Adjudication order in the matter of Harita Seating Systems Ltd

8/20/2019 Adjudication order in the matter of Harita Seating Systems Ltd.

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Adjudication Order in the matter of Harita Seating Systems Limited

Page 1 of 54 July 31, 2015

BEFORE THE ADJUDICATING OFFICER

SECURITIES AND EXCHANGE BOARD OF INDIA

[ADJUDICATION ORDER NO.EAD-5/SVKM/RGA/AO/01-12/2015]

________________________________________________

UNDER SECTION 15-I OF SECURITIES AND EXCHANGE

BOARD OF INDIA ACT, 1992 READ WITH RULE 5 OF SEBI

(PROCEDURE FOR HOLDING INQUIRY AND IMPOSING

PENALTIES BY ADJUDICATING OFFICER) RULES, 1995

In respect of

S.NO. NAME OF THE ENTITY Order No. PAN No.

1. Priya Dhaval Thakkar EAD-5/SVKM/RGA/AO/01/2015 ACBPT1501C

2. Mahesh Dhanvantrai Mehta EAD-5/SVKM/RGA/AO/02/2015 AACPM3933C

3. Nikunj Dhanvantrai Mehta EAD-5/SVKM/RGA/AO/03/2015 AACPM3931A

4. Amita Nitesh Thakkar EAD-5/SVKM/RGA/AO/04/2015 ACAPT2682B

5. Fenil Nitesh Thakkar EAD-5/SVKM/RGA/AO/05/2015 AILPT1308D

6. Nitesh Arjun Thakkar HUF EAD-5/SVKM/RGA/AO/06/2015 AACHN5060K


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7. Madhukanta Dhanvantrai

Mehta

EAD-5/SVKM/RGA/AO/07/2015 AAGPM7193Q

8. Nitesh Arjun Thakkar EAD-5/SVKM/RGA/AO/08/2015 AABPT3925E

9. Dhaval Arjun Thakkar EAD-5/SVKM/RGA/AO/09/2015 AAAPT5706A

10. Yogesh Rasiklal Doshi EAD-5/SVKM/RGA/AO/10/2015 AAEPD3360Q

11. Darshana Yogesh Doshi EAD-5/SVKM/RGA/AO/11/2015 AEJPD8749N

12. Mitali Yogesh Doshi EAD-5/SVKM/RGA/AO/12/2015 AJNPD6635Q

In the matter of M/s Harita Seating Systems Limited

FACTS OF THE CASE

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

'SEBI') conducted an investigation into the alleged irregularities in

the trading in the shares of Harita Seating Systems Limited

(hereinafter referred to as 'HSSL/ scrip') for the period November

01, 2009 to March 31, 2010 (hereinafter referred to as the ‘relevant

period’) and into the possible violation of the provisions of the

Securities and Exchange Board of India Act, 1992 (hereinafterreferred to as 'SEBI Act, 1992') and various Rules and Regulations

made thereunder. The shares of HSSL are listed on BSE Limited

(BSE), National Stock Exchange of India Limited (NSE), Bangalore

Stock Exchange (BgSE) and Madras Stock Exchange(MSE).


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2. Pursuant to the said investigation, it was alleged that Priya Dhaval

Thakkar, Mahesh Dhanvantrai Mehta, Nikunj Dhanvantrai Mehta,

Amita Nitesh Thakkar, Fenil Nitesh Thakkar, Nitesh Arjun Thakkar

(HUF), Madhukanta Dhanvantrai Mehta, Nitesh Arjun Thakkar,

Dhaval Arjun Thakkar, Yogesh Rasiklal Doshi, Darshana Yogesh

Doshi, Mitali Yogesh Doshi (hereinafter referred to as 'Noticees')

while transacting through Aquarian Share Broking Co. Pvt. Ltd.

(hereinafter referred to as ' ASB ') a sub- broker (SEBI Regn No

INS 012298431) of SVS Securities Limited, trading member BSE &

NSE [SEBI Regn. No. BSE-INB010995736, INF010995736,

INB230995731 & INF230995731] (hereinafter referred to as 'SVS')

indulged in synchronized trades and cross deals that created

artificial volumes and rigged the price of the scrip. It was therefore,

alleged that Noticee No. 1 to Noticee No. 7 had violated Regulation

4(1), 4(2) (a) and (g) SEBI (Prohibition of Fraudulent and Unfair

Trade Practices) Regulations, 2003 (hereinafter referred to as

‘PFUTP Regulations, 2003’), and Noticee No. 8 to Noticee No.10

had violated Regulation 4(1), 4(2) (a), (b),(e) and (g) of PFUTP

Regulations, 2003 and Noticee No. 11 & Noticee No.12 had

violated Regulation 4(1)(2)(e)of PFUTP Regulations, 2003 and liable

for monetary penalty under section 15HA of SEBI Act, 1992.

APPOINTMENT OF ADJUDICATING OFFICER

3. SEBI vide December 11, 2012 appointed Shri P.K. Kuriachen as

the Adjudicating Officer under section 15 I of SEBI Act, 1992 read

with Rule 3 of 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

SEBI Act, 1992 the aforesaid alleged violations. Consequent to the

transfer of Shri P.K. Kuriachen, Shri Piyoosh Gupta was appointed


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as the Adjudicating Officer vide order dated July 30, 2013.

Subsequent to the transfer of Shri Piyoosh Gupta, Shri A. Sunil

Kumar was appointed as Adjudicating Officer vide order dated

November 08, 2013. Pursuant to the transfer of Shri A. Sunil

Kumar, the undersigned has been appointed as the Adjudicating

Officer vide order dated June 22, 2015.

SHOW CAUSE NOTICE, REPLY AND PERSONAL HEARING

4. Show Cause Notice No. EAD-2/RGA/4721/2013 dated February 22,

2013 (hereinafter referred to as 'SCN') was issued to the Noticees

under Rule 4(1) of the Rules to show cause as to why an inquiry

should not be initiated and penalty be not imposed under section

15HA of SEBI Act, 1992 for the alleged violations specified in the

said SCN.

5. Noticees vide letters dated April 22, 2013/April 26, 2013/May 06,

2013 submitted their reply to the SCN. The Noticees also availed of

the opportunity of personal hearing and appeared before theundersigned on June 30, 2015 and July 08, 2015. Written

submissions were also filed on behalf of the Noticees dated July 07,

2015. The salient submissions made by the Noticee No. 1, 4, 5, 6, 8

and 9 are as under:

• We are retail investors in capital market for the last several years and have

been holding equity shares of HSSL for last three years i.e. 2010, 2011

and 2012.

•

Our transactions were normal, buy and/or sell in the said scrip. Wereceived deliveries of bought shares and tendered deliveries of sold shares

from our existing stock lying in our demat accounts.

• We deny that we were involved in anyway in cross trades or artificial

volume in HSSL scrip as alleged or otherwise.BSE and NSE did not annul

the trades nor expunged the daily quotations of share prices of HSSL scrip

at the relevant time.


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• Trading platforms are online, real time, computerized, price and time

priority matching trade systems for orders keyed –in in different scrips

through a large number of terminals. The trading modules are therefore

anonymous and its algorithm not known to anyone. A family has to have a

separate trading/demat account for its different family members and who

may trade separatey, jointly and/or independently on selective occasion as

per strategy, conviction, and short/long term view on a scrip etc. factors.

Their trading on the same day does not mean anything adverse or

negative. Further, if a few orders get matched within family members

trading accounts when the scrip is illiquid, no wrongdoing can be

attributed to them.

• Each of Thakkar family members' trading, buying, selling and dealing and

investing was separate, independent and stand alone and recorded in

individual UCC, accounted in individual ledger account/demat account

and fund flow was through upfront mapped bank account. We declaredour profit/loss through trading in our separate income tax returns.

• Seen in a continuous/cumulative/comparative matrix, it is evident that

trading volume of some members (such as Shri Fenil ) was insignificant

and only on few days and some members trading was comparatively large

and on many days-there are vast differences in the style, pattern, method

and features of trading of members.

• Considering our volume on both the exchanges on a net basis(i.e. buy

minus sell) all the members were buyers (except in one case) during the

investigation period and they took deliveries of shares of HSSL.

• The basis viz trades and raisen detre for making the Thakkar family first

as group and connecting this group to other groups (of other families) and

making all such four groups into another big group of parties is not only

incorrect and improper but also perverse.

• The Thakkar family members did not act in concert with anyone-inter se

or intra-se. They had no business relationship with any of the parties of the

purported big group with whom they are included, bunched, bundled,

clubbed, lumped and tied to. Had there been any prior meeting of minds,

the pattern of trading would have been different, without any disconnect

and involved other dealings by Thakkar family members such as off-market, side deal, financing etc.

• Thakkar family has six trading accounts. Alleged quantity of shares and

%( percentage) of manipulative buy trades and sell trades as a % of market

volume of each party is different. Assuming but without admitting some

orders were matched, they did not result into any manipulation of price

and or volume and no economic loss was caused to anyone. Transfer of


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beneficial holding by one family member to another family member

through market mechanism is a legitimate activity.

• As Thakkar family wanted to keep and hold shares of HSSL and some

members wanted monies for temporary purpose (and as SEBI rules do not

permit intra-family adjustment of debits/credits in broker's office), a few

trades were done to shift holding from one member to another member

through market mechanism. Such cross trades which involved change of

beneficial ownership (and within the family) cannot be considered

objectionable.

• As far as Doshi family is concerned, the cross deals involved mostly sale

of HSSL shares by Doshi family members and purchase by Thakkar

family as investment in the said scrip. In view of the scrip being illiquid,

whenever funds were required by Thakkar family, the Doshi family either

bought shares from them or arranged buyer from their own family/circle.

• There is no relationship between Thakkar and Mehta family. Mehtafamily members bought shares, paid for and took deliveries. Thakkar

family members bought and sold shares when price went up and they

booked some profit. Mehta family was incidentally a buyer at the relevant

time.

• Alleged cross deals of Thakkar family members involved change of

beneficial ownership when they first sold and when they later bought from

Mehta family.

• The purported cross deals did not cause any adverse/negative impact nor

any aberration as they were within market price range and delivery based.

• Thakkar family has not caused any material or significant impact on price

of the said scrip. As desperate buyer may offer to buy at a higher price

than the ruling market price and a desperate seller may accept little lower

price than the prevailing price, the objective in both the cases being to

ensure execution of trade and not price manipulation.

6. The salient submissions made by the Noticee No. 2, 3 and 7 in

addition to the above submissions are as under:

• Mehta's were not involved in anyway in cross trades or price rigging in

HSSL scrip as alleged or otherwise. The volume of trading of Mehta

family cannot be treated as cross and or synchronized.

• Alleged manipulative trade is insignificant and number of trades are very

few.

• Assuming but without accepting the trade as synchronized, no fault can be

found as there was change in beneficial ownership.


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• No relationship with Thakkar family members. Commercial transactions

were separate and independent.

• Each of Mehta family members' trading, buying, selling and dealing and



and fund flow was through upfront mapped bank account. We declared

our profit/loss through trading in our separate income tax returns.

7. The salient submissions made by the Noticee No. 10, 11 and 12 in

addition to the above submissions are as under:

• Each of Doshi family members' trading, buying, selling and dealing and



and fund flow was through upfront mapped bank account. We declared

our profit/loss through trading in our separate income tax returns.

• In illiquid scrip if an investor holding shares of a company sees spurt in

the price on account of any event, then he may chose to sell at a higher

price on one exchange and then he may try to acquire shares back on the

same exchange or another exchange on the same day or the next day. For

that purpose he may place order at a higher price than the last traded price

or at last closing price on another exchange. This way of selling/buying

activity result into lowering of cost of holding of the investment. Hence

no manipulative intent is involved.

8. In terms of Rule 4(3) of the Rules, Noticees were granted an

opportunity of personal hearing Mr. J.J. Bhatt, Senior Advocate,

Authorized Representative of the Noticees (hereinafter referred to as

'AR') appeared for hearing on June 20, 2013 reiterated the earlier

submissions made by the Noticees in their reply and sought

additional time to file written submissions. Noticees vide letter dated

July 08, 2013 reiterated the earlier submissions. AuthorizedRepresentative appeared for hearing on August 19, 2013, May 13,

2014, June 30, 2015 and July 08, 2015.


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9. On July 08, 2015, Mr. Rajesh Shah, Chartered Accountant appeared

on behalf of the Noticees and filed written submissions dated July

07, 2015. The Noticees inter-alia submitted the following:

a) Noticee submitted that it has filed statement of trades of

their dealings in scrips other than HSSL and that the clients

are long standing clients who have dealt in other scrips.

b) As regards trade details in Annexure VI to the SCN, it was

submitted that in all there were 16 clients including the

Noticees who dealt in the scrip. Out of the 16 clients, 4

clients were let off by SEBI with warning. Therefore, it was

submitted that the rest of the clients i.e. Noticees are

similarly situated and hence deserved to be viewed similarly.

While referring to Annexure VI to the SCN it was pointed out

that matching time of orders are as long as 45 minutes to

more than one hour in some of the trades which means that

the orders were exposed to the market as a whole and it

would not be correct to allege that these are synchronized

trades as alleged in the SCN. In all, there were 65 trades

executed in less than 10 seconds over a period of 5 months

with about 10-12 trades in a month. If there was any

manipulative intent on the part of the Noticees, higher

volumes could have been built by the Noticees in a short

span of time and the Noticees would have exited from the

scrip of HSSL. However, no such intention is shown by the

trading behavior over a period of 5 months and all 12 clients

are holding the scrip even as on today. Therefore, it is not

the case of rising the price by manipulation and then exiting

the scrip by making unjust profit. It was further submitted that

around 80 clients have traded in the HSSL scrip and majority

are still holding including 12 Noticees.


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c) Referring to page no. 4 of reply dated July 07, 2015, it was

submitted that over a period of four financial years

commencing from 2009-10 the clients were adding on to the

stock of HSSL thereby meaning that Noticees had a long

term view in the company which is reflected by their

incremental increase in the holdings over the years.

Referring to Annexure II to the reply dated July 07, 2015, it

was submitted that the general market index had risen by

nearly 80% between April 2009 and March 2010 and the

Auto Index rose nearly by 150%. Further, the individual

stocks within the Auto sector have also shown an upward

movement ranging from 131% in the case of Kennametal to

as high as 447% in the case of WABCO. In comparison, the

increase in the price of the shares of HSSL during this period

was 108%. It was thus submitted that the price increase in

the shares of HSSL was in tandem with the market, Auto

sector and peer group companies.

d) Further the company was coming out of the losses during

the said period and there was corporate announcement in

February, 2010 with regard to acquisition of shares of

subsidiary of HSSL by a German company which has led to

an increase in the price of the scrip. It is therefore contended

that rise in price of the scrip was due to the better

performance and the positive prospects of the company

rather than manipulative intent by the Noticees.

CONSIDERATION OF ISSUES AND FINDINGS

10. I have carefully perused the written and oral submissions of the

Noticees and the documents available on record. The issues that

arise for consideration in the present case are :


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a) Whether Noticee No. 1 to 7 have violated the provisions of

Regulation 4(1), 4(2) (a) and (g) of PFUTP Regulations, 2003?

b) Whether Noticee No. 8 to 10 have vio lated the provis ions of

the Regulation 4(1), 4(2) (a), (b),(e) and (g) of PFUTP

Regulations, 2003?

c) Whether Noticee No. 11 to 12 have vio lated provis ions of

Regulation 4(1)(2)(e)of PFUTP Regulations , 2003?

d) Does the violation, if any, on the part of the Noticees attract

any penalty under section 15HA of the SEBI Act, 1992?

e) If yes, what should be the quantum of penalty?

11. The relevant regulations of PFUTP Regulations, 2003 are stated as

under:

PFUTP Regulations, 2003

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

security;


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(f) …….

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

or without intention of change of ownership of such security;

12. I find that the Noticees dealt significantly in the scrip of HSSL

through ASB, sub broker of SVS. All the Noticees were introduced

for trading by Mr. Yogesh R Doshi (Noticee No. 10) and Mr. Ballabh

Dagri, Directors of ASB. Noticee No. 10 besides being Director and

introducer has also traded in the scrip of HSSL.

13. The relevant period was divided into three phases: phase 1 from

November 03, 2009 to November 19, 2009, phase 2 from November

20, 2009 to February 18, 2010 and phase 3 from February 19, 2010

to March 31, 2010.

14. At BSE, during phase 1, the price of the scrip opened at ` 48.55 on

November 03, 2009 and closed at ` 76.3 on November 19, 2009 i.e.

an increase of 57.15% within a span of 17 days. During phase 2, theprice of the scrip opened at ` 75 on November 20, 2009 and closed

at ` 76.4 on February 18, 2010. Further, during phase 3, the price of

the scrip opened at ` 77.5 on February 19, 2010 and closed at `

100.05 on March 31, 2010 i.e. an increase of 29.09% within a span

of 41 days.

15. At NSE during phase 1 the price of the scrip opened at ` 51.9 on

November 03, 2009 and closed at ` 76.15 on November 19, 2009

i.e. an increase of 46.72% within a span of 17 days. During phase 2

the price of the scrip opened at ` 75 on November 20, 2009 and

closed at ` 76.35 on February 18, 2010. During the phase 3 the

price of the scrip opened at ` 74.4 on February 19, 2010 and closed


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at ` 108.95 on March 31, 2010 i.e. an increase of 46.43% within a

span of 41 days.

16. It was alleged that two trading members namely SVS and Pune E

Stock Broking Pvt. Ltd.( hereinafter referred to as ‘PSB’) contributed

significantly in the buy and sell side of the transaction at BSE in the

scrip of HSSL. The combined contribution of the two trading

members in the buy side was 5,36,223 shares accounting for

68.55% of the total volume traded during the relevant period. The

combined contribution of the two trading members in the sell side

was 4,68,538 shares accounting for 59.90% of the total volume

traded during the relevant period.

17. At NSE, the contribution of SVS in the buy side was 3,69,974 shares

accounting for 76.92% of the total volume traded during the relevant

period. The contribution of SVS in the sell side was 3,48,143 shares

accounting for 72.38% of the total volume traded during the relevant

period.

18. The Noticees belong to 3 families viz. Thakkar, Mehta & Doshi

families. All the 3 families reside in Ghatkopar area and traded

through the common sub broker ASB. Also the directors of the ASB,

Noticee No. 10 and Mr. Ballabh Dagri had introduced the Noticees

to the broker SVS. Further, Noticee No. 10 Director of ASB had also

traded in the scrip in the relevant period besides being the

introducer of all the remaining Noticees. The relationship among the

Noticees is given below:


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S.No. Noticee Address of the Entity Introducer

detail

Relationship

with others

1 Priya Dhaval

Thakkar (PDT)

2nd Floor Nand

Ashish,r.b.mehata

Marg,ghatkopar(east),Mumbai, Maharashtra,

India, 400077

Yogesh R

Doshi

Priya Dhaval

Thakkar is the

wife of DhavalArjun Thakkar

2 Mahesh

Dhanvantrai

Mehta (MDM)

A-3, Janak Kutir, Plot

No 92, Vallabhbaug

Lane, Ghatkopar (east),Mumbai, Maharashtra,

India, 400077

Yogesh R

Doshi

Brother of Nikunj

and son of

Madhukanta

3 Nikunj

Dhanvantrai

Mehta (NDM)


No 92, Vallabhbaug

Lane, Ghatkopar (east),Mumbai, Maharashtra,

India, 400077

Yogesh R

Doshi

Brother of

Mahesh and son

of Madhukanta

4 Amita Nitesh

Thakkar (ANT)

1101 Kailash

Palace,upashraya

Lane,ghatkopar(east),Mumbai, Maharashtra,

India, 400077

Yogesh R

Doshi

Nitesh Arjun

Thakkar is the

husband of Amita Nitesh Thakkar.

Fenil Nitesh

Thakkar is the sonof Amita

Thakkar.

5 Fenil NiteshThakkar (FNT) 1101 KailashPalace,upashraya

Lane,ghatkopar(east),

Mumbai, Maharashtra,India, 400077

Ballabh Bagri As explainedabove

6 Nitesh ArjunThakkar Huf

(NTH)

1101 KailashPalace,upashraya

Lane,ghatkopar(east),

Mumbai, Maharashtra,

India, 400077

Yogesh RDoshi

As explainedabove

7 Madhukanta

DhanvantraiMehta (MD)


No 92, VallabhbaugLane, Ghatkopar (east),


India, 400077

Yogesh R

Doshi

Mother of Nikunj

DhanvantraiMehta and

Mahesh

DhanvantraiMehta

8 Nitesh Arjun

Thakkar (NAT)

6,nilkanth,jethabhai

Lane,rajawadi.ghatkopar

(e), Mumbai,

Maharashtra, India,

Yogesh R

Doshi

Nitesh Arjun

Thakkar is the

husband of Amita

Nitesh Thakkar,


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19. Noticee Nos. 1, 4, 5, 6, 8, 9 are from the same family. Further,

except Noticee No. 5 all other members of Thakkar family were

introduced to the broker SVS by Noticee No. 10, who was director of

ABSCPL. Noticee Nos. 10, 11 and 12 are from the same family.

Noticee Nos. 2, 3 and 7 are from the same family.

Trading at BSE

20. By dealing on behalf of the Noticees, ASB at BSE, purchased

320591 shares and sold 2,95,315 shares which constitutes 41% of

the total buy and 36% of the total sale volume in the scrip during the

400077 father of Fenil Nitesh Thakkar

and brother of

Dhava ArjunThakkar.

9 Dhaval ArjunThakkar (DAT)

2nd Floor NandAshish,r.b.mehataMarg,ghatkopar(east),

Mumbai, Maharashtra,India, 400077

Yogesh RDoshi

DhavalArjunThakkar isthe husband of

Priya ArjunThakkar and

brother of Nitesh

Thakkar

10 Yogeshkumar

Rasiklal Doshi

(YRD)

4,anand Kutir,,cama

Lane,,hansoti

Lane,ghatkopar(w),


India, 400086

Sanjay Shah Director of

Aquarian Share

Broking Co.Ltd. ,

sub-broker and

commonintroducer of

other Noticees

11 Darshana Yogesh

Doshi(DYD)

4,anand Kutir,,cama

Lane,,hansotiLane,ghatkopar(w),


India, 400086

Yogesh R

Doshi

Wife of Yogesh R

Doshi and motherof Mitali Yogesh

Doshi

12 Mitali YogeshDoshi (MYD)

4,anand Kutir,,camaLane,,hansoti

Lane,ghatkopar(w),Mumbai, Maharashtra,India, 400086

Yogesh RDoshi

As explainedabove


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relevant period. Further, details of purchase and sale by the

Noticees is as follows:

Client

Name

Total

buy

% of

total

volume

traded

buy

within

the

Noticees

%

traded

within

the

Noticees

Total

sale

% of

total

volume

traded

sale

within

the

Noticees

%

traded

within

the

Noticees

Noticee

No.1 54736 7.00 52333 95.61 75900 9.70 71226 93.84

Noticee

No. 2 21985 2.81 20695 94.13 7900 1.01 7900 100.00

Noticee

No. 3 45997 5.88 44398 96.52 6500 0.83 6500 100.00

Noticee

No. 4 50472 6.45 48350 95.80 38918 4.98 36156 92.90

Noticee

No. 5

10035

1.28

10000

99.65

10200

1.30

10000

98.04

Noticee

No. 6 15503 1.98 14040 90.56 22505 2.88 22505 100.00

Noticee

No. 7 1036 0.13 550 53.09 20000 2.56 20000 100.00

Noticee

No. 8 31217 3.99 22181 71.05 42981 5.49 38201 88.88

Noticee

No. 9 26139 3.34 18856 72.14 19341 2.47 17864 92.36

Noticee

No.10 50567 6.46 10784 21.33 32257 4.12 14463 44.84

Noticee

No. 11

8017

1.02

0.00

0.00

1950

0.25

1000

51.28

Noticee

No, 12 4887 0.62 0.00 0.00 3444 0.44 2454 71.25

Total 320591 40.98 242187 75.54 281896

36.03 248269 88.07

21. From the above table, it is observed that 242187 shares (75.54%)

constituted the total buy of the group and 281896 shares (88.07%)

of the total sale of the group were executed among the Noticees.

Out of the 110 trades entered into by the major clients for 69 tradesaccounting for 1,82,747 shares (23.36% of the total volume traded)

the buy and sell orders were placed within time difference of less

than 1 minute. Further, there were 46 cross trades i.e. where the

buy and sell orders were executed by the same broker among the

Noticees which accounted for 1,20,091 shares during 20 days


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(15.35% of the total volume traded). The buy and sell orders were

placed in perfectly synchronized manner i.e. the quantity, price and

time were exactly the same.

22. On the 20 days during the relevant period i.e. November 04, 2009,

November 19, 2009, November 20, 2009. November 23, 2009,

December 15, 2009, December 21, 2009, December 29, 2009,

January 07, 2010, January 08, 2010, January 12, 2010, January 13,

2010, January 14, 2010, January 18, 2010, February 26, 2010,

March 09, 2010, March 10, 2010, March 11, 2010, March 15, 2010,

March 17, 2010 and March 18, 2010 when the Noticees entered into

synchronized trades among themselves, the percentage of thegroup volume contribution to the volume traded of the day was upto

74%. The volume traded during the 20 trading days contributed by

the Noticees by entering into synchronized trading was 36.26%.

Moreover, 1,18,194 shares were traded among the Thakkar family

alone.

23. During the relevant period, SVS through sub-broker ASB dealing on

behalf of 71 clients purchased 3,84,823 shares (49.20% of the total

market volume) and sold 3,17,138 shares (40.54% of the total

market volume) respectively. Further, it was also observed that SVS

dealing for the aforesaid 71 clients executed 268 cross deals

contributing 2,78,836 shares, accounting for 35.64% of the total

market volume during the period. Further, for 118 out of 268 cross

deals contributing total volume of 1,82,991 shares accounting for

23.39% of the total volume traded during the period, the buy and sell

orders were placed within time difference of less than or equal to

one minute only. Out of the 118 cross deals mentioned above 61

cross deals contributing 1,22,864 shares accounting for 15.70% of

the total volume traded during the relevant period, the buy and sell


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orders were placed in synchronized manner wherein the order time,

quantity and price were matched.

24. During the first phase of relevant period the price of the scrip

opened at ` 48.55 and touched a high of ` 81.65, i.e. there was

increase of ` 33.10 which is about 68.1% of the price rise. It was

observed that on 13 trading days and on 22 occasions a new high

price was discovered. Further, out of 22 occasions, on 20 occasions

(on 10 out of 13 trading days), Noticees contributed to an increase

of ` 29.85 (out of ` 33.10) which is about 61.48% of the price rise.

Only on 2 occasions Noticees were counterparties contributing to a

price rise of ` 4.80. There was no significant change in the economic

fundamental of the scrip of HSSL during the relevant period

justifying the price rise.

25. The dealings of the Noticees which influenced price of the scrip are

as follows:

Major

SVS

Client

No of

trades

above

LTP Influence

on price

No of

trades

below

LTP Influence

on price Net

impact

No of

1st

trades influence

on price

No

of

NDP Influence

on price

Noticee

No. 8 2 6.35 1 ‐0.05 6.3

0 0 0 0

Noticee

No. 10 15 22.05 9 ‐12.65 9.4 2 6.35 7 10.95

Noticee

No.11 11 10.3 5 ‐7.55 2.75 2 5.65 2 3.85

Noticee

No. 12 7 16.3

0 0

16.3 1 2 3 7.65

Grand

Total 35 55 15 ‐20.25 34.75 5 14 12 22.45

26. From the above table, it is observed that Noticee No. 10, 11 and 12

mainly influenced the price rise of the scrip at BSE during the first

phase of relevant period by placing buy orders at a price above LTP

thereby creating artificial volume and price hike. Noticees increased

the price by ` 92.3(resulted out of 29 cross deals cum synchronized


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trades) at BSE in the aforesaid manner. Noticees have created

artificial demand for the scrip of HSSL by placing buy orders

successively at higher rates than the LTP which scrip was available

at lower prices.

Trading at NSE

27. By dealing on behalf of Noticees, ASB purchased 3,03,056 shares

and sold 3,23,200 shares at NSE which constituted 63% of the total

buy and 67.19% of the total sell volume. The details of purchase and

sale by the Noticees dealing through SVS are as follows:

ClientName

TotalBuy

% ofthe

totalvolume

Within

theNoticees

%trading

withinNoticees

Totalsale

% ofthe

totalvolume

salewithin

theNoticees

%trading

withinNoticees

NoticeeNo.1 75728 15.74 71700 94.68 53564 11.14 50406 94.10

NoticeeNo. 2 25215 5.24 24547 97.35 37100 7.71 35758 96.38

NoticeeNo. 3 1203 0.25 343 28.51 36500 7.59 36000 98.63

NoticeeNo. 4 23529 4.89 22361 95.04 34489 7.17 32750 94.96

NoticeeNo. 5 10165 2.11 10000 98.38 10000 2.08 10000 100.00

Noticee

No. 6 23102 4.80 23102 100.00 15800 3.28 15800 100.00NoticeeNo. 7 45964 9.56 43600 94.86 22800 4.74 22800 100.00

NoticeeNo. 8 34509 7.17 31942 92.56 16495 3.43 13956 84.61

NoticeeNo. 9 31950 6.64 20086 62.87 34945 7.26 25599 73.26

NoticeeNo. 10 28724 5.97 17828 62.07 48730 10.13 32625 66.95

NoticeeNo. 11 675 0.14 0.00 0.00 8992 1.87 6976 77.58

NoticeeNo. 12 2292 0.48 0.00 0.00 3785 0.79 3065 80.98

Total 303056 63 265509 87.6 323200 67.19 285735 88.4

28. From the above table, it is observed that 265509 shares (87.6%)

constituted the total buy of the group and 285735 shares (88.4%) of

the total sale of the group were executed among the Noticees. Out


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of the 282 trades entered into by the major clients, for 134 trades

accounting for 2,31,142 shares (48.05% of the total volume) the buy

and sell orders were placed within time difference of less than 1

minute. Further, for 76 cross deals among the entities accounting for

1,89,549 shares resulting out of 76 buy orders and 76 sell orders

during 27 days (39.40% of the total volume) the buy and sell orders

were placed in a synchronized manner wherein the order time,

quantity and price were matched.

29. On the 27 days during the relevant period i.e. November 04, 2009,

November 05, 2009, November 06, 2009, November 16, 2009,



December 02, 2009, December 15, 2009, December 22, 2009,

December 29, 2009, January 06, 2010, January 11, 2010, January

13, 2010, January 15, 2010, January 18, 2010, February 03, 2010,

February 04, 2010, February 26, 2010, March 10, 2010, March 11,

2010, March 15, 2010, March 18, 2010, March 19, 2010 when the

Noticees entered into synchronized trades among themselves,

percentage of the group volume contribution to the total volume

traded of the day was upto 100% on some days. The volume traded

during the 27 trading days contributed by the Noticees by entering

into synchronized trading was as high as 57.49%. Moreover, 44,062

shares were traded among the Thakkar family during the relevant

period.

30. During the relevant period, SVS through sub-broker ASB dealing on

behalf of 58 clients purchased 3,69,974 shares (76.92% of the total

market volume) and sold 3,48,143 shares (72.38% of the total

market volume) respectively. Further, it was also observed that SVS

dealing for the aforesaid 58 clients executed 622 cross deals


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contributing 3,17,253 shares, accounting for 65.95% of the total

market volume during the period. Further, for 202 out of 622 cross

deals contributing total volume of 2,41,715 shares accounting for

50.25% of the total volume traded during the period, the buy and

sale orders were placed within time difference of less than or equal

to one minute only. Out of the 202 cross deals, for 98 cross deals

contributing 1,94,405 shares accounting for 40.41% of the total

volume traded during the relevant period, the buy and sale orders

were placed in perfectly synchronized manner wherein the order

time quantity and price were matched.

31. During the first phase of relevant period the price of the scripopened at ` 51.90 and touched a high of ` 83.25, i.e. there was

increase of ` 31.35 constituting 60.4% of the price rise. On 13

trading days and 20 occasions a new high price was discovered. On

all the 20 occasions (on 12 days out of 13 trading days), Noticees

contributed to an increase of ` 31.35 (out of ` 31.35) i.e. 100% of

the price rise.

32. The analysis of the tables given as trade log and order log reveals

the following about the trades in HSSL shares conducted through

sub broker ASB of broker SVS:

a. Trades of Priya Dhaval Thakkar (PDT) – Noticee 1

It is observed that at 10:00:19 on 21.12.2009, Priya Dhaval

Thakkar (PDT) put in a buy order at BSE for 10,000 shares

of HSSL @ ` 68.45. At 10:01:13 on 21.12.2009, PDT put in

another buy order for 4,000 shares of HSSL @ ` 68.45. At

10:01:25, her husband, Dhaval Arjun Thakkar (DAT) placed

a sell order for 14,000 HSSL shares @ ` 68.45 which was

matched and executed at 10:01:26 for 10,000 shares. The

time gap between purchase and sale order was 00:01:06


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and 00:00:12 respectively and can be considered as

synchronized. Further, this was a cross trade in the office of

ASB. The overall order quantity and price was matching

between the related buying and selling entities.

It is also observed that at 10:27:28 on 21.12.2009, PDT

placed a buy order at BSE for 4,800 shares @ ` 68.45. At

10:27:29, her husband’s brother, Nitesh Arjun Thakkar

(NAT) entered a buy order for 4800 HSSL shares @ ` 68.45.

The said orders matched with each other and were executed

for 4800 shares. It was a synchronized trade as the time gap

between purchase and sale order was 2 seconds. The order

quantity and price was matching between the buying and

selling entities and it was a cross trade.

b. Trades of Mahesh Dhanvantrai Mehta-MDM-Noticee-2

It is observed that at 09:14:26 on 07.01.2010, Dhaval Arjun

Thakkar placed a buy order at BSE for 7,900 shares @

` 71.70. At 09:14:27, MDM entered a sell order for 7900

shares @ ` 71.70. The said orders matched with each other

and were executed for 7,900 shares at 09:14:27. It was a

synchronized trade as the time gap between purchase and

sale order was 1 second. The order quantity and price was

matching between the buying and selling entities and it was

a cross trade.

c. Trades of Nikunj Dhanvantrai Mehta-NDM-Noticee-3

It is observed that at 09:19:10 on January 12, 2010, PDT

placed a sell order at BSE for 25,000 shares @ ` 84.5. The

last traded price was ` 80.5. At 09:19:11 on January 12,


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2010, NDM placed a matching buy order at BSE for 25,000

shares @ ` 84.5. It was a synchronized trade as the time gap

between purchase and sale order was 1 second. The order

quantity and price was matching between the buying and

selling entities and it was a cross trade.

It is observed that at 09:15:31 on January 13, 2010, NAT

placed a buy order at BSE for 6,500 shares @ ` 73.05. At

09:15:32 on January 13, 2010, NDM placed a matching sell

order at BSE for 6500 shares @ ` 73.05. . It was a


sale order was 1 second. The order quantity and price was


a cross trade.

d. Trades of Amita Nitesh Thakkar –ANT-Noticee No. 4

It is observed that at 10:20:17 on December 21, 2009, ANT

placed a buy order at BSE of 4,000 shares @ ` 69. The last

traded price was ` 68.5. At 10:20:19 on December 21,

2009, NAT placed a matching sell order of 4,000 shares @

` 69. It was a synchronized trade as the time gap betweenpurchase and sale order was 1second. The order quantity

and price was matching between the buying and selling

entities and it was a cross trade.

e. Trades of Fenil Nitesh Thakkar-FNT-Noticee No.5

Further, FNT at 10:10:16 on December 29, 2009 placed a

sell order of 10,000 shares at BSE@ ` 71.95. At 10:10:21

on December 29, 2009, ANT placed a matching buy order of

10,000 shares @ ` 71.95. It was a synchronized trade as

the time gap between purchase and sale order was 5

seconds. The order quantity and price was matching

between the buying and selling entities and it was a cross

trade.


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f. Trades of Nitesh Arjun Thakkar (HUF)-NTH-Noticee No.6

It is observed that at 14:25:47 on March 18, 2010, NTH

placed a buy order of 3,000 shares at BSE @ ` 105.95. The

last traded price was ` 104.05. At 14:25:48 on March 18,

2010, NAT placed a matching order @ ` 105.95. NAT is a

director of NTH. It was a synchronized trade as the time gap

between purchase and sale order was 10 seconds. The

order quantity and price was matching between the buying

and selling entities and it was a cross trade.

g. Trades of Madhukanta Dhanvantrai Mehta –MDM-

Noticee No. 7

It is observed that at 10:05:53 on December 29, 2009, FNT

placed a buy order of 10,000 shares at BSE @ ` 68. At

10:05:57 on December 29, 2009, MDM placed a sell order of

20,000 shares @ ` 68. It is observed that within a time gap

of 4 seconds the order for 10,000 shares were synchronized.

h. Trades of Nitesh Arjun Thakkar –NAT-Noticee No. 8

It is observed that at 10:41:16 on November 19, 2009,

Darshana Yogesh Doshi (DYD) placed a sell order of 250

shares at BSE @ ` 81.35. The last traded price was

` 80.95. At 10:41:20 November 19, 2009, NAT placed a

matching buy order of 250 shares @ ` 81.35. It was a


sale order was 4 seconds. The order quantity and price was


a cross trade.

It is observed that at 10:20:17 on December 21, 2009 ANT

placed a buy order at BSE of 4,000 shares @ ` 69. At

10:20:19 on December 21, 2009, NAT placed a matching

sell order of 4,000 shares @ ` 69. It was a synchronized


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trade as the time gap between purchase and sale order was

2 seconds. The order quantity and price was matching


trade.

i. Trades of Dhaval Arjun Thakkar-DAT-Noticee No.9

It is observed that at 14:58:04 on November 05, 2009, a sell

order was placed at NSE by MYD for 500 shares@ ` 57. At

14:58:13 on November 05, 2009, a matching buy order of

500 shares @ ` 57 was placed by DAT. The LTP was `

51.75. It was a synchronized trade as the time gap between

purchase and sale order was 9 seconds. The order quantity



It is observed that at 11:18:52 on November 16, 2009, a sell

order was placed at NSE by YRD for 1225 shares @ ` 72.4.

At 11:19:02 on November 16, 2009, a matching buy order

was placed by DAT @ ` 72.4. The LTP was ` 69. It was a

synchronized trade as the time gap between purchase andsale order was 9 seconds. The order quantity and price was


a cross trade.

It is observed that at 09:01:32 on February 26, 2010, YRD

placed a buy order of 2,500 shares @ ` 80.55. At 09:01:35

on February 26, 2010 a matching sell order of 2,500 shares

@ ` 80.55 was placed by DAT. It was a synchronized trade

as the time gap between purchase and sale order was 3

seconds. The order quantity and price was matching


trade.


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It is observed that at 09:14:26 on January 07, 2010, DAT

placed buy order at BSE of 7,900 shares @ ` 71.7. At

09:14:27 on January 07, 2010 a matching sell order 7,900

shares @ ` 71.7 was placed by MDM. It was a synchronized


1 second. The order quantity and price was matching


trade.

j. Trades of Yogesh Rasik lal Doshi-YRD-Noticee No. 10

It is observed that at 11:04:17 on December 15, 2009, DAT

placed a sell order at BSE of 1164 shares @ ` 73. At

11:04:23 on December 15, 2009, YRD placed a buy order

of 1164 shares @ ` 73. The Last Traded Price was ` 72. It

was a synchronized trade as the time gap between purchase

and sale order was 6 seconds. The order quantity and price

was matching between the buying and selling entities and it

was a cross trade.

It is observed that at 11:37:16 on November 23, 2009, YRD

placed a sell order at BSE of 100 shares @ ` 78.95. At

11:37:20 on November 23, 2009, NAT placed a matching

buy order of 100 shares @ ` 78.95. The Last Traded

Price was ` 76.5. It was a synchronized trade as the time

gap between purchase and sale order was 4 seconds. The



It is observed that at 13:22:33 on November 19, 2009, YRD

placed a sell order at NSE of 500 shares @ ` 83.15. At

13:22:39 NAT placed a buy order of 500 shares @ ` 83.15.

It was a synchronized trade as the time gap between

purchase and sale order was 6 seconds. The order quantity


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k. Trades of Darshana Yogesh Doshi-DYD-Noticee No. 11

It is observed that at 10:41:04 on November 19, 2009, DYD



buy order of 250 shares @ ` 80.95. The LTP was ` 75. It




was a cross trade.

It is observed that at 10:10:22 on November 19, 2009, DYD

placed a sell order at NSE of 300 shares @ ` 82.95. At


buy order of 300 shares @ ` 82.95. It was a synchronized


5 seconds. The order quantity and price was matching

between the buying and selling entities and it was a crosstrade.

l. Trades of Mitali Yogesh Doshi-MYD-Noticee No. 12

It is observed that at 13:01:58 on March 15, 2010, MYD


13:02:01 on March 15, 2010, NAT placed a matching buy

order of 100 shares @ ` 107.2. The LTP was ` 103.55. It




was a cross trade.


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It is observed that at 14:58:46 on November 05, 2009, MYD

placed a sell order at NSE of 500 shares @ ` 57. At 14:58:52

on November 05, 2009, NAT placed a matching buy order of

500 shares @ ` 57. It was a synchronized trade as the time

gap between purchase and sale order was 6 seconds. The



33. It is observed that 70 clients traded at BSE and 58 clients traded at

NSE. Out of 70 clients and 58 clients at BSE and NSE respectively,

the trades of 12 clients i.e. Noticees were synchronized in terms of

order, time, quantity and price.

34. I find that Noticee No. 1-6 contributed significantly to creation of

artificial volume by indulging in synchronized trades amongst

themselves at both BSE and NSE. Noticee No. 1-6 bought 1,30,806

shares at BSE. There were a total of 15 instances of cross deals

which were almost perfectly synchronized in terms of quantity, time

and price amongst the members of the group. Following are theaforementioned instances:

Trade

Date

Client Name

LTP Diff

CP Client Name

Buy Ord

Time

sale Ord

Time

time

Diff

buy

Ord

Price

sale

Ord

Price

price

diff

buy

ord

Qty

sale

ord

qty

q

d

23‐Nov‐09

AMITA

NITESH

THAKKAR 75.80 0.00

YOGESHKUMAR

RASIKLAL

DOSHI 15:49:16 15:49:10 0:00:06 75.8 75.8 0 37 37

21‐Dec‐09

AMITA

NITESH

THAKKAR 68.45 0.05 NITESH

ARJUN

THAKKAR 10:01:46 10:02:15 0:00:28 68.45 68.5 0.05 20000 20000

21‐Dec‐09

AMITA

NITESH

THAKKAR 68.50 0.00

NITESH ARJUN

THAKKAR 10:02:31 10:02:36 0:00:05 68.5 68.5 0 4000 4000

21‐Dec‐09

AMITA

NITESH

THAKKAR 68.50 0.50

NITESH ARJUN

THAKKAR 10:20:17 10:20:19 0:00:01 69 69 0 4000 4000

21‐Dec‐09

PRIYA

DHAWAL 69.00

‐

0.55

NITESH ARJUN

THAKKAR 10:27:28 10:27:29 0:00:02 68.45 68.45 0 4800 4800


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35. Similarly Noticee No. 1-6 sold 1,19,039 shares at BSE . There were

a total of 13 instances of cross deals which were almost perfectly

synchronized in terms of quantity, time and price amongst the

members of the group. Following are the aforementioned instances:

Trade

Date

Client Name

LTP Diff

CP Client

Name Buy Ord

Time

sale Ord

Time

time

Diff

buy

Ord

Price

sale

Ord

Price

price

diff

buy

ord

Qty

sale

ord

qty

qty

diff

21‐

Dec‐

09

NITESH ARJUN

THAKKAR 74.95

‐

0.05

PRIYA

DHAWAL

THAKKAR 11:08:58 11:08:53 0:00:05 74.9 74.9 0 4000 4000 0

29‐

Dec‐

09

AMITA NITESH

THAKKAR 68.00 3.95

NITESH ARJUN

THAKKAR HUF 10:10:01 10:09:47 0:00:14 71.95 71.95 0 10000 10000 0

29‐

Dec‐

09

AMITA NITESH

THAKKAR 71.95 0.00

FENIL NITESH

THAKKAR 10:10:21 10:10:16 0:00:05 71.95 71.95 0 10000 10000 0

31‐

Dec‐

09

PRIYA

DHAWAL

THAKKAR 74.00 0.50

AMITA NITESH

THAKKAR 10:05:50 9:55:06 0:10:45 74.5 77 2.5 20000 20000 0

7‐ DHAWAL 72.05 ‐ MAHESH 9:14:26 9:14:27 0:00:01 71.7 71.7 0 7900 7900 0

THAKKAR

29‐Dec‐09

AMITA

NITESH

THAKKAR 68.00 3.95

NITESH ARJUN

THAKKAR HUF 10:10:01 10:09:47 0:00:14 71.95 71.95 0 10000 10000

29‐Dec‐09

AMITA

NITESH

THAKKAR 71.95 0.00

FENIL NITESH

THAKKAR 10:10:21 10:10:16 0:00:05 71.95 71.95 0 10000 10000

31‐Dec‐09

PRIYA

DHAWAL

THAKKAR 74.00 0.50

AMITA NITESH

THAKKAR 10:05:50 9:55:06 0:10:45 74.5 77 2.5 20000 20000

8‐Jan‐10

PRIYA

DHAWAL

THAKKAR 77.90

‐

2.20

AMITA NITESH

THAKKAR 13:49:38 13:49:47 0:00:09 75.7 75.7 0 11708 11708

12‐Jan‐10

NIKUNJ

DHANVANTR

AI MEHTA 80.50 4.00

PRIYA DHAWAL

THAKKAR 9:19:11 9:19:10 0:00:01 84.5 84.5 0 25000 25000

12‐Jan‐10

NIKUNJ

DHANVANTR

AI MEHTA 84.50 0.00

PRIYA DHAWAL

THAKKAR 9:19:40 9:19:40 0:00:01 84.5 84.5 0 18000 18000

3‐Feb‐10

PRIYA

DHAWAL

THAKKAR 79.00 2.00

YOGESHKUMAR

RASIKLAL

DOSHI 10:19:35 12:17:15 1:57:40 76.75 81 4.25 250 250

9‐Mar‐10

AMITA

NITESH

THAKKAR 105.75 0.00

YOGESHKUMAR

RASIKLAL

DOSHI 13:38:24 13:38:20 0:00:04 105.75 105.75 0 2 2

11‐Mar‐10

PRIYA

DHAWAL

THAKKAR 106.00 1.90

MITALI YOGESH

DOSHI 13:50:19 13:50:12 0:00:07 107.9 107.9 0 9 9

18‐Mar‐10

NITESH

ARJUN

THAKKAR

HUF 104.05

‐

1.00

NITESH ARJUN

THAKKAR 14:24:48 14:24:58 0:00:10 103.05 103.05 0 3000 3000


29/54


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Jan‐

10

ARJUN

THAKKAR

0.35 DHANVANTRAI

MEHTA

8‐

Jan‐

10

PRIYA

DHAWAL

THAKKAR 77.90

‐

2.20

AMITA NITESH

THAKKAR 13:49:38 13:49:47 0:00:09 75.7 75.7 0 11708 11708 0

12‐

Jan‐

10

NIKUNJ

DHANVANTRAI

MEHTA

80.50

4.00

PRIYA

DHAWAL

THAKKAR

9:19:11

9:19:10

0:00:01

84.5

84.5

0

25000

25000

0

12‐

Jan‐

10

NIKUNJ

DHANVANTRAI

MEHTA 84.50 0.00

PRIYA

DHAWAL

THAKKAR 9:19:40 9:19:40 0:00:01 84.5 84.5 0 18000 18000 0

13‐

Jan‐

10

NITESH ARJUN

THAKKAR 77.55

‐

4.50

NIKUNJ

DHANVANTRAI

MEHTA 9:15:31 9:15:32 0:00:01 73.05 73.05 0 6500 6500 0

14‐

Jan‐

10

YOGESHKUMAR

RASIKLAL

DOSHI 74.10 0.90

PRIYA

DHAWAL

THAKKAR 9:05:40 9:05:44 0:00:03 75 75 0 250 250 0

18‐

Jan‐

10

YOGESHKUMAR

RASIKLAL

DOSHI 85.35

‐

7.90

AMITA NITESH

THAKKAR 11:00:46 11:00:51 0:00:05 77.45 77.45 0 2500 2500 0

18‐

Mar‐

10

NITESH ARJUN

THAKKAR 103.05 2.90

NITESH ARJUN

THAKKAR HUF 14:25:48 14:25:47 0:00:01 105.95 105.95 0 3000 3000 0

25‐

Mar‐

10

DHAWAL

ARJUN

THAKKAR 105.00

‐

0.80

PRIYA

DHAWAL

THAKKAR 10:41:23 10:18:27 0:22:57 104.2 104.2 0 181 181 0

36. At NSE, Noticee No. 1-6 bought 97,222 shares. There were a total

of 26 instances of cross deals which were almost perfectly


members of the group. Some of the instances are mentioned below:

Trade

Date

Client

Name

LTP Diff

CP Client

Name Buy Ord

Time

sale Ord

Time

time

Diff

buy

Ord

Price

sale

Ord

Price

price

diff

buy

ord

Qty

sale

ord

qty

qty

diff

29‐Dec‐09

NITESH

A.THAKKAR 67.05 1.10

MADHUKANTA

DHANVANTRAI

MEHTA 10:06:39 10:06:53 0:00:14 68.15 68.15 0.00 2800 2800 0

29‐Dec‐09

PRIYA

DHAVAL

THAKKAR 68.15 2.80

NITESH

A.THAKKAR 10:08:54 10:08:46 0:00:08 70.95 70.95 0.00 12800 12800 0

29‐Dec‐09

PRIYA

DHAVAL

THAKKAR 70.95 0.00

FENIL NITESH

THAKKAR 10:09:26 10:09:20 0:00:06 70.95 70.95 0.00 10000 10000 0

6‐Jan‐10

PRIYA

DHAVAL

THAKKAR 72.00

‐

0.30

MAHESH

DHANVANTRAI

MEHTA 10:54:08 10:54:15 0:00:07 71.70 71.70 0.00 10000 10000 0

6‐Jan‐10

PRIYA

DHAVAL

THAKKAR 71.70 0.00

MAHESH

DHANVANTRAI

MEHTA 10:54:08 10:55:10 0:01:02 71.70 71.70 0.00 10000 10000 0

6‐Jan‐10 PRIYA 71.70 0.00 MAHESH 10:55:05 10:55:10 0:00:05 71.70 71.70 0.00 10000 10000 0


30/54


Page 30 of 54 July 31, 2015

37. At NSE, Noticee No. 1-6 sold 1,50,677 shares. There were a total of

25 instances of cross deals which were almost perfectly



DHAVAL

THAKKAR

DHANVANTRAI

MEHTA

6‐Jan‐10

PRIYA

DHAVAL

THAKKAR 71.70 0.00

MAHESH

DHANVANTRAI

MEHTA 10:55:41 10:55:46 0:00:05 71.70 71.70 0.00 4000 4000 0

6‐Jan

‐10

AMITA

NITESH

THAKKAR

71.70

0.00

MAHESH

DHANVANTRAI

MEHTA

10:56:30

10:56:34

0:00:04

71.70

71.70

0.00

2500

2500

0

6‐Jan‐10

AMITA

NITESH

THAKKAR 71.70 0.00

MAHESH

DHANVANTRAI

MEHTA 10:56:30 10:57:28 0:00:58 71.70 71.70 0.00 4 4 0

6‐Jan‐10

AMITA

NITESH

THAKKAR 71.70 0.00

MAHESH

DHANVANTRAI

MEHTA 10:58:32 10:58:36 0:00:04 71.70 71.70 0.00 2500 2500 0

6‐Jan‐10

AMITA

NITESH

THAKKAR 71.70 0.00

MAHESH

DHANVANTRAI

MEHTA 10:59:12 10:59:16 0:00:04 71.70 71.70 0.00 1500 1500 0

Trade

Date

Client Name

LTP Diff

CP Client

Name Buy Ord

Time

sale Ord

Time

time

Diff

buy

Ord

Price

sale

Ord

Price

price

diff

buy

ord

Qty

sale

ord

qty

qty

diff

22‐Dec‐

09

MADHUKANTA

DHANVANTRAI

MEHTA 72.55 4.40

AMITA NITESH

THAKKAR 14:35:45 14:35:43 0:00:02 76.95 76.95 0.00 28000 28000 0

22‐Dec‐

09

MADHUKANTA

DHANVANTRAI

MEHTA 76.95 0.00

PRIYA DHAVAL

THAKKAR 14:36:13 14:36:12 0:00:01 76.95 76.95 0.00 14800 14800 0

29‐Dec‐

09

PRIYA

DHAVAL

THAKKAR 68.15 2.80

NITESH

A.THAKKAR 10:08:54 10:08:46 0:00:08 70.95 70.95 0.00 12800 12800 0

29‐Dec‐

09

PRIYA

DHAVAL

THAKKAR 70.95 0.00

FENIL NITESH

THAKKAR 10:09:26 10:09:20 0:00:06 70.95 70.95 0.00 10000 10000 0

6‐Jan‐

10

PRIYA DHAVAL

THAKKAR 72.00

‐

0.30

MAHESH

DHANVANTRAI

MEHTA 10:54:08 10:54:15 0:00:07 71.70 71.70 0.00 10000 10000 0

6‐

Jan‐

10 PRIYA

DHAVAL

THAKKAR 71.70 0.00

MAHESH

DHANVANTRAI

MEHTA 10:54:08 10:55:10 0:01:02 71.70 71.70 0.00 10000 10000 0

6‐Jan‐

10

PRIYA DHAVAL

THAKKAR 71.70 0.00

MAHESH

DHANVANTRAI

MEHTA 10:55:05 10:55:10 0:00:05 71.70 71.70 0.00 10000 10000 0

6‐Jan‐

10

PRIYA DHAVAL

THAKKAR 71.70 0.00

MAHESH

DHANVANTRAI

MEHTA 10:55:41 10:55:46 0:00:05 71.70 71.70 0.00 4000 4000 0

6‐Jan‐

10

AMITA NITESH

THAKKAR 71.70 0.00

MAHESH

DHANVANTRAI 10:56:30 10:56:34 71.70 71.70 0.00 2500 2500 0


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Page 31 of 54 July 31, 2015

38. From the above, it can be seen that substantial volume of trades

were synchronized by Noticee No. 1-6 both at BSE and NSE.

Hence, Noticee No. 1-6 created artificial volume in the scrip of

HSSL.

39. I find that at NSE, on December 22, 2009, Noticee No. 7 bought a

total of 42,800 shares which were almost perfectly synchronized in

terms of quantity, time and price amongst the members of the group.

Hence, Noticee No. 7 created artificial volume in the scrip of HSSL.

40. I find that Noticee No. 8 and 9 contributed significantly to creation of

artificial volume by indulging in synchronized trades within the group

at both NSE and BSE. At NSE, Noticee No. 8 and 9 bought 38,126

shares. There were a total of 50 instances of cross deals which

were almost perfectly synchronized in terms of quantity, time and

price amongst the members of the group. Some of the instances are

mentioned below:

MEHTA

6‐Jan‐

10

AMITA NITESH

THAKKAR 71.70 0.00

MAHESH

DHANVANTRAI

MEHTA 10:56:30 10:57:28 71.70 71.70 0.00 4 4 0

6‐Jan‐

10

AMITA NITESH

THAKKAR 71.70 0.00

MAHESH

DHANVANTRAI

MEHTA 10:58:32 10:58:36 71.70 71.70 0.00 2500 2500 0

6‐Jan‐

10

AMITA NITESH

THAKKAR 71.70 0.00

MAHESH

DHANVANTRAI

MEHTA 10:59:12 10:59:16 71.70 71.70 0.00 1500 1500 0

Trade Date Client

Name

LTP

Diff

CP Client

Name Buy Ord

Time

sale Ord

Time

time

Diff

buy

Ord

Price

sale

Ord

Price

price

diff

buy

ord

Qty

sale

ord

qty

qty

diff

5‐Nov‐09

DHAVAL

A.

THAKKAR 51.75 5.25

MITALI Y.

DOSHI 14:58:13 14:58:04 0:00:09 57.00 57.00 0.00 500 500 0

5‐Nov‐09

NITESH

A.

THAKKAR 57.00 0.00

MITALI Y.

DOSHI 14:58:52 14:58:46 0:00:06 57.00 57.00 0.00 500 500 0

5‐Nov‐09

NITESH

A.

THAKKAR 57.00 0.00

MITALI Y.

DOSHI 15:19:25 15:17:30 0:01:55 57.00 57.00 0.00 250 250 0


32/54


Page 32 of 54 July 31, 2015

41. At NSE, Noticee No. 8 and 9 sold 20,590 shares. There were a

total of 19 instances cross deals which were almost perfectly



6‐Nov‐09

NITESH

A.

THAKKAR 57.00 2.00

YOGESH

RATILAL

DOSHI 10:18:33 10:18:21 0:00:12 59.00 59.00 0.00 1000 1000 0

6‐Nov‐09

NITESH

A.

THAKKAR 54.15 5.60

YOGESH

RATILAL

DOSHI 10:48:58 10:48:49 0:00:09 59.75 59.75 0.00 250 250 0

16‐Nov‐09

DHAVAL

A.

THAKKAR 69.00 3.40

YOGESH

RATILAL

DOSHI 11:19:02 11:18:52 0:00:10 72.40 72.40 0.00 1225 1225 0

16‐Nov‐09

DHAVAL

A.

THAKKAR 71.50 0.45

YOGESH

RATILAL

DOSHI 12:28:45 9:57:44 2:31:01 71.95 71.95 0.00 500 500 0

16‐Nov‐09

DHAVAL

A.

THAKKAR 71.95 0.00

YOGESH

RATILAL

DOSHI 12:49:12 12:49:06 0:00:06 71.95 71.95 0.00 55 55 0

17‐Nov‐09

DHAVAL

A.

THAKKAR 75.55

‐

0.05

YOGESH

RATILAL

DOSHI 13:38:50 13:30:37 0:08:13 75.50 75.50 0.00 105 105 0

17‐Nov‐09

DHAVAL

A.

THAKKAR 75.50 0.00

YOGESH

RATILAL

DOSHI 13:39:22 13:39:18 0:00:04 75.50 75.50 0.00 100 100 0

18‐Nov‐09

DHAVAL

A.

THAKKAR 79.30 0.00

YOGESH

RATILAL

DOSHI 13:49:24 13:49:19 0:00:05 79.30 79.30 0.00 335 335 0

18‐Nov‐09

DHAVAL

A.

THAKKAR 79.30 0.00

YOGESH

RATILAL

DOSHI 13:49:57 13:49:51 0:00:06 79.30 79.30 0.00 15 15 0

18‐Nov‐09

DHAVAL

A.

THAKKAR 79.30 0.00

YOGESH

RATILAL

DOSHI 13:55:19 13:55:15 0:00:04 79.30 79.30 0.00 200 200 0

19‐Nov‐09

NITESH

A.

THAKKAR 79.30 3.65

DARSHANA

YOGESH

DOSHI 10:07:29 10:07:23 0:00:06 82.95 82.95 0.00 150 150 0

19‐Nov‐09

NITESH

A. THAKKAR 82.95 0.00

DARSHANA

YOGESH DOSHI 10:10:27 10:10:22 0:00:05 82.95 82.95 0.00 300 300 0

19‐Nov‐09

NITESH

A.

THAKKAR 83.25

‐

0.10

DARSHANA

YOGESH

DOSHI 12:56:57 9:56:05 3:00:52 83.15 83.15 0.00 1000 1000 0

19‐Nov‐09

NITESH

A.

THAKKAR 83.15 0.00

DARSHANA

YOGESH

DOSHI 12:58:00 12:57:44 0:00:16 83.15 83.15 0.00 221 221 0

19‐Nov‐09

NITESH

A.

THAKKAR 83.15 0.00

YOGESH

RATILAL

DOSHI 13:21:36 12:59:18 0:22:18 83.15 83.15 0.00 1000 1000 0

19‐Nov‐09

NITESH

A.

THAKKAR 83.15 0.00

YOGESH

RATILAL

DOSHI 13:22:39 13:22:33 0:00:06 83.15 83.15 0.00 500 500 0


33/54


Page 33 of 54 July 31, 2015

42. From the above, it can be seen that substantial volume of trades

were synchronized by Noticee No. 8 and 9 during the relevant

period both at BSE and NSE. Hence, Noticee No. 8 and 9 created

artificial volume in the scrip of HSSL.

43. Noticee No. 8 and 9 also influenced the price of the scrip during the

first phase of investigation by placing buy orders at price more than

LTP and set new high prices both at BSE and NSE. Some of the

instances of influencing the price at BSE are mentioned below:

Trade Date Client

Name

LTP Diff

CP Client

Name

Buy Ord

Time

sale Ord

Time

time

Diff

buy

Ord

Price

sale

Ord

Price

price

diff

buy

ord

Qty

sale

ord

qty

qty

diff

11‐Jan‐10

PRIYA

DHAVAL THAKKAR 77.50 ‐8.15

DHAVAL

A. THAKKAR 9:12:21 9:12:21 0:00:00 69.35 69.35 0.00 7900 7900 0

13‐Jan‐10

YOGESH

RATILAL

DOSHI 76.80

‐

0.10

DHAVAL

A.

THAKKAR 13:06:56 13:07:11 0:00:15 76.70 76.70 0.00 1473 1473 0

18‐Jan‐10

YOGESH

RATILAL

DOSHI 79.40 0.60

DHAVAL

A.

THAKKAR 12:18:27 12:18:38 0:00:11 80.00 80.00 0.00 27 27 0

18‐Jan‐10

YOGESH

RATILAL

DOSHI 81.70

‐

1.55

NITESH

A.

THAKKAR 14:38:21 12:27:21 2:11:00 80.15 80.15 0.00 500 500 0

26‐Feb‐10

YOGESH

RATILAL

DOSHI 81.05

‐

0.25

NITESH

A.

THAKKAR 9:05:13 9:05:17 0:00:04 80.80 80.80 0.00 790 790 0

26‐Feb‐10

YOGESH

RATILAL

DOSHI 81.50

‐

0.25

NITESH

A.

THAKKAR 9:05:13 9:06:10 0:00:57 81.25 81.25 0.00 500 500 0

26‐Feb‐10

YOGESH

RATILAL

DOSHI 81.25 0.30

DHAVAL

A.

THAKKAR 9:05:13 9:08:02 0:02:49 81.55 81.55 0.00 900 900 0

26‐Feb‐10

YOGESH

RATILAL

DOSHI 84.80 ‐

3.25

DHAVAL

A.

THAKKAR 9:09:07 9:09:12 0:00:05 81.55 81.55 0.00 350 350 0


34/54


Page 34 of 54 July 31, 2015

Trade Date Client

Name

LTP Diff

CP Client Name

Buy Ord

Time

sale Ord

Time

time

Diff

buy

Ord

Price

sale

Ord

Price

price

diff

buy

ord

Qty

sale

ord

qty

qty

diff

19‐Nov‐09

NITESH

ARJUN

THAKKAR 75.00 5.95

DARSHANA

YOGESH DOSHI 10:40:10 10:40:04 0:00:07 80.95 80.95 0 250 250 0

19‐Nov‐09

NITESH

ARJUN

THAKKAR 80.95 0.40

DARSHANA

YOGESH DOSHI 10:41:20 10:41:16 0:00:04 81.35 81.35 0 250 250 0

20‐Nov

‐09

NITESH

ARJUN

THAKKAR

75.00

4.95

YOGESHKUMAR

RASIKLAL

DOSHI

10:06:51

10:06:45

0:00:06

79.95

79.95

0

250

250

0

20‐Nov‐09

NITESH

ARJUN

THAKKAR 79.00 0.95

YOGESHKUMAR

RASIKLAL

DOSHI 10:30:12 10:30:05 0:00:07 79.95 79.95 0 200 200 0

20‐Nov‐09

NITESH

ARJUN

THAKKAR 76.05 3.70

YOGESHKUMAR

RASIKLAL

DOSHI 14:48:50 14:48:42 0:00:08 79.8 79.75 0.05 50 50 0

23‐Nov‐09

NITESH

ARJUN

THAKKAR 76.05 2.90

YOGESHKUMAR

RASIKLAL

DOSHI 11:37:20 11:37:16 0:00:04 78.95 78.95 0 100 100 0

23‐Nov‐09

NITESH

ARJUN

THAKKAR 76.00 1.45

YOGESHKUMAR

RASIKLAL

DOSHI 12:38:49 12:38:45 0:00:04 77.45 77.45 0 100 100 0

23‐Nov‐09

NITESH

ARJUN

THAKKAR 75.80 1.65

YOGESHKUMAR

RASIKLAL

DOSHI 12:39:09 12:39:05 0:00:04 77.45 77.45 0 50 50 0

9‐Mar‐10

DHAWAL

ARJUN

THAKKAR 103.55 1.25

YOGESHKUMAR

RASIKLAL

DOSHI 15:05:37 15:05:33 0:00:04 104.85 104.8 0.05 50 50 0

9‐Mar‐10

DHAWAL

ARJUN

THAKKAR 103.55 1.25

YOGESHKUMAR

RASIKLAL

DOSHI 15:18:46 15:18:43 0:00:03 104.85 104.8 0.05 50 50 0


35/54


Page 35 of 54 July 31, 2015

9‐Mar‐10

DHAWAL

ARJUN

THAKKAR 103.55 1.25

YOGESHKUMAR

RASIKLAL

DOSHI 15:26:33 15:26:30 0:00:03 104.85 104.8 0.05 100 100 0

10‐Mar‐10

NITESH

ARJUN

THAKKAR 100.25 5.60

YOGESHKUMAR

RASIKLAL

DOSHI 9:40:32 9:40:28 0:00:04 105.85 105.85 0 100 100 0

10‐Mar‐10

NITESH

ARJUN

THAKKAR 100.25 5.55

YOGESHKUMAR

RASIKLAL

DOSHI 10:47:10 10:47:08 0:00:03 105.85 105.8 0.05 50 50 0

10‐Mar‐10

NITESH

ARJUN

THAKKAR 100.35 5.45

YOGESHKUMAR

RASIKLAL

DOSHI 11:06:18 11:06:12 0:00:06 105.8 105.8 0 100 100 0

11‐Mar‐10

DHAWAL

ARJUN

THAKKAR 100.25 8.40

YOGESHKUMAR

RASIKLAL

DOSHI 9:32:29 9:32:21 0:00:08 108.65 108.65 0 100 100 0

11‐Mar‐10

DHAWAL

ARJUN

THAKKAR 102.45 4.85

YOGESHKUMAR

RASIKLAL

DOSHI 10:57:40 10:57:35 0:00:05 107.3 107.3 0 50 50 0

11‐

Mar‐

10

DHAWAL

ARJUN

THAKKAR

102.45

4.80

YOGESHKUMAR

RASIKLAL

DOSHI

11:26:10

11:26:07

0:00:03

107.3

107.25

0.05

5

5

0

44. Some of the instances of influencing the price at NSE are mentioned

below:

Trade Date Client

Name

LTP Diff

CP Client

Name

Buy Ord

Time

sale Ord

Time

time

Diff

buy

Ord

Price

sale

Ord

Price

price

diff

buy

ord

Qty

sale

ord

qty

qty

diff

5‐Nov‐09

DHAVAL

A.

THAKKAR 51.75 5.25

MITALI Y.

DOSHI 14:58:13 14:58:04 0:00:09 57.00 57.00 0.00 500 500 0


36/54


Page 36 of 54 July 31, 2015

6‐Nov‐09

NITESH

A.

THAKKAR 57.00 2.00

YOGESH

RATILAL

DOSHI 10:18:33 10:18:21 0:00:12 59.00 59.00 0.00 1000 1000 0

6‐Nov‐09

NITESH

A.

THAKKAR 54.15 5.60

YOGESH

RATILAL

DOSHI 10:48:58 10:48:49 0:00:09 59.75 59.75 0.00 250 250 0

16‐Nov‐09

DHAVAL

A.

THAKKAR 69.00 3.40

YOGESH

RATILAL

DOSHI 11:19:02 11:18:52 0:00:10 72.40 72.40 0.00 1225 1225 0

16‐Nov‐09

DHAVAL

A.

THAKKAR 71.50 0.45

YOGESH

RATILAL

DOSHI 12:28:45 9:57:44 2:31:01 71.95 71.95 0.00 500 500 0

19‐Nov‐09

NITESH

A.

THAKKAR 79.30 3.65

DARSHANA

YOGESH

DOSHI 10:07:29 10:07:23 0:00:06 82.95 82.95 0.00 150 150 0

45. It is evident from the instances mentioned in the table that Noticee

No. 8 and 9 mainly influenced the price of the scrip at BSE and NSE

during the first phase of relevant period by placing buy orders at a

price above LTP. On perusal of both the above tables, it is seen that

on a number of instances the aforesaid Noticees have placed buy

orders at a new high price than the LTP when shares were available

at lower prices and changed the course of the prices.

46. At NSE, Noticee No. 10 bought 13,666 shares. There were a total of

14 instances of cross deals which were almost perfectly


37/54


Page 37 of 54 July 31, 2015



Trade

Date

Client

Name

LTP Diff

CP Client

Name

Buy Ord

Time

sale Ord

Time

time

Diff

buy

Ord

Price

sale

Ord

Price

price

diff

buy

ord

Qty

sale

ord

qty

qty

diff

13‐Jan‐10

YOGESH

RATILAL

DOSHI 76.80

‐

0.10

DHAVAL A.

THAKKAR 13:06:56 13:07:11 0:00:15 76.70 76.70 0.00 1473 1473 0

13‐Jan‐10

YOGESH

RATILAL

DOSHI 76.65 0.05

PRIYA

DHAVAL

THAKKAR 15:28:43 15:28:54 0:00:11 76.70 76.70 0.00 3250 3250 0

15‐Jan‐10

YOGESH

RATILAL

DOSHI 76.30 0.45

AMITA

NITESH

THAKKAR 9:37:11 9:37:19 0:00:08 76.75 76.75 0.00 2500 2500 0

15‐Jan‐10

YOGESH

RATILAL

DOSHI 77.05

‐

0.25

PRIYA

DHAVAL

THAKKAR 9:37:39 9:37:46 0:00:07 76.80 76.80 0.00 2500 2500 0

47. At NSE, Noticee No. 10 sold 21,895 shares. There were a total of 38

instances cross deals which were almost perfectly synchronized in

terms of quantity, time and price amongst the members of the group.

Some of the instances are mentioned below:

Trade Date Client Name

LTP Diff

CP Client

Name Buy Ord

Time

sale Ord

Time

time

Diff

buy

Ord

Price

sale

Ord

Price

price

diff

buy

ord

Qty

sale

ord

qty

qty

diff

4‐Nov‐09

YOGESH R.

DOSHI

(HUF) 51.90 2.55

YOGESH

RATILAL

DOSHI 14:00:28 14:00:19 0:00:09 54.45 54.45 0.00 50 50 0

6‐Nov‐09

NITESH A.

THAKKAR 57.00 2.00

YOGESH

RATILAL

DOSHI 10:18:33 10:18:21 0:00:12 59.00 59.00 0.00 1000 1000 0

6‐Nov‐09

NITESH A.

THAKKAR 54.15 5.60

YOGESH RATILAL

DOSHI 10:48:58 10:48:49 0:00:09 59.75 59.75 0.00 250 250 0

6‐Nov‐09

SHRUTI

SANJEEV

SHAH 59.85

‐

0.05

YOGESH

RATILAL

DOSHI 12:21:12 12:21:07 0:00:05 59.80 59.80 0.00 900 900 0

16‐Nov‐09

DHAVAL A.

THAKKAR 69.00 3.40

YOGESH

RATILAL

DOSHI 11:19:02 11:18:52 0:00:10 72.40 72.40 0.00 1225 1225 0

16‐Nov‐09 DHAVAL A. 71.50 0.45 YOGESH 12:28:45 9:57:44 2:31:01 71.95 71.95 0.00 500 500 0


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Page 38 of 54 July 31, 2015

THAKKAR RATILAL

DOSHI

16‐Nov‐09

DHAVAL A.

THAKKAR 71.95 0.00

YOGESH

RATILAL

DOSHI 12:49:12 12:49:06 0:00:06 71.95 71.95 0.00 55 55 0

17‐Nov

‐09

DHAVAL A.

THAKKAR

75.55

‐

0.05

YOGESH

RATILAL

DOSHI

13:38:50

13:30:37

0:08:13

75.50

75.50

0.00

105

105

0

17‐Nov‐09

DHAVAL A.

THAKKAR 75.50 0.00

YOGESH

RATILAL

DOSHI 13:39:22 13:39:18 0:00:04 75.50 75.50 0.00 100 100 0

18‐Nov‐09

DHAVAL A.

THAKKAR 79.30 0.00

YOGESH

RATILAL

DOSHI 13:49:24 13:49:19 0:00:05 79.30 79.30 0.00 335 335 0

18‐Nov‐09

DHAVAL A.

THAKKAR 79.30 0.00

YOGESH

RATILAL

DOSHI 13:49:57 13:49:51 0:00:06 79.30 79.30 0.00 15 15 0

18‐Nov‐09

DHAVAL A.

THAKKAR 79.30 0.00

YOGESH

RATILAL

DOSHI 13:55:19 13:55:15 0:00:04 79.30 79.30 0.00 200 200 0

19‐Nov‐09

NITESH A.

THAKKAR 83.15 0.00

YO

Documents

Adjudication order in the matter of Harita Seating Systems Ltd