price by ` 52.30 (out of ` 58.10).

24. I find from the analysis of the trading activity in the scrip of SIL on NSE that a

group of 18 Pabari-Parikh Group entities i.e. Noticee Nos. 1 & 3 to 19,

connected to each other one way or the other and dealing through multiple

brokers, had purchased 45992205 shares which accounted for 56.77% of the

total volume traded and sold 51740181 shares which accounted for 63.86% of

the total volume traded in the scrip of SIL during the period under



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investigation. Further, as mentioned in para 16 above, the group entities had

also done certain off-market transactions which further confirm the nexus

between the said entities. The relationship between the 18 entities i.e. Noticee

Nos. 1 & 3 to 19, is detailed as under:

ClientName


Sharemoveme

ntthrough

offmarket

ClientName

KYC Relation FundMovem

ent

Sharemoveme

ntthrough

offmarket

1.LabhShare andStockPrivateLimited

Sl. no. 1 traded withsl. No. 1, 4, 5, 6, 7, 8,10, 11, 13, 14, 17 & 18,who all haveconnection withBhavesh Pabarithrough, KYCrelation, fundmovement or offmarket share transfer

10.Bhavesh Pabari

Sl. no. 3 is his uncle& sl. no. 18 is hisbrother in law.Sl. no. 11 is cousinof sl. no.10Sl. no. 10 & 13 bothdirectors ofRajnandi Yarns Pvt.Ltd.(sl.no.2)Share common Tel.no. with sl. no. 17,18, 4.BR* with sl. no. 4, 7,8, 11, 13, 15, 17.

With sl.no. 11,13, 2, 3,4, 17, 18,9.

2.Rajnandi YarnsPrivateLimited

Sl. no. 10 & 13 bothdirectors of Rajnandi

Yarns Pvt. Ltd.

With sl.no. 3, 4, 7,8, 10, 11,

13, 14, 17,18.

11.PremMohanlal Parikh

Sl. no. 11 is cousinof sl. no.10.

Common email

with sl. 17, 11 & 18.Sl. no. 13 is nomineeof sl. no.11.

BR* with sl. no. 3, 4,7, 8, 10, 13, 17, 18.

With sl.no. 10,13, 8.

With sl.no. 10,13, 8, 2,

3, 4, 13,14, 17,18.

3.BharatShantilalThakkar

Sl. no. 10 is hisnephew.

Same address with sl.no.10.

Sl. no. 10 is hisnominee.

Joint a/c with sl. no.

10.BR* with sl. no. 4, 7, 8,11, 13, 17, 18.

Withsl. no.10, 11,

17.

With sl.no. 10, 5,

2.

12.Santosh

MarutiPatil

Sl. no. 12 tradedwith sl. No. 6, 17 &

18, who all haveconnection withBhavesh Pabarithrough, KYCrelation, fund

movement or offmarket sharetransfer

4.Bipin JayantThaker

Same Tel. no. with sl.no. 10.BR* with sl. no. 3, 7, 8,10, 11, 13, 17, 18.

Withsl. no.2, 10.

With sl.no. 2, 14,7, 10, 11,13.

13.HemantMadhusudanSheth

Sl. no. 10 & 13 bothdirectors ofRajnandi Yarns Pvt.Ltd.Same email with sl.no. 17.BR* with 3, 11, 17,18, 4, 7, 8, & sl. no.15 is his wife & sl.

no. 16 is hisnephew.

With sl.no. 10,11, 8.

With sl.no. 10,11, 8, 2,15, 17,18, 14, 4.



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5.VasudevRamchandraKamat

Sl. no. 3 share thesame address with sl.no.10.

With sl.no.3.

14.JigarPrafulGhoghari

With sl.no. 2, 4,11, 13,17.

6.BharatGVaghela

Same address &Tel.no. as sl. no. 9who has sharemovement with sl.no.10.Sl. No. 7 is nephew ofsl. no. 10 and sharessame Tel. no. with sl.no. 10.

Withsl. no.7.

15.MalaHemantSheth

Sl. no. 15 is the wifeof sl. no. 13 and sl.no. 16 is thenephew.

With sl.no. 10,11.

With sl.no. 13.

7.ChiragRajnikant

Jariwala

Same Tel. no. withsl.no.10.Sl. no. 10 is his uncle.BR* with sl. no. 3, 4, 8,10, 13, 17, 18.

Withsl. no.10, 13,6, 2.

With sl.no. 2, 4.

16.Gaurang AjitSeth

Has commonaddress & Tel. no.with sl. no. 13. & sl.no. 13 and 10 bothdirectors of

Rajnandi Yarns Pvt.Ltd.(sl.no.2)8.KishoreChauhan

Join a/c with sl. no. 10Sl. no. 10 & 13 arewitness for demata/c.BR* with sl. no. 3, 4, 7,10, 11, 13, 17.

Withsl. no.10, 11,13.

With sl.no. 2, 10,11, 13, 18.

17.AnkitSanchaniya

Same Tel. no. withsl. no. 11 and alsoshares Tel. no. withsl. no. 10 who is thenominee for his a/c.BR* with sl. no.3, 4,7, 8, 10, 11, 13, 17.

With sl.no. 10,11.

With sl.no. 2, 10,11, 13, 7,14, 18.

9.BipinkumarGandhi

With sl.no. 10.

18.VivekKishanpal

Samant

Sl. no. 10 is thebrother in law &shares common Tel.

no. & sl.no. 10 is thenominee of sl. no.18 for trading a/c &bank a/c.Shares email withsl. no. 13.Shares email withsl. no. 11.

With sl.no. 13.

With sl.no. 2, 10,13, 7, 8,

11, 17.

*BR-Business relation.

25. I find that during the relevant period, the abovementioned 18 group entities had

purchased and sold a total of 45992205 shares and 51740181 shares, respectively,on NSE. They traded for 39239127 shares ( i.e. 48.43% of the market volume)

accounting for 85.32% of the total purchases of the group and for 75.84% of the

total sales of the group, within the group entities, accounting for 48.43% of the

market volume from within the group entities. Out of 39239127 shares traded in

scrip of SIL within the group entities, for 14853157 shares constituting 18.33% of

the market volume, the buy and sale orders were placed within one minute time

difference. 14853157 shares constituted for 32.29% of the total purchases and



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28.71% of the total sales of the 18 Pabari-Parikh Group entities. Further, it was

noted that out of 14853157 shares, for 3594922 shares accounting for 4.44% of the

total market volume, the buy and sale orders were placed in synchronized

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 sidebeing same) by Noticee Nos. 1, 3 to 15 & 19. 3594922 shares constituted for 7.82%

of the total purchases and 6.95% of the total sales of the 18 Pabari-Parikh Group

entities. The summary of the said synchronized trades entered into by the Noticee

Nos. 1, 3 to 15 & 19 while trading on NSE is as under:

PAN No Client Name synchronisedbuy trades

% ofMarketVolume

% ofsynctototalbuybyclient

synchronisedsale trades

% ofMarketVolume

% ofsynctototalsalebyclient

AABCL7637A Labh Share and StockPrivate Limited(Noticee No.1)

163281 0.20 30.90 46500 0.06 95.95

AAZPT9542R Bharat Shantilal Thakkar(Noticee No.3)

25750 0.03 3.01 71120 0.09 8.59

ABYPT4984H Bipin Jayant Thaker(Noticee No.4)

276949 0.34 5.82 322577 0.40 6.00

ADCPK2552N Vasudev RamchandraKamat(Noticee No.5)

0 0.00 0.00 2500 0.00 27.93

ADYPV0844N Bharat G Vaghela(Noticee No.6)

1277904 1.58 17.13 599693 0.74 8.05

AFMPJ7543L Chirag Rajnikant Jariwala(Noticee No.7)

339022 0.42 6.71 367990 0.45 6.23

AFPPC9703GKishore Chauhan(Noticee No.8) 37149 0.05 1.63 143119 0.18 3.78

AKGPP8679NBhavesh Pabari(Noticee No.9) 126200 0.16 4.03 301140 0.37 7.69

ALHPP3489N Prem Mohanlal Parikh(Noticee No.10) 252719 0.31 7.33 249652 0.31 6.88

AMAPP2722NSantosh Maruti Patil(Noticee No.19) 1000 0.00 6.65 0 0.00 0.00

ANOPS8607E

Hemant MadhusudanSheth(Noticee No.11) 320262 0.40 5.69 544491 0.67 9.47

ASFPG8598L Jigar Praful Ghoghari(Noticee No.12) 51820 0.06 3.20 116796 0.14 8.86

AZXPS0694JMala Hemant Sheth(Noticee No.13) 12500 0.02 98.43 25000 0.03 93.46

BLNPS3316L

Ankit Sanchaniya

(Noticee No.14) 250945 0.31 4.76 361351 0.45 5.23BRSPS0294N Vivek Kishanpal Samant 459421 0.57 7.87 442993 0.55 6.70



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(Noticee No.15)

Grand Total 3594922 4.44 7.82 3594922 4.44 6.95

26. It was also observed that Noticee Nos. 1, 3, 4, 6 to 11, 14 & 15 had indulged in

certain trades which were self trades in nature while trading through their

multiple brokers including Noticee No. 20. The details of the said fictitious trades

indulged into on NSE by the said Noticees are as under:

PAN Name of the entity Total buy Total sale

Selftradeqty

% ofTotalBuy

%TotalSale

% ofMarketVolume

No ofSelftrades

AABCL7637A

Labh Share and StockPrivate Limited(Noticee No.1) 528486 48465 77 0.01 0.16 0.00 1

AAZPT9542R Bharat Shantilal Thakkar(Noticee No.3) 856100 828413 2100 0.25 0.25 0.00 4

ABYPT4984HBipin Jayant Thaker(Noticee No.4) 4757443 5374442 125664 2.64 2.34 0.16 78

ADYPV0844NBharat G Vaghela(Noticee No.6) 7459507 7453490 46114 0.62 0.62 0.06 93

AFMPJ7543LChirag Rajnikant Jariwala(Noticee No.7) 5055146 5910781 197101 3.90 3.33 0.24 108

AFPPC9703GKishore Chauhan(Noticee No.8) 2278639 3790421 76387 3.35 2.02 0.09 23

AKGPP8679NBhavesh Pabari(Noticee No.9) 3134691 3913748 31777 1.01 0.81 0.04 22

ALHPP3489NPrem Mohanlal Parikh(Noticee No.10) 3446372 3631238 141135 4.10 3.89 0.17 78

ANOPS8607E

Hemant MadhusudanSheth(Noticee No.11) 5633024 5748297 16934 0.30 0.29 0.02 11

BLNPS3316LAnkit Sanchaniya(Noticee No.14) 5266567 6903099 307909 5.85 4.46 0.38 310

BRSPS0294NVivek Kishanpal Samant(Noticee No.15) 5834049 6608664 279414 4.79 4.23 0.34 142

Grand Total 44250024 50211058 1224612 2.77 2.44 1.51 870

27. For the above fictitious trades, it was noted that the brokers mentioned in thetable below were appearing on both sides of the trade i.e. acted as broker and

counter party broker. The number of instances wherein the Noticee No. 20 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 Brokers Pvt.Ltd.

Ankit Sanchaniya(Noticee No.14) 20768 69



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Bharat G Vaghela(Noticee No.6) 46114 93Bharat Shantilal Thakkar(Noticee No.3) 10 1Bipin Jayant Thaker(Noticee No.4) 1114 4

Hemant Madhusudan Sheth(Noticee No.11) 1098 3Labh Share and Stock PrivateLimited (Noticee No.1) 77 1

Arcadia Share & Stock Brokers Pvt. Ltd. (Noticee No. 20) Total 69181 171

Arch Finance Ltd.Bhavesh Pabari(Noticee No.9) 4900 5

Arch Finance Ltd. Total 4900 5

Fairwealth Securities Ltd.

Ankit Sanchaniya(Noticee No.14) 344 2Bhavesh Pabari(Noticee No.9) 1873 4Chirag Rajnikant Jariwala(Noticee No.7) 212 2Hemant Madhusudan Sheth(Noticee No.11) 1645 3Prem Mohanlal Parikh(Noticee No.10) 3328 5Vivek Kishanpal Samant(Noticee No.15) 601 2

Fairwealth Securities Ltd. Total 8003 18

IFCI Financial Services Ltd.Hemant Madhusudan Sheth(Noticee No.11) 1946 2

IFCI Financial Services Ltd. Total 1946 2

Master Capital Services LimitedBharat Shantilal Thakkar(Noticee No.3) 2090 3

Master Capital Services Limited Total 2090 3

Religare Securities Ltd.Vivek Kishanpal Samant(Noticee No.15) 31 1

Religare Securities Ltd. Total 31 1

Grand Total 86151 200

28. From the price volume data analysis on NSE, I note that the scrip of SIL was

traded on 192 trading days at NSE. Out of 192 trading days, the group entities

had traded among themselves on 159 days, i.e. 83% of the total number of

days the scrip was traded during the relevant period. By trading among

themselves, the group entities had contributed to daily market volume traded

in the scrip in the range from 79.12% on May 03, 2010 to 1.06% on January 17,

2011. Out of 159 trading days on which the group entities traded among



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themselves, on 127 trading days the 18 Pabari-Parikh Group entities

contributed for more than 50% to the total market volume of the scrip during

the relevant period.

29. Further, out of 159 trading days on which the Pabari-Parikh Group traded, I

note that on 149 trading days both buy and sell orders were placed within

time difference of one minute. By trading amongst themselves, the group

entities contributed to daily market volume of the scrip in the range from

20.23% on May 03, 2010 to 1.93% on December 08, 2010. I also note that out of

149 trading days, on 19 trading days Pabari-Parikh Group entities contributed

for more than 50% of the total market volume by placing both buy and sell

order within one minute time difference. On further examination, it was alsonoted that out of 149 trading days, on 100 trading days the trades executed by

the Pabari-Parikh Group entities were synchronized in nature. By executing

synchronized trades among themselves, the Pabari-Parikh Group entities

contributed to the total market volume in the range from 0.84% on May 10,

2010 to 1.93% on December 08, 2010. The group entities contributed for more

than 50% of the market volume by entering into synchronized trading on 3

trading days.

30. I further note that out of 130787 trades executed during the period under

investigation, 31253 trades were places at a price less than the Last Traded

Price (LTP) (Summation TP-LTP= ` - 26548.60), 68053 trades were placed at a

price equal to LTP and 31481 trades were placed at a price greater than LTP

(Summation TP-LTP= Rs. 26450.85). Upon further examination, it was also

noted that out of 130787 trades, the 18 Pabari-Parikh Group entities entered

into 41149 buy transactions while dealing through multiple brokers.

Additionally, I also note that out of 41149 trades, 8504 trades were placed at a

price less than LTP (contributing a gross fall in price by ` - 6681.20), 24690

trades were placed at a price equal to LTP and 7955 trades were placed at a

price greater than LTP (contributing a gross increasing in price by ` 6229.65).

The details of individual contributions by entering into buy transactions



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towards changing the price of the scrip, including the major contribution to

net positive LTP differential by Noticee Nos. 9 & 11 are as under:

Name of the entityNo oftrades

no oftrades

aboveLTP

Gross

increasein price

No oftradesless

thanLTP

Gross

fall inprice

No of

tradesat LTP

Netimpact

Labh Share and Stock PrivateLimited 773 294 141.30 272 -135.85 207 5.45Rajnandi Yarns Private Limited 23 1 0.50 4 -2.00 18 -1.50Bharat Shantilal Thakkar 1345 114 19.40 67 -26.10 1164 -6.70Bipin Jayant Thaker 4065 721 671.70 731 -679.70 2613 -8.00Vasudev Ramchandra Kamat 0 0 0.00 0 0.00 0 0.00Bharat G Vaghela 10329 2622 2060.20 3105 -2422.50 4602 -362.30Chirag Rajnikant Jariwala 3226 431 313.45 385 -330.35 2410 -16.90

Kishore Chauhan 1276 102 53.10 146 -81.15 1028 -28.05Bipinkumar Gandhi 40 22 13.45 10 -5.45 8 8.00Bhavesh Pabari 2664 591 450.65 496 -349.40 1577 101.25Prem Mohanlal Parikh 2401 301 141.30 338 -234.55 1762 -93.25Santosh Maruti Patil 55 23 16.35 23 -18.05 9 -1.70Hemant Madhusudan Sheth 3339 624 463.40 549 -363.50 2166 99.90 Jigar Praful Ghoghari 848 49 15.15 48 -24.30 751 -9.15Mala Hemant Sheth 3 2 0.60 1 -0.05 0 0.55Gaurang Ajit Seth 30 1 0.05 2 -1.60 27 -1.55Ankit Sanchaniya 7456 1864 1733.25 2034 -1836.40 3558 -103.15Vivek Kishanpal Samant 3276 193 135.80 293 -170.25 2790 -34.45Grand Total 41149 7955 6229.65 8504 -6681.20 24690 -451.55

31. In addition to above, I further note that the price of the scrip on NSE opened

at ` 118.70 and touched a high of ` 169.00, i.e. there was increase of ` 50.30. I

note that on 192 trading days, a new high price was discovered for 82

occasions. Consequently, I also note that out of 82 occasions, on 30 occasions

(i.e. on 16 days out of 26 days), Noticee Nos. 6, 7, 9, 11, 14 & 15 contributedmajorly to increase the price.

32. It was, therefore, alleged in the SCN that the Noticee Nos. 1 to 19, by indulging in

manipulative trade practices on both the exchanges 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 of SIL and

further alleged that the Noticee No. 20, by executing the manipulative trades onbehalf of the Noticee Nos. 1 to 19, had violated Clauses A(1), (2) & (3) of the Code



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of Conduct for Stock Brokers as specified under schedule II read with Regulation

7 of the Broker Regulations.

Submissions made by the Noticees:

Noticee No.1:

33. Noticee No. 1 vide its reply dated January 10, 2014 while denying being part of

the Pabari-Parikh Group, submitted that it has neither received nor given any

funds to Noticee No. 9 and therefore, is not connected to the Pabari -Parikh

Group in any way. It has also neither received nor transferred any shares by way

of off-market transactions. The Noticee submitted that it has done net delivery

based business in the scrip of SIL through a NSE and BSE registered broker i.e.

Noticee No.20 and the Noticee placed orders with the said broker who in turn

executed trades for the Noticee. The Noticee being a client could not have been a

party to said synchronized transactions. Further, the Noticee submitted that it

had executed trades only on 8 days out of the total of 180 days during which the

scrip was traded. Further, as regards the allegation of self trades executed on

December 7, 2010, the Noticee No. 1 submitted that its total volume traded in the

scrip on BSE was 2,87,763 out of the total volume traded on the said date (i.e.6,34,654 shares) while the total volume traded on NSE was 350021 out of the total

volume traded in the scrip on the said date i.e. 6,96,042. Further, the self trade of

77 shares is very insignificant in volume.

Noticee No.3:

34. Vide letter dated October 16, 2014, the Noticee No. 3 submitted his reply to the

SCN. The Noticee stated that he has been debarred from buying, selling and

dealing in the securities market vide SEBI order dated February 02, 2011 and the

same was later confirmed vide SEBI order dated July 08, 2011 and that by

initiating adjudication proceedings in the matter, although the earlier debarment

is still in force, it amounts to "double jeopardy". The Noticee denied being

connected to the alleged Pabari-Parikh Group and stated that he has traded in the

scrip of SIL independently. He also submitted that the trading done by him in the

scrip of SIL on BSE and NSE are negligible in volume. The Noticee being a trader



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and into the business of jobbing had traded in lot of other scrips apart from SIL

before and after the investigation.

35. As regards the allegation of the said Noticee's association with the Pabari Parikh

Group, he admitted to having business relation with few entities and sharing thesame postal address with that of Noticee No. 9. He also admitted having

transferred funds with Noticee No. 9 along with few other entities. Further, the

Noticee also admitted carrying out off-market transfers with a few entities. On

the other hand, the Noticee denied carrying out any funds transactions for

purchase/sale in the scrip of SIL with Noticee No. 9 and other entities. Further

the Noticee No. 3 submitted that he has only bought 1395519 shares and sold

1518102 shares which constitutes only 1.50% and 1.63% of the total market

volume traded in the scrip of SIL during the investigation period. The Noticee

submitted that it is alleged in the SCN that he had received/transferred a total of

784500 shares (1.42%) out of the total 5.53 crore shares through off market

transfers. It is the case of the Noticee that this could not have affected the trading

in the market by resulting in a huge rise in the trading volume.

36. The Noticee submitted as regards the synchronized trades that were executed on

BSE that, as far as his buy is concerned, his trading within the group is only 1.32%

of the total market volume, while the orders which were placed in less than one

minute were also 0.44% of the total market volume. Further, the synchronized

trading carried out by the Noticee was only 0.03% of the total market volume.

Similarly, as far as his sale is concerned, his trading within the group is only

1.63% of the total market volume, while the orders which were placed in less thanone minute were also 0.46% of the total market volume and his synchronized

trading was only 0.04% of the total market volume. The Noticee stated that the

said volumes of trading were very negligible in quantity which could not have

created artificial market volume.

37. The Noticee submitted with respect to the details of trades illustrated in

Annexure D that, his buy and sell within the alleged group of entities are only



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0.03% and 0.04% respectively and that he had instructed his broker to execute the

orders on the anonymous trading platform of the stock exchanges and therefore,

he was not aware of the counter party. Moreover, in majority of his trading the

time difference was more than one minute i.e. ranging from one and a half

minute to more than one and a half hours for the shares purchased and similarly,ranging from two minutes to more than forty minutes for the shares sold. Further,

in majority of the orders there was a large difference in the quantity ordered and

the price, consequently, the Noticee submitted that abovementioned trades

cannot be synchronized trades in nature. In addition, the Noticee stated that the

said synchronized trading was carried out by him only on 9 days out of the total

98 trading days.

38. As regards the synchronized trades executed between the Pabari Parikh Group of

entities the Noticee submitted that only four transactions on the buy side for a

total of 24,451 shares which accounted for 0.03% and five transactions on the sell

side for a total of 41,115 shares which is accounted for 0.04% of the total market

volume, were executed by his broker. Furthermore, with respect to the allegation

of self trades, the Noticee no. 3 submitted that he had executed 6 self trades for a

volume of 2,263 shares which cannot be counted in percentage. Further, out of 6

orders in 3 orders, the buy orders were different from the sell orders. Upon

analysis of the trades carried out by the Noticee on June 01, 2010, the Noticee

submitted that he had placed 333 shares worth of buy orders and 80,000 shares

worth of sell orders while the quantity of order which got matched were merely

150 orders. Only on 2 days out of the 180 days did the orders get matched

inadvertently.

39. With respect to the trades carried out by the Noticee on NSE, the said Noticee

submitted that, he has only bought 8,56,100 shares and sold 8,28,413 shares

which was 1.06% and 1.02% of the total market shares of SIL during the

investigation period. As regards the synchronized trades that were executed on

NSE, the Noticee submitted that, as far as his buy is concerned, his trading within

the group is only 1.01% of the total market volume and his synchronized trading



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is also only 1.01% of the total market volume. Similarly, as far as his sale is

concerned, his trading within the group is only 0.92% of the total market volume

and his synchronized trading is also only 0.09% of the total market volume. The

Noticee further stated that in more than 90% of the Noticee's trading the price of

the buy and the sell trade has not matched and therefore cannot be synchronized.

40. The Noticee submitted regarding his synchronized trades with the Pabari Parikh

Group as illustrated in Annexure F that, he bought shares of SIL which accounted

for only 0.03% and sold shares of SIL which accounted for only 0.09% which

were executed by his broker. The alleged synchronized trades were executed by

the Noticee only on 5 days out of the total 100 trading days. Furthermore, with

respect to the alleged self trades, the Noticee stated that the 4 self trades executed

by him for a volume of 2,100 shares cannot even be counted in percentage. Upon

analysis it was observed by the Noticee that there was a large difference between

in the buy order and the sell order quantities and further, out of 4 orders in 3

orders, the buy order rate was different from the sell order rate. Upon further

analysis of his trading on May 20, 2010, the Noticee stated that he had placed buy

orders for 7500 shares and sell orders for 5,000 shares while the quantity of order

which got matched was merely 340 shares. Only on 2 days out of the 180 days did

the orders get matched inadvertently.

41. Vide letter dated April 21, 2014, the Noticee No. 4 had submitted that he has

been debarred from buying, selling and dealing in the securities market vide

SEBI order dated February 02, 2011 which was confirmed vide SEBI order dated July 08, 2011. Further, he stated that as the investigation period is 4 years old, he

is in the process of collating the data and will be filing his detailed reply in the

matter. Accordingly, vide letter dated November 13, 2014, the Noticee No. 4

filed his detailed reply in the matter. The Noticee submitted that he is into the

business of jobbing and arbitrage activities in the stock market.

Noticee No. 4:



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42. As regards the allegation of off market dealings within the group, the

Noticee submitted that he had paid and received consideration for the same,

however, he had no commercial relationship or understanding of any nature

with them. He also submitted that the off market dealings with Noticee Nos.

11 & 16 was carried out to meet urgent exigencies of fund requirements anddo not relate to any of the Noticees trades in the market. Further, the

Noticee submitted that he had carried out transactions in the scrip

independently and the above mentioned off market transactions have not

had any impact on the market price of SIL. Additionally, the Noticee stated

that he had traded in several other scrips and hardly any linkages or

similarities were found on dealing with the alleged Pabari-Parikh entities.

Therefore, for merely executing few stray off market transactions, the

Noticee submitted that he cannot be linked to the group. With respect to the

allegation of synchronized trades, the Noticee submitted that the

synchronization of the orders with the group were purely coincidental as he

was not aware of the counter parties. Therefore, these synchronized trades

cannot have had any impact on the market equilibrium, as the value and the

volume were insignificant compared to the total volume in the scrip during

the investigation period.

43. As regards the synchronized trades allegedly executed by him individually,

the Noticee submitted that on BSE only 1,23,874 shares (0.13%) were

synchronized out of his total buy volume of 48,17,677 shares (5.17%) and on

NSE only 2,76,949 shares (0.34%) were synchronized out of his total buy

volume of 47,57,443 shares (5.87%). Similarly, on BSE only 2,11,685 shares(0.23%) were synchronized out of his total sell volume of 57,40,151 shares

(6.16%) and on NSE only 3,22, 577 shares (0.40%) were synchronized out of

his total buy volume of 53,22,577 shares (6.63%). He also submitted that, as

he was not aware of the counter party, the synchronized trades were mere

coincidence.



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Noticee No. 5:46. The Noticee No. 5 submitted his reply to the SCN vide letter dated November 17,

2014. The Noticee stated that he is a doctor by profession and Noticee No.3 (Shri

Bharat Shantilal Thakkar), being one of his patients, had advised him to deal in

capital markets. The said Noticee Nos. 5 and 3 were clients of the broker Angel

Shares Broking however, the investment decisions were taken independently.

Noticee No. 5 further submits that he had sold 19, 500 shares (accounting for

0.02%) of the total market volume in the scrip of SIL during the period under

investigation. Further, all his trades were delivery based which were met with the

pay in obligation of broker in time, hence it is the case of the Noticee that there

cannot be any artificial volume or misleading appearance of trading in the scrip

of SIL. Further, the Noticee denied executing any circular and/or synchronizedtrades in the scrip of SIL or entering into reversal trades through different brokers

using different client codes. He also denied his association with the alleged

Pabari-Parikh Group, especially, with Noticee No.9. Further, he stated that he

received 20,000 shares of SIL on September 10, 2009 in off- market transaction

from Noticee No.3 against which consideration was paid by Noticee No. 5 to

Noticee No.3. Further, the Noticee submitted that his trading in the scrip of SIL is

very miniscule to have impacted the market thereby, creating artificial volume.

Noticee No. 7:

47. Noticee No. 7 vide his letter dated April 21, 2014 submitted that he has been

debarred from buying, selling and dealing in the securities market vide SEBI

order dated February 02, 2011. Further, he stated that as the investigation period

is 4 years old , he is in the process of collating the data and will be filing his

detailed reply in the matter. Accordingly, vide letter dated November 12, 2014,

the Noticee No. 7 filed his detailed reply in the matter. The, inter alia, submitted

that he is into the business of jobbing and arbitrage activities in the stock market.

He has met all the pay-in obligations of shares and securities from his own

account and has never defaulted in any manner. All the trading done by him was

well within his financial capabilities and not speculative. The Noticee also

submitted that he has traded in several other scrips including SIL before and after

the investigation. He also earned a small margin of arbitrage profit and had no



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other interest in SIL. Further, the Noticee denied being connected / associated

with the alleged Pabari-Parikh Group and stated that his investment decisions

were taken independently by him. He further submitted that the above

mentioned ad-interim ex-parte order was later confirmed vide SEBI order dated

July 08, 2011 and consequentially, he is still debarred from trading in thesecurities market. Additionally, it is submitted by the Noticee that by initiating

adjudication proceedings in the matter although the earlier debarment being still

in force is nothing but double jeopardy.

48. With respect to the trades carried out by the Noticee on BSE, he submitted that he

had bought only 4731650 shares and sold 4077019 shares of the total market

volume of 121235196 shares of SIL, while his total buy volume is 5.08% while histotal sale volume is 4.38% of the total market volume. Further, with respect to the

trading carried out by the Noticee No. 7 on NSE, he submitted that he had only

bought 5055146 shares and sold 5910781 shares which is 6.24% and 7.30% of the

total market shares of SIL during the investigation period. In addition, with

respect to the trades mentioned in Annexure C to the SCN, the Noticee submitted

that his total buy volume was 5.08% and sell volume was 4.38% of the total

market volume traded in the scrip of SIL. Further, with respect to the alleged

synchronized trades, the Noticee submitted that the shares which were traded in

synchronized manner on buy side of his trades constituted for only 025% of the

total volumes traded and on the sell side it constituted for 0.20% of the total

traded volume in the scrip of SIL. The said volumes of trading were negligible in

quantity, therefore could not be carried out with manipulative intent. He also

submits that his trades have not disturbed the market equilibrium.

49. With respect to the trade details provided in Annexure D of the SCN, the Noticee

he had instructed his broker to execute the orders on the anonymous trading

platform of the stock exchanges and therefore, he was not aware of the counter

party. Moreover, in majority of his trading the time difference was more than one

minute i.e. ranging from few seconds to more than three and a half hours for the

shares purchased and similarly, ranging from a few seconds to forty seven



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any default. With regard to self trades, the Noticee submitted that there are only a

few stray instances of such alleged trades. The buy and the sell orders were

placed by different brokers.

52. As regards the synchronized trades allegedly executed by him individually, theNoticee submitted that on BSE only 3,94,745 shares (0.42%) were synchronized

out of his total buy volume of 88,61,360 shares (9.51%) and on NSE only 1,26,200

shares (0.16%) were synchronized out of his total buy volume of 31,34,691 shares

(3.87%). Similarly, on BSE only 4,03,261 shares (0.43%) were synchronized out of

his total sell volume of 1,01,44,037 shares (10.89%) and on NSE only 3,01,140

shares (0.37%) were synchronized out of his total buy volume of 39,13,748 shares

(4.83%). Thus, the Noticee stated that the same were very minuscule percentages

to have affected the volumes in the market during the period.

53. Further, as regards the self-trades allegedly executed by him, the Noticee

submitted that, there are only few stray instances of such trades. Further, it is the

case of the Noticee that as the buy order quantity and the sell order quantity

which has been alleged to have matched has vast variance, the same cannot be

treated as self trades. Further, the said matching had taken place wherein the buy

order member is different from sell order member.

54. With respect to the allegation of being part of the Pabari-Parikh Group, the

Noticee submitted he is not associated with the Pabari Parikh Group in any way,

because even though he is a director in Noticee No. 16 (Rajnandi Yarns Pvt. Ltd)

along with Noticee No. 11 (Shri Hemant Madhusudhan Sheth), he makes hisinvestment decisions independently and also cannot be blamed for any act or

omission of Noticee No. 11. Further, the Noticee stated that Noticee No. 3 (Shri

Bharat Shantilal Thakkar) is not his real uncle as they do not share a common

address/ telephone number or e-mail id. Additionally, as regards the off market

dealing with few of the other Noticees, the Noticee submitted that the same were

carried out to meet certain urgent exigencies of fund requirements and they do

not relate to the Noticee's trades in the market. Further, the Noticee's off market



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alleged relationship with one Shri Bhupesh Rathod (not a related party in the

present case) has not been established but for stating that his name was filled as

an introducer while filing his KYC documents with one of the brokers through

which the Noticee traded namely, S P Jain Securities Pvt. Ltd. The Noticee

clarifies that his name was preferred only on the ground that he was already aregistered client with the broker. Therefore, for merely executing few stray off

market transactions, he cannot be linked to the group. The Noticee submitted that

he has traded in several other scrips and hardly any linkages or similarities were

found with the said entities while carrying out trades in the other scrips. The

Noticee also submitted that the synchronization of the orders with the group

were purely coincidental as he was not aware of the counter parties and these

synchronized trades have had no impact on the market equilibrium, as the value

and the volume were insignificant compared to the total volume in the scrip

during the investigation period.

58. Further, the Noticee submitted that on BSE only 2,68,146 shares (0.29%) were

synchronized out of his total buy volume of 44,80,527 shares (4.81%) and on NSE

only 2, 52, 719 shares (0.31%) were synchronized out of his total buy volume of

34,46,372 shares (4.25%). Similarly, the Noticee submitted that on BSE only

3,38,972 shares (0.36%) were synchronized out of his total sell volume of 45,87,734

shares (4.93%) and on NSE only 2,49,652 shares (0.31%) were synchronized out of

his total sell volume of 36,31,238 shares (4.48%). He also submitted that as he was

not aware of the counter party, the said synchronized trades were coincidental in

nature and the value/volume of the said trades was negligible when compared to

the market volume.


submitted that, the details furnished in Annexure G of the SCN are different

from the facts and figures as can be seen from the data extracted for the trades

relating to him, as the buy and sell orders for the same have been placed from

different broker terminals during different duration of time with different

quantity and different rate as they were carrying out arbitrage trading on both



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with established dividend track record and its shares were traded in B group

in BSE, therefore, he decided to deal in the shares of SIL.

62. With regard to the off market dealing with Noticee Nos. 4, 10, 13, 14 & 16 the

Noticee submitted that he had paid and received consideration for the same, andthat he had no commercial relationship or understanding of any nature with

them. Noticee No. 13 (Ms. Mala Hemant Sheth) is the wife of the said Noticee

(Hemant Madhusudhan Sheth) and therefore, all the transfers / dealings made

with her are strictly within the family. Further, the Noticee submitted that he had

carried out transactions in the scrip of SIL independently and the above

mentioned off market transactions have not had any impact on the market price

of SIL. Therefore, for merely executing few stray off market transactions the

Noticee cannot be linked to the group. With respect to the allegation of being

part of the Pabari-Parikh Group, the Noticee submitted he is not associated with

the Pabari Parikh Group in any way, because even though he is a director in

Noticee No. 16 (Rajnandi Yarns Pvt. Ltd) along with Noticee No. 09 (Shri

Bhavesh Pabari), he makes his investment decisions independently and also

cannot be blamed for any act or omission of Noticee No. 09. Additionally he

submitted that his alleged relationship with Bhupesh Rathod (not a related party

in the present case) has not been established but for stating that his name was

filled as an introducer while filing his KYC documents with one of the brokers

through which the Noticee traded namely, S P Jain Securities Pvt. Ltd. The

Noticee clarifies that his name was preferred only on the ground that he was

already a registered client with the broker. The Noticee submitted that he has

traded in several other scrips and hardly any linkages or similarities were foundwith the said group entities while dealing in the said other scrips.

63. With regard to the allegation of synchronised trading, the Noticee submitted

that the said synchronized trades carried out with the group were purely

coincidental as he was not aware of the counter parties and these

synchronized trades cannot have had any impact on the market equilibrium,

as the value and the volume were insignificant compared to the total volume



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in the scrip during the investigation period. Further, the Noticee submitted

that on BSE only 2,33,072 shares (0.25%) were synchronized out of his total

buy volume of 68,90,281 shares (7.40%) and on NSE only 3,20,262 shares

(0.40%) were synchronized out of his total buy volume of 56,33,024 shares

(6.95%). Similarly, the Noticee submitted that on BSE only 7,48,019 shares(0.80%) were synchronized out of his total sell volume of 97,54,318 shares

(10.47%) and on NSE only 5,44,491 shares (0.67%) were synchronized out of

his total sell volume of 57,48,297 shares (7.10%). The value/ volume of the

said trades were negligible when compared to the market volume and

therefore, it is the case of the Noticee that they could not have created any

impact on the volumes in the scrip of SIL on the exchange.


submitted that, the details furnished in Annexure G of the SCN are different

from the facts and figures as can be seen from the data extracted for the trades

relating to him, as the buy and sell orders for the same have been placed from

different broker terminals during different duration of time with different

quantity and different rate as they were carrying out arbitrage trading on both

the exchanges. Further, with respect to the trade time the Noticee stated that

there is a vast difference in buy order placing time, sell order placing time and

the execution of the said orders into trades, which goes to show that again the

buy/ sell order and trade time do not match. The Noticee submitted that the

buy order quantity and the sell order quantity having a huge difference

resulting into a very small quantity in itself shows that the alleged self-trades

may have gotten executed owing to the Noticees jobbing and arbitrage

business. Therefore, it was during the due course of his business that the

Noticees huge volume matched a small quantity of orders without his

knowledge at the prevailing market price.

65. With respect to the allegation of no change in beneficial ownership while

executing the trades, the Noticee submitted that, the total number of shares

traded on BSE is 9,31,32,003 out of which the total delivery quantity volume



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was 5,44,84,576 which works out to almost 58.50% of the total market volume as

available on the BSE website. The same shows that the major amount of volume

carried out on the said exchange during the investigation period was delivery

based. Therefore, it is the case of the Noticee that there was a change in

beneficial ownership for the trades carried out by him. As regards the largevolume said to have been created by the Noticee, he submitted that the same

was created in the scrip by him due to his arbitrage activities and considering

his holding in SIL shares his volume in the scrip is normal.

Noticee No. 12:

66. Vide letter dated April 21, 2014 the Noticee No. 12 had submitted that he has

been debarred from buying, selling and dealing in the securities market vide

SEBI order dated February 02, 2011. Further, he stated that as the

investigation period is 4 years old, he is in the process of collating the data

and will be filing his detailed reply in the matter. Accordingly, vide letter

dated August 14, 2014, the Noticee No. 12 filed his detailed reply in the

matter. The said Noticee, inter alia, submitted that he is into the business of

jobbing and arbitrage activities in the market. The said Noticee submittedthat SIL was a profit making company with established dividend track

record and its shares were traded in B group in BSE, therefore he decided to

deal in the shares of SIL.

67. With regard to the off market dealing with Noticee Nos. 4, 6, 10, 11 & 14, the

Noticee submitted that he had paid and received consideration for the same

and that he had no commercial relationship or understanding of any nature

with them. Further, the Noticee submitted that he had carried out

transactions in the scrip independently and the above mentioned off market

transactions cannot have had any impact on the market price of SIL.

Therefore, for merely executing few stray off market transactions, the he

cannot be linked to the group. The Noticee further submitted that he has

traded in several other scrips and hardly any linkages or similarities were

found with the said entities while trading in the said other scrips.



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68. With regard to the charge of carrying out synchronized trades, the Noticee

submitted that the said trades with the group were purely coincidental as he

was not aware of the counter parties and the said trades have had no impact

on the market equilibrium, as the value and the volume were insignificantcompared to the total volume in the scrip during the investigation period.

The Noticee submitted that on April 01, 2010, only 43,355 shares out of his

buy volume of 9,47,718 shares were synchronized. Similarly, only 27,400

shares out of his sell volume of 5,82,260 shares were synchronized on March

10, 2010 (15000 shares), March 17, 2010 (3000 shares) and April 22, 2010

(9400 shares). He also submitted that as he was not aware of the counter

party, the synchronization were coincidental and the value/volume of the

said trades were negligible when compared to the market volume traded in

the scrip of SIL. Therefore, the said trades could not have created volumes in

the said scrip and impacted trading in the scrip of SIL on the exchange.

69. Further, as regards the self-trades allegedly executed by the Noticee, he

submitted that only on a single day 9990 shares coincidentally matched with

the Noticee's 10,000 shares. The Noticee stated that instead of putting

another buy order of 10000 shares by mistake a sell order was punched,

however, no harm or damage has been caused to anyone and the said trade

had in no way impacted the market equilibrium as the count and quantity

were insignificant.

Noticee No. 13:

70. Vide letter dated August 19, 2014, the Noticee No. 13 submitted her reply in the

matter and submitted that she is into the business of business of jobbing and

arbitrage activities in the market. Further, the said Noticee submitted that she has

been debarred from buying, selling and dealing in the securities market vide SEBI

order dated February 02, 2011. The Noticee's demat account is still frozen.

Additionally, she stated that by initiating adjudication proceedings in the matter

although the earlier debarment being still in force amounts to "double jeopardy".



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With respect to the allegation of being connected / related to the Pabari-Parikh

group, the Noticee denied having any movement of funds between her and

Noticee No. 9 (Shri Bhavesh Pabari). The Noticee No. 13 admits being wife of

Noticee No. 11 (Shri Hemant Madhusudhan Sheth) but denies having any

business / professional connection with him.

71. Further, the Noticee submitted that on BSE she bought only 29,531 shares which

accounted for 0.03% of the total market volume and sold only 51,921 shares which

accounted for 0.06% of the total market volume traded in the scrip of SIL. She also

submitted that her buy volume accounted for 0.72% and sell volume accounted

for 0.54 % of the total market volume within the group in off market. With regard

to trading within the group, the Noticee submitted that her total buy within the

group is only 0.02% of the total market volume and the orders placed for less than

one minute are also 0.02% of the total market volume, while there are no buy

transactions through synchronized trades. Similarly her total sale within the

group is only 0.02% of the total market volume and the orders placed less than

one minute are also 0.02% of the total market volume, whereas, her sale through

synchronized trading is only 0.01%.

72. With regard to the allegation of synchronized trades, the Noticee submitted that

she had bought 0.03% shares and sold 0.06% shares of the market volume traded

in the scrip. Out of her total trading, only in a couple of trades executed, the time

difference was less than one minute and in all others the time difference was

more than one minute i.e. ranging from more than two minutes to more than five

hours and twenty five minutes for the shares purchased and ranging from oneminute to more than three minutes for the shares sold. In majority of the orders,

there was a huge difference in the quantity ordered, hence, it is the case of the

Noticee that the same cannot be synchronized trades. As regards the

synchronized trades illustrated in the SCN, the said Noticee submitted that she

executed only three transactions of sale for a total of 12, 560 shares constituting

0.01% of the total traded volume in the scrip of SIL. The Noticee stated that since,

the value and the volume of the alleged synchronized trades executed by the said



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from buying, selling and dealing in the securities market vide SEBI order dated

February 02, 2011. Further, the said Noticee stated that vide SEBI order dated July

08, 2013 he is still debarred from trading in the securities market. The Noticee

submitted that by initiating adjudication proceedings in the matter although the

earlier debarment being still in force amounts to "double jeopardy". The Noticeealso submitted that he is not a part of any group and he had carried out

transactions in the scrip independently. He stated that his trading as per the SCN

was negligible in quantity in comparison to the total traded volume in the market

and he has also dealt in several other scrips prior to and after the period of

investigation.

75. With regard to the connection to the other entities, he submitted that the off

market dealings with some of the other Noticees was carried out to meet urgent

exigencies of fund requirements and do not relate to any of the Noticees trades in

the market. Therefore, for merely executing few stray transactions matched that

of a groups he cannot be linked to the group as his transactions were done

independently.

76. The Noticee further submitted that he is into the business of jobbing and arbitrage

activities in the market and he had neither received any investor complaints nor

were any query was raised as regards his trading in the shares of SIL. As regards

his alleged off market dealings with the group, the Noticee submitted that he had

paid and received consideration for the same and that he had no commercial

relationship or understanding of any nature with them. Further, the Noticee

submitted that he had carried out transactions in the scrip independently and theabove mentioned off market transactions have not had any impact on the market

price of SIL. The Noticees submitted that he has traded in several other scrips and

hardly any linkages or similarities were found with the alleged group entities

while dealing in the said other scrips. Therefore, for merely executing few stray

off market transactions, the he cannot be linked to the group. With respect to the

synchronized trades carried out by the noticee, he submitted that the said trades

were purely coincidental as he was not aware of the counter parties. The Noticee



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submitted that on BSE only 3,03,168 shares (0.33%) were synchronized out of his

total buy volume of 51,45,520 shares (5.52%) and on NSE only 2,50,945 shares

(0.31%) were synchronized out of his total buy volume of 52,66,567 shares

(6.50%). Similarly, the Noticee submitted that on BSE only 2,02,345 shares (0.22%)

were synchronized out of his total sell volume of 47,87,916 shares (5.14%) and onNSE only 3,61,351 shares (0.45%) were synchronized out of his total sell volume

of 69,03,099 shares (8.52%). Therefore, these synchronized trades had no impact

on the market equilibrium and the value / volume were insignificant compared

to the total volume in the scrip during the investigation period.


submitted that, the details furnished in Annexure G of the SCN are differentfrom the facts and figures as can be seen from the data extracted for the

trades relating to him, as the buy and sell orders for the same have been

placed from different broker terminals during different duration of time

with different quantity and different rate as they were carrying out arbitrage

trading on both the exchanges. Further, with respect to the trade time the

Noticee stated that there is a vast difference in buy order placing time, sell

order placing time and the execution of the said orders into trades, which

goes to show that again the buy/ sell order and trade time do not match. The

Noticee submitted that the buy order quantity and the sell order qu

Documents

Adjudication Order against 20 entities in the matter of Spectacle Infotek Limited