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Page 1 of 191
WTM/GA/17/IVD/6/07
BEFORE THE SECURITIES AND EXCHANGE BOARD OF INDIA
CORAM: G. ANANTHARAMAN, WHOLE TIME MEMBER
ORDER
UNDER REGULATION 13(4) OF SECURITIES AND EXCHANGE BOARD OF
INDIA (PROCEDURE FOR HOLDING ENQUIRY BY ENQUIRY OFFICER AND
IMPOSING PENALTY) REGULATIONS, 2002 AGAINST KARVY STOCK
BROKING LTD, DEPOSITORY PARTICIPANT AND MEMBER, NATIONAL
STOCK EXCHANGE OF INDIA LTD, BOMBAY STOCK EXCHANGE LTD.
AND HYDERABAD STOCK EXCHANGE LIMITED AND KARVY
COMPUTERSHARE PRIVATE LIMITED, REGISTRAR TO THE ISSUE IN
RESPECT OF DEALINGS IN THE INITIAL PUBLIC OFFERINGS.
Date of Final Hearing: May 29, 2007.
Appearances:
For noticees: Shri Shyam Mehta, Advocate.
Shri Vinay Chauhan, Advocate
Shri C. Parthasarathy, Director of the noticee
For Securities and Exchange Board of India: Shri. Sanjiv Dutt, Chief General Manager,
Shri B J Dilip, Assistant General Manager
Shri Vijayakrishnan. G, Assistant Legal Advisor.
Page 2 of 191
1.0. Background:
1.1.In October 2005, the stock exchanges submitted their preliminary observations on the
Initial Public Offering (IPO) of Yes Bank Ltd. (YBL) which hinted at the possibility
of large scale off-market transactions immediately following the date of allotment and
prior to the listing on the stock exchanges. SEBI therefore carried out a preliminary
scrutiny by calling for data from the depositories and the Registrar to the Issue (RTI).
SEBI found that, many demat accounts in fictitious/ benami names were opened by
certain entities (hereinafter referred to as the “Key Operators”) and these entities had
cornered/ acquired the IPO shares, by making applications in fictitious/ benami names
with each of the applications being of small value so as to make it eligible for
allotment under the retail category. The aforesaid demat accounts are hereinafter
referred to as “afferent accounts” for the sake of brevity. The investigation conducted
by SEBI further revealed that subsequent to the allotment of IPO shares, the
fictitious/benami allottees had transferred the said shares to their principals which
were identified by SEBI as key operators / master account holders. The modus
operandi as detailed above led to the prima facie view that the thousands of entities in
whose names demat accounts and bank accounts had been opened and IPO
applications made, were either benami, name lenders or non existent.
1.2.On noticing the irregularities and widespread abuse, SEBI acted against the entities
who were responsible for the irregularities by passing interim order dated December
15, 2005 restraining them from participating in all future IPOs and also directing the
depositories to effectively freeze their dematerialized accounts.
1.3. It was noticed during the course of preliminary scrutiny of Yes Bank IPO, that all the
dematerialized accounts in fictitious / benami names had been opened with the DP
Karvy Stockbroking Ltd. (“Karvy DP”). Therefore, in the said interim order dated
December 15, 2005 it was mentioned that “Also, the role of Karvy-DP i.e. Karvy
Stockbroking Ltd. that opened the dematerialized accounts of 6315 entities being
Page 3 of 191
benamis of Roopalben Panchal and 1315 entities being benamis of Sugandh probably
without taking adequate steps to ascertain the genuineness of these entities while
acting as a facilitator in what appears to be an act of either gross negligence or active
collusion ill behoves them as a SEBI registered market participant.”
1.4.In view of the prima facie finding as above, vide the interim order dated December
15, 2005 in the matter of Yes Bank IPO, the following direction was issued by SEBI
against Karvy DP:
“NSDL is directed to undertake a comprehensive inspection of Karvy-DP particularly
focusing on the sytems and procedures, if any, put in place by Karvy-DP for
implementing the ‘know your client’ norms that DPs are required to follow. NSDL
shall identify the deficiencies in Karvy-DP with regard to the above and also ascertain
from Karvy-DP the particulars of other potential benami accounts more particularly
those multiple accounts having the same contact address and / or having the same
person / entity authorized to operate these dematerialized accounts. Karvy-DP is
directed to fully co-operate with NSDL in the above inspection. NSDL shall submit a
report to SEBI detailing the findings of its inspection in a time-bound programme.”
1.5.Thereafter, SEBI examined the dealings in another major IPO of IDFC wherein the
very same players were suspected to have played a major role in cornering the shares.
SEBI issued ad interim orders in the case of IDFC also along the similar lines as done
in the case of Yes Bank. In the interim order dated January 12, 2006 in the case of
IDFC IPO, SEBI inter alia observed as below:
“11.16. Further the reports of inspection of Karvy-DP submitted to SEBI by NSDL
and CDSL shows that ‘Know your client’ norms have not been adhered at all while
opening the dematerialized accounts.
11.17. Further, Karvy’s internal e-mail correspondences given as Annexure to the
NSDL inspection report show that even during November 2005 the top management
of Karvy-DP were aware of the issue of multiple dematerialized accounts opened
Page 4 of 191
with the same address. It appears that the management of Karvy-DP, on coming to
know of the same in the wake of a query from SEBI in some other case had, as early
as November 2005, internally decided to process these multiple dematerialized
accounts bearing the same address for closure. The above goes to confirm that
Karvy-DP had knowledge about the fictitious nature of such multiple accounts.
11.18. Also, some of the documents collected by CDSL during the course of
inspection show that Karvy-DP has obtained letters purported issued by the
concerned banks such as Bharat Overseas Bank as proof of identity and proof of
address of the person for the purpose of opening dematerialized accounts. It is seen
that one branch manager has on the same date signed as authorized signatory of
different branches of the bank. This raises a doubt as to the authenticity of the bank
documents obtained by Karvy-DP for opening dematerialized accounts. SEBI is
making reference to RBI regarding such apparent irregularities in the bank documents
submitted to Karvy-DP for the purpose of opening the dematerialized accounts.
11.19. It is also noted that in view of significant irregularities noticed during the
course of inspection of Karvy-DP, both NSDL and CDSL have directed Karvy-DP
not to open new dematerialized accounts till the issue of verifying the genuineness of
multiple dematerialized account-holders having the same address is addressed to the
satisfaction of the depositories.
11.20. The above facts cast grave doubts as to the genuineness of the thousands of
IPO applicants who have apparently furnished the address of Roopalben Panchal or
Sugandh or Purshottam Budhwani as their address. The findings of the
investigation/Inspection of the concerned banks by RBI has fortified the initial
findings of SEBI that Karvy-DP has actively colluded with the above entities in
opening multiple/benami bank accounts and dematerialized accounts in the names of
fictitious persons.”
1.6.In view of the findings as above, SEBI in the interim order dated January 12, 2006 in
the matter of IDFC IPO, inter alia, issued the following directions against Karvy DP:
Page 5 of 191
“12.5. Thousands of dematerialized accounts being opened on the same day with
the same branch and being introduced by the same bank should have alerted the
DPs at the time of opening of the dematerialized accounts. However the fact that
DPs failed to exercise even this basic due diligence gives rise to a suspicion that
they have actively colluded with the perpetrators. It is a matter of serious
concern that Karvy-DP has opened such apparently benami / fictitious accounts
working out to over 95% (42,056 nos) of the multiple dematerialized accounts in
relation to IDFC IPO. I note that Karvy-DP has already been directed by the
depositories to verify the genuineness of the dematerialized account-holders and to
close those dematerialized accounts where it is unable to verify the genuineness of
identity and address of the dematerialized account-holders. The depositories have
prohibited Karvy-DP from opening new dematerialized accounts till the above
process has been completed. I hereby direct Karvy-DP and Pratik-DP to complete the
process of verifying the identity and address of dematerialized account-holders and to
close / freeze the dematerialized accounts where they are unable to do the verification
not later than January 31, 2006. Further, Karvy-DP and Pratik-DP shall put in place
systems and procedures to ensure that in future no non-genuine dematerialized
accounts are opened by them. Karvy-DP and Pratik-DP shall submit a detailed report
to SEBI narrating the actions taken by them in this regard and also give an
undertaking that the SEBI’s above directions have been fully complied with. I further
direct that Karvy-DP and Pratik-DP shall not open new dematerialized accounts till
the submission of above report and undertaking to SEBI and obtaining a no-objection
from SEBI for accepting fresh business as a DP.”
1.7.Further, in view of the findings of preliminary scrutiny as above, SEBI referred the
matter to other government agencies including Income Tax Department, Ministry of
Company Affairs and the Reserve Bank of India. Also, SEBI filed a complaint with
CBI in the matter.
1.8.Pursuant to the same, RBI conducted inspections of the banks involved. The
inspection by RBI brought out various irregularities at the end of the banks involved,
Page 6 of 191
specifically BhOB and also the role of Karvy group behind the enire gamut of
operations.
1.9.Further, the parliamentary Standing Committee on Finance conducted a study on
“Efficacy of Reform Process in the Capital Market – Recent IPO Scam”.
1.10. For the purpose of the study / examination of the matter, the committee took oral
and written testimonies / evidences of SEBI and RBI, the representatives of Investors’
Grievances Forum, Indian Overseas Bank, Vijaya Bank, ICICI Bank, HDFC Bank
and Bharat Overseas Bank, National Stock Exchange, Bombay Stock Exchange,
National Securities Depository Ltd., and Central Depository Services Ltd. Purusuant
to the study, the committee submitted its report before the parliament on November
28, 2006.
1.11. The major observations of the committee with regard to the role of Karvy group
in the IPO irregularities was as follows:
“… ..The fact that Karvy RTI had made consolidated refund favouring BhOB in
respect of thousands of IPO applicants and that the Karvy Group was directing the
investment of funds in respect of IPO applications are real eye openers. The
Committee also note that Karvy had very conveniently issued an idea paper to
BhOB certifying that the applications received for the IPO offer were valid, which
shows the extent to which Karvy could prevail upon the Bank. They feel that the
discreet arrangement for mutual benefit of BhOB and Karvy would have gone
further ahead had there been no unearthing of the IPO scam.
61. The Committee are convinced that the role of Karvy Group of Companies in
the IPO Scam was questionable right from the beginning. … ..”
In view of the above, the committee advised SEBI to conduct investigation in all
Page 7 of 191
areas of manipulation allegedly done by the Karvy Group. The committee further
observed that
“62. … … … As a major part of the malfunctioning leading to the scam could
be attributed to the role of the intermediary, the Karvy Group of Companies
which performed multiple functions in all directions, the Committee feel that
the role of such intermediaries should be examined minutely with a view to
see that those operating in multiple capacity are not able to manipulate the
system… … ”
1.12. Besides the above, the committee, in various parts of the report has made many
adverse observations regarding the role of Karvy group companies in the IPO
irregularities.
1.13. Further, SEBI also received references from various Government Agencies
including Reserve Bank of India (‘RBI’), Serious Fraud Investigation Office (‘SFIO’)
and Intelligence Bureau (‘IB’). Various investor complaints were also received
alleging irregularities in various IPOs.
1.14. In the course of investigations pursuant to interim orders in the cases of Yes Bank
and IDFC IPOs, SEBI noticed that some of these multiple accounts were opened in
June 2003. The involvement of these accounts in Initial Public Offerings prior to that
of Yes Bank and IDFC were looked into. Securities and Exchange Board of India
(hereinafter referred to as SEBI) conducted an investigation into the buying, selling or
dealing in the shares issued through Initial Public Offerings (IPOs) of companies
during the period 2003-2005. The investigation conducted by SEBI found that the
modus operandi, as detailed above, had been adopted for cornering of IPO shares in
21 IPOs that came during 2003-2005.
1.15. The investigations prima facie revealed the substantial involvement of Karvy
Page 8 of 191
group companies in the IPO irregularities. It was found that Karvy-DP had, during
2003, tied up with BhOB for the purpose of provding IPO finance to their demat
account clients. Based on introduction of saving account by Karvy, BHOB disbursed
the loan amount to the clients of Karvy DP. However, with passage of time, it appears
that Bharat Overseas Bank officials chose to rely more on Karvy’s DP account details
and drew comfort therefrom while dropping their guard in the matter of opening bank
accounts and verification thereof. Exploiting the blind trust and complacency on the
part of BhOB, Karvy gave short shrift to the KYC procedures. Thus in the year 2005
when market for IPOs was booming, Karvy-DP did not comply with the account
opening formalities by opening multiple demat accounts in fictitious / benami names.
Thereafter, in order to make its account opening procedure seemingly compliant,
Karvy-DP resorted to fabrication of bank documents towards POI and POA and also
arranged for photographs from other sources. The perfect matching of the fabricated
bank documents with the details available in the depository system gave rise to the
possibility that the bank documents might have been forged by the DP itself. Thus, it
appeared that Karvy, being the progenitor of the entire scheme won over the trust of
the allies in the bank and made its pitch effectively in the market, besides making
common cause with the sub brokers and financiers who were part of the manipulative
assemblage. Other Karvy group entities namely Karvy Consultants Ltd. and Karvy
Computershare P Ltd. (“Karvy RTI”) were also found to have played their part by
providing / arranging IPO finance and providing consolidated refund cheques in
respect of the afferent accounts and directing the bank to credit the refunds in the
accounts of the key operators.
1.16. In the above facts and circumstances, SEBI vide an ad interim ex parte interim
order dated April 27, 2006 inter alia directed as below:
“17.7. In view of the detailed findings against Karvy DP and Pratik DP in this order, Karvy DP and Pratik DP, in my view prima facie do not appear to be fit to deal in securities market as SEBI registered intermediaries. Appropriate quasi- judicial
Page 9 of 191
proceedings are being initiated against the two DPs. In view of the substantial findings of a serious nature brought out in this order against Karvy DP and Pratik DP, in addition to what has been noticed in the earlier two interim orders in the cases of Yes Bank and IDFC, I direct that Karvy DP and Pratik DP shall not carry on the activities as DP till the completion of enquiry and passing of final order, excepting for effecting transfer of BO account to another SEBI registered DP on request. Notwithstanding this direction, Karvy DP and Pratik DP shall continue to be governed by the SEBI (Depositories and Participants) Regulations, 1996 and other applicable legal provisions in other respects. 17.8. Since the other business groups of Karvy have appeared to have acted in concert in the gamut of the IPO manipulations, I further direct Karvy Stock Broking Ltd., Karvy Computershare Pvt. Ltd., Karvy Investor Services Ltd. and Karvy Consultants Ltd. not to undertake fresh business as a Registrar to Issue and Share transfer agent, excepting those businesses already contracted as on date.”
1.17. Subsequent to the issue of ex-parte interim directions as above, an opportunity of
post decisional hearing was granted to the Karvy group. After considering the oral
and written submissions of Karvy group, vide order dated May 26, 2006, the
following directions were issued:
“ (a) KSBL is directed not to act as a depository participant, pending enquiry and
passing of final orders, except for acting on the instructions of existing beneficial owners, so that the interests of existing BOs remain unaffected. It shall transfer the demat account of an existing BO to another SEBI registered DP, on request. It is clarified that KSBL shall continue to be governed by the SEBI (Depositories and Participants) Regulations, 1996 and other applicable legal provisions.
(b) KSBL, as a stock broker, is directed not to undertake any proprietary trades in securities, either off-market or on market, pending enquiry and passing of final orders.
(c) KCPL is directed not to act as a registrar to an issue and as a share transfer agent, pending enquiry and passing of final orders, except for the assignments already contracted before passing of interim order dated April 27, 2006. This direction will not apply to KCPL as Registrar and Transfer Agent to Mutual Funds. It is noted that Karvy Investor Services Ltd. and KCL are not registered as registrars to an issue or share transfer agents with SEBI.”
1.18. The DP filed an appeal before the Hon’ble Securities Appellate Tribunal
Page 10 of 191
(SAT) against the aforesaid order of SEBI dated May 26, 2006 and the same was
dismissed by SAT vide order dated January 8, 2007 with a direction to SEBI to
complete the enquiry not later than March 31, 2007. Further, SAT had directed SEBI
to take a final decision in accordance with law within two months thereafter. In the
said order SAT had inter alia observed “what needs to be examined is whether the
appellant had really failed to get alerted to the abuse of its systems by the so called
sub-brokers or whether there was active collusion of the appellant with its clients for
abusing the IPO process and sharing the gains arising from the same. We can not
decide these issues at this stage not can it be said as to which of these two versions is
correct. It is an undisputed fact that thousands of fictitious/ benami demat accounts
were opened with the appellant with common addresses and more than 10000
accounts were opened on one single day. The appellant was under a duty to check
and comply with the various norms. The obvious appears to have been overlooked. Is
the action of the appellant innocent is the question. The appellant is clearly under a
cloud and the truth can be known only after a detailed inquiry. The findings of the
inquiry will either remove the appellant or the cloud.” (emphasis supplied)
Thereafter, SAT, on an application filed by SEBI, extended the time limit upto the
end of June 2007.
2.0. APPOINTMENT OF ENQUIRY OFFICER
2.1 In the facts and circumstances, SEBI appointed an Enquiry Officer vide orders
dated May 25, 2006 and September 18, 2006 under regulation 5(1) of Securities
and Exchange Board of India (Procedure for Holding Enquiry by Enquiry Officer
and Imposing Penalty) Regulations, 2002 (hereinafter referred to as the Enquiry
Regulations) to enquire into the alleged violations committed by Karvy Stock
Broking Ltd. as a depository participant and stock broker and Karvy
Computershare Pvt. Ltd as a Registrar to the Issue while dealing in the IPOs. The
alleged violations committed by the said entities are as follows :
Page 11 of 191
a. Karvy Stock Broking Ltd. as a depository participant
i) Section 12A of Securities and Exchange Board of India Act, 1992 (hereinafter
referred to as the ‘Act’) ,
ii) Regulation 3 and 4 of Securities and Exchange Board of India (Prohibition of
Fraudulent and Unfair Trade Practices Relating to Securities Market)
Regulations, 2003 (hereinafter referred to as the FUTP Regulations)
iii) Regulations 19, 20A, 42, 43, 46 and 52 of Securities and Exchange Board of
India (Depositories and Participants) Regulations 1996 (hereinafter referred to
as DP Regulations) and
iv) Provisions of Securities and Exchange Board of India (Criteria for Fit and
Proper Persons) Regulations 2004 (hereinafter referred to as Fit and Proper
Regulations).
b. Karvy Stock Broking Ltd. as a Stock Broker
i) Regulation 3 and 4 of FUTP Regulations,
ii) Regulation 5, 7 and 15(1)(b) of Securities and Exchange Board of India (Stock
Brokers and Sub – Brokers) Regulations, 1992 (hereinafter referred to as
Broker Regulations),
iii) Provisions of the Fit and Proper Regulations and
iv) Provisions of Securities and Exchange Board of India (Disclosure and Investor
Protection) Guidelines, 2000 (hereinafter referred to as DIP Guidelines).
c. Karvy Computer Share Pvt. Ltd as a Registrar to the Issue
i) Section 12A of the Act,
ii) Regulation 3 and 4 of the FUTP Regulations,
Page 12 of 191
iii) Regulation 6 and 13 of Securities and Exchange Board of India (Registrars to
an Issue and Share Transfer Agents) Regulations, 1993 (hereinafter referred to
as RTI Regulations) and
iv) Provisions of Fit and Proper Regulations.
2.2 The Enquiry Officer submitted his reports dated March 30, 2007 (in the case of
DP), March 15, 2007 (in the case of stock broker) and December 20, 2006 (in the
case of RTI) and his recommendations in the respective enquiry reports are as
follows :
i. to prohibit KSBL from acting as a depository participant for a period
of 18 months.
ii. to suspend the certificate of registration of KSBL as a stock broker for
a period of 3 months.
iii. to prohibit KCPL from acting as a registrar to an issue for a period of
nine months.
The enquiry officer further clarified that the prohibition of 18 months
recommended by him against the DP was in respect of taking up new assignment /
fresh business as a depository participant. The Enquiry Officer also recommended
to take into account the period of prohibition already undergone by the DP and the
RTI, as per the interim orders of SEBI for the purpose of computing the period of
prohibition recommended by him.
2.3 The Enquiry Officer in his report (in the case of DP) had inter alia considered
various allegations leveled against the Karvy DP such as assisting the key
operators in opening bank accounts, opening of large number of afferent accounts
by the key operators, irregularities in opening the demat accounts, non
verification of documents pertaining to Proof Of Identity (POI), Proof of Address
(POA), fabrication of the documents, IPO funding to the key operators, financing
after the closure of the issue, single consolidated refund cheques etc. In so far as
the allegations pertaining to the fabrication of introduction letters, the Enquiry
Officer had observed that on the basis on the circumstantial evidence alone it
Page 13 of 191
could not be conclusively held that the DP had fabricated the said documents. The
Enquiry Officer had inter alia observed that the DP had actively facilitated,
assisted and abetted many key operators in cornering the shares by facilitating
opening of the accounts, facilitating the transfer of securities through pre printed
DIS etc. The Enquiry Officer observed that the other entities belonging to the
Karvy Group also played an important role in supplementing the action of DP and
found that the DP had violated the provisions of Section 12 A of the SEBI Act,
Regulation 3 and 4 of FUTP Regulation, 2003, Regulations 19, 42(2) and (3), 43,
46 and 52 of DP regulations 1996 and Clauses 3,9,12,16,19,20& 22 of the Code
of Conduct specified in regulation 20A of the DP regulations.
2.4 The Enquiry Officer in his report (in the case of stock broker) had inter alia
observed that the findings of the enquiry against KSBL as the depository
participant might be considered as a part of the said report as the same is
reflective on the various activities of KSBL as a stock broker. The Enquiry
Officer further found that the Broker has violated the provisions of regulation 3
and 4(1) of the FUTP Regulations and Clauses A(1), A(3) and A(4) of Schedule II
of the Broker Regulations and the provisions of DIP Guidelines.
2.5 The Enquiry Officer in his report dated December 20, 2006 (in the case of RTI)
found that KCPL had violated the provisions of section 12 A (a), (b), (c) of the
Act and Regulations 3 and 4 (1) of FUTP Regulations and clause 3 of the Code of
Conduct specified under regulation 13 of the RTI Regulations.
3.0. SHOW CAUSE NOTICES AND REPLIES
3.1. a) In the case of KSBL DP
While considering the Enquiry Report and other materials available on record
(which were considered while passing interim orders dated January 12, 2006,
April 27, 2006 and May 26, 2006 and also considered at the time of the hearing
Page 14 of 191
before the SAT), it was observed that the alleged violations committed by the DP
prima facie called for a higher penalty than that recommended by the Enquiry
Officer. Accordingly, a notice dated May 4, 2007 was issued to the DP to show
cause as to why the period of prohibition as recommended by the Enquiry Officer
should not be enhanced to 3 years.
3.2. The DP vide letter dated May 19, 2007 filed its reply to the said show cause
notice. The submissions made by the DP in its aforesaid reply in brief are as
follows:
i) The show cause notice was merely a formality to show the procedural fairness
as it has been categorically concluded that the prohibition of 18 months should
be enhanced to 3 years. The authority cannot consider any documents which
were not considered by the Enquiry Officer. The authority can not travel
beyond the Enquiry Report and what was considered therein.
a. On the basis of a rubber stamp on a sheet of paper containing 50
names and signatures, it cannot be said that the account holders
have been introduced by it to the bank.
b. It had effected off market transfers from various accounts based on
duly filled in Delivery Instructions Slips (DIS). In respect of the
allegation pertaining to the opening of demat accounts using
different combinations of surnames, the DP stated that the same
were opened after obtaining the application forms submitted by the
respective IPO sub brokers with documents relating to KYC
requirements.
c. There was a clear division of operations between the DP and the
other Karvy entities and that it had not acted in concert or aided
and abetted the key operators in opening benami / fictitious demat
accounts to corner shares in various IPOs as alleged. The DP stated
that it was impracticable to expect the application which were
Page 15 of 191
received and bid on the last day were deposited in the bank on the
same day itself by any syndicate / sub syndicate member.
d. It was not liable for any activities carried out by KCL other than
the DP activities of KCL. The DP further stated that it had opened
the demat accounts in the ordinary course of business after
complying with the KYC requirements. In respect of opening of
demat accounts earlier than the date of letter of introduction, the
DP submitted that the same happened only in 27 cases as there
were deficiencies in the original documents. The DP further
clarified that the said deficiencies were identified at the time of the
scrutiny and fresh set of documents were sought and the same were
received and attached alongwith the application form.
e. KCL had financed Shri Purshottam Budhwani and his clients and
the DP was aware that Shri Purshottam Budhwani and his clients
were applying for the shares in IPO. However, the DP claimed that
it was not aware that the said Shri Purshottam Budhwani was a key
operator and that he was abusing the IPO process by making
fictitious / benami applications. In respect of the issue of single
consolidated refund cheques, the DP submitted that the same was a
market practice.
f. The DP further stated “In retrospect it is realized that some of the
IPO sub brokers who are the alleged key operators have exploited
the loop holes in the system and have used Karvy DP as one of the
DPs amongst others for carrying out their manipulative designs.”
The DP further claimed that it had not printed any other details
apart from client id, serial number and name in the DIS. The DP
further contended that it had not appointed any franchisee and that
it had not delegated the activities of the DP to the sub brokers.
g. There was no electronic system to store and match the photographs
of the demat applicants. The DP asserted that there was nothing
wrong or illegal in the activation of demat accounts on the date of
Page 16 of 191
closure of issue. The DP also stated that it had not introduced the
key operators to open the bank accounts as alleged.
h. The DP denied violating the provisions of section 12A (a), (b) and
(c) of SEBI Act and Regulations 3, 4 (1) and 4 (2) of the FUTP
Regulations. It also denied of violating the provisions of DP
Regulations. In respect of the quantum of penalty the DP relied
upon the judgment of the Hon’ble Supreme Court in the matter of
Ex-Naik Sardar Singh V. Union of India (1991) 3 SCC 212.
Finally the DP has claimed that it had not committed any
violations as alleged.
3.3. In the case of Stock Broker
A show cause notice dated May 4, 2007 was also issued to the Broker asking it to
show cause as to why action as recommended by the Enquiry Officer should not
imposed against it.
The stock broker vide letter dated May 19, 2007 inter alia stated that simply because
its employees had introduced the accounts and put the address or stamp of the
company on the forms, it could not be concluded that the Broker was aware of the
activities of the employees. The Broker also denied that it had facilitated the key
operators to open many accounts as alleged. The Broker further stated that it had not
violated the provisions of the Broker Regulations or the FUTP Regulations. The
Broker denied that the Karvy group assisted the key operators in opening the bank
account with BhOB. Further the Broker had reiterated the reply of the DP dated May
19, 2007. The Broker inter alia submitted that their employees had not introduced
several bank accounts as alleged and added that the introduction of certain bank
accounts by the employees were after fulfilling the KYC requirements.
In respect of 50 additional names attached to 37 bank accounts of Smt. Roopalben
Panchal, the DP reiterated the stand taken by the DP. The Broker further stated that
the alleged afferent accounts have been opened by IPO sub brokers. The Broker
Page 17 of 191
further stated that simply because the IPO sub brokers used to procure large number
of applications along with others could not concluded that it was aware of the
financing arrangement. The Broker added that it was not aware about the finances
provided by KCL to Smt Roopalben Panchal and that she had made large number of
applications. It also contended that the sale of shares by it on behalf of Shri
Purshottam Budhwani and Shri Manoj Seskaria was in the ordinary course of
business. The Broker asserted that it had not directly or indirectly employed any
device, scheme or artifice to defraud in connection with issue or dealing in securities
which were listed or proposed to be listed on a recognized stock exchange. Further it
stated that it had not violated any of the provisions of law as alleged against it.
3.4. In the case of RTI
A show cause notice dated December 20, 2006 was also issued to KCPL and asking it
to show cause as to why the appropriate penalty including the penalty as
recommended by the Enquiry Officer should not be imposed against it. An
opportunity of hearing was granted to KCPL on January 4, 2007.
KCPL vide letter dated January 8, 2007 inter alia stated that there was no material to
substantiate the allegation of knowledge in respect of the fictitious nature of the
applications pertaining to the key operators made against it. In respect of the common
management, KCPL stated that there was clear division of operations between it and
the other Karvy entities. In respect of the single consolidated refund orders, KCPL
stated that the same was established for the purpose of efficient investor servicing and
administrative convenience. KCPL further stated that it had not issued any single
consolidated refund order pertaining to the alleged benami/ fictitious applications
made by Shri PUrshottam Bhuwani and Shri Manoj Seksaria. It asserted that in case
of most IPO brokers such as KSBL, a co ordinator was appointed who was
responsible of the effective servicing of the clients of such IPO brokers. KCPL further
contended that as an RTI it had no role to play in the financing activity of KCL. In
view of the above submissions KCPL requested SEBI to drop the proceedings
initiated against it. KCBL further stated that single consolidated refund orders were
Page 18 of 191
issued by it on a uniform basis to all such institutions who sought to receive such a
consolidated cheques such as ICICI Web Trade Ltd., IDBI Bank, Indian Overseas
Bank etc. It is further stated that the said system was according to the specific
instructions of the respective IPO applicants and the same was purely intended for
facilitating the settlement process and was nearly administrative in nature. KCPL
further denied of having any role in the alleged IPO irregularities and added that each
of the companies forming part of Karvy Group are independent legal entities.
KCPL further added that the practice of issuance of single consolidated refund orders
was undertaken by it since October 2004. It further added that the said practice was
undertaken much prior to the KCL financing IPO applications, as alleged. KCPL
further in respect of multiple applications stated that 487 applications (in the case of
Yes Bank IPO) and 45 applications without beneficiary details were rejected. In the
case of IDFC IPO, KCPL stated that 1526 application were rejected on the ground of
being multiple applications and 56 applications were rejected for want of beneficiary
details. KCPL further added that it was not aware of the fictitious nature of the
application made by Roopalben Panchal group and in the said context KCPL stated
that it had no role as an RTI to play in the financing activity of KCL.
4.0. HEARINGS
4.1. An opportunity of hearing was granted by SEBI to RTI on January 4, 2007 Shri R.
Parthasarthy the Chairman of the Karvy Group made submissions on behalf of
KCPL. As the nine months prohibition as recommended by the Enquiry Officer was
already elapsed and taking into account the balance of consideration, vide order
dated February 22, 2007 SEBI had lifted the prohibition imposed on KCPL vide
interim order dated April 27, 2006. In the said order it was specified that the final
findings as to the role of KCPL could be determined only when the final findings as
to the role of KSBL was determined in the enquiry proceeding against it.
Page 19 of 191
4.2. An opportunity of hearing was also granted to the DP and the Broker on May 22,
2007, May 25, 2007 and May 29, 2007. Shri Shyam Mehta, advocate represented
the DP and the Broker and made submissions on behalf of them. Shri Vinay
Chauhan, advocate, and Shri R Parthasarathy, were also present during the time of
the hearing. Shri. Shyam Mehta made submissions on the lines of the reply of the
DP and the Broker dated May 19, 2007.
4.3. Pursuant to the above hearing, the DP and the stock broker filed written
submissions vide letters dated June 6, 2007 and June 8, 2007 respectively. The DP
while reiterating its reply dated May 19, 2007 stated that it was not liable for the
activities of the KCL as a DP which was at variance with the contentions of Karvy
DP made in its reply dated May 19, 2007. The counsel further stated that the
authority can not enhance the penalty what was recommended by the Enquiry
Officer.
4.4. As the DP and the Broker are admittedly group companies and are functioning
under the same management and control and also the fact that the issues involved in
all the present proceedings (including that of RTI) are connected / similar and
further since the responses of the said intermediaries are common/similar all the
present proceedings (against DP, RTI and the Broker) are dealt with in a common
order.
5.0. Issues for Consideration
5.1. Keeping in view the oral / written submissions of Karvy, various documents on
record, the observations of the Hon’ble Securities Appellate Tribunal and the
findings of the Enquiry Officer, the following issues remain for consideration:
? Whether it is a simple case of failure to exercise due diligence or whether Karvy
DP had gone beyond in crafting a collusive game-plan with the key operators for
the purpose of cornering IPO shares?
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? Whether, the other entities belonging to the Karvy group, specificially Karvy
Consultants Ltd. (NBFC and formerly DP), Karvy Stock Broking Ltd. (Broker)
and Karvy Computershare P Ltd. (RTI) had colluded with the DP in executing the
gameplan for cornering IPO shares?
? Whether, based on the material available on record, the findings of Enquiry
Officer be accepted? and
? Whether, based on material available on record, the penalty recommended by the
Enquiry Officer is appropriate or whether it calls for a higher penalty?
5.2. Before proceeding with the issues for consideration, I note that the existence of
fictitious afferent accounts as opened with Karvy DP are not in dispute as would
be evident from the Hon’ble Securities Appelate Tribunal Order dated January
8, 2007. Karvy has also admitted the same in the complaint filed against 4 sub-
brokers namely, Grace Consultancy, 402-403, Shashwat, Opp: Gujarat
College,Ellisbridge, Ahmedabad – 380006 (Rep by its Proprietor Deepak
Panchal) (Accused no.1), Arth Realty Pvt. Ltd, 803, Abhijeet-1, Mithakali
Circle, Navrangpura, Ahmedabad – 380009 (Rep by its Director Parag P
Jhaveri) (Accused no.2), Purshotham Budwani S/o. Late Ghanshyamdas
Budwani Age: 41 years, R/o. B/2, Himalay Housing Co-op Soc, Asalfa,
Ghatkopar (W) Mumbai 84 (Accused no.3) and Manoj G Sakseria S/o.
Gokulchand Seksana, R/o. 33, Maheshwan Niketan, Peddar Road, Mumbai 26
(Accused no.4). In the memorandum of the complaint, Karvy DP has, inter alia,
stated as below:
5.3. “The Complainant herein states and submits that the Company as a
Depository Participant opens accounts through its branches and through
its associates across the country. For the past 2/3 years, due to the strong
market sentiments, number of Companies have offered their shares to the
Public. For applying for shares offered by a company, having a
depository account is a must which is opened with Depository
Participants like Karvy Stock Broking Ltd. The company accepts
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application forms for opening depository account from business
Associates also. For opening a depository account, the applicant has to
submit along with application form in the prescribed format duly filled in,
various supporting documents like proof of address and identity. The
business associates generally collect the applications from various
applicants whom they service and submit the same to our Branches for
opening the depository account.
5.4. These associates are either provided special rates for opening depository
accounts for their clients or are paid remuneration on each account for
processing the application. These Business Associates, have collected
applications for opening depository accounts from various applicants.
Since they had direct contact with the applicants, they are required to
verify credentials of the applicant, including verification of documents
like proof of address, identity proof, Bank account details etc. of the
person who intends to open the account after filling up the prescribed
form as per the norms of SEBI and submit the same to our branches.
With regard to the accounts under reference, these associates or their
friends / relatives have also acted as introducer for each of the accounts.
5.5. The Complainant states that they believed that all the accounts forwarded
by the associates are true and correct and are eligible to open the
depository accounts. The accused have fraudulently opened fictitious
accounts to defraud and cheat the Company. The Complainant herein
states that consequent to the order issued by Securities and Exchange
Board of India (sebi), National Securities Depository Limited (NSDL)
had, vide their letter dated 17th December 2005, directed the Company as
Depository Participant to verify the cases. On such verification, the
Company came to know that the associates have committed breach of
trust with the intention to cheat genuine investor. These associates on
demand by the company have failed to produce their customers for
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identification which has lead the company to suspect that they have
opened accounts of non existing persons and got lot of shares allotted
to them. Thus they have cheated the genuine investors, Company and
committed criminal breach of trust as the Company totally depended on
the information and scrutiny of the sub-brokers.
5.6. The Complainant submits that the accused 1 to 4 herein have opened
depository participant accounts with ulterior motive and malafied
intention to cheat genuine investors knowing fully aware of the facts and
committed criminal breach of trust as such the accused committed offence
punishable under Section 406 and 420 of IPC.” (emphasis supplied).
Any discussion on the case would be incomplete without a proper understanding
of the processes involved in IPOs. Accordingly, I proceed to deal with the same.
6.0. IPO Process
6.1. As per information obtained from NSE the IPO process involves the following:
1. The Book Running Lead Manager (BRLM) files the Draft Offer Document
(DOD) with SEBI and the stock exchange where the Company proposes to list its
securities for their comments/approval.
2. The stock exchange checks as to whether the applicant company is eligible as per
the listing criteria for listing on the stock exchange pursuant to its Initial Public
Offering.
3. Further, the stock exchange also checks details on the background of the
promoters, disclosures made by the Company in the Draft Offer Document
including the risk factors mentioned therein etc.
4. The stock exchange thereafter provides an in-principle approval for enabling the
company to mention in the offer document that the shares after the issue are
proposed to be listed on the stock exchange named therein.
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5. After the in principle approval of the stock exchange is issued, and subject to
approvals they have to obtain from SEBI and other authorities, if any, the Issuer
company can make the public issue.
6.2. Book Building
Book building is an electronic mechanism for collection of orders through the IPO
infrastructure of the Exchanges. The members who are eligible for using the IPO system
or who are entitled to enter the bids are decided by the BRLMs to the issue. (These stock
brokers selected by the BRLMs for accepting bids are called syndicate members).
The bid data collected through the book building process is provided by the stock
exchanges to the Book Running Lead Managers who in-turn forwards the same to the
Registrars and Transfer Agent concerned. The physical applications are collected by the
Registrars from the banks where the applications and cheques are deposited. The
applications are processed by the Registrars and a meeting of the Book Running Lead
Managers, Registrars and the Issuer company is held to decide the basis of allotment. The
minutes of this meeting which inter alia contain details regarding how the basis has been
drawn, total subscription received for the issue, technical rejections, total number of
shares to be considered for allotment etc., is submitted to the stock exchanges. To
determine the successful allotees, the draw of lots is conducted by the Designated Stock
Exchange (draw of lots are done by a SEBI approved Public Representative on the Board
of the Designated Stock Exchange) and the basis of allotment is finalised. As such, the
stock exchanges do not process or scrutinise the physical application forms or the unique
details of the applicants such as addresses, PAN number etc., during the IPO process and
hence will not be in a position to ascertain multiple or fictitious applications.
On completion of the basis of allotment, the Registrars for the IPO carries out the
allotment process by making allotment in accordance with the basis of allotment and then
uploading the file containing the details of allotment to the depository which in turn
credits the shares to the applicants’ beneficiary accounts. The Issuer company will then
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submit a certificate from a practicing Chartered Accountant or a Company Secretary
confirming that the allotment has been done by the Registrars as per the basis approved
by the stock exchange. After the completion of the credit of shares, the depositories issue
a certificate indicating that the shares as detailed by the Registrars have been credited to
the beneficiary accounts to the Issuer which is in turn submitted to the stock exchanges
by the Book Running Lead Manager / Issuer company. A confirmation of the dispatch of
refund orders is submitted to the stock exchanges by the Registrars.
6.3. Stages in a Book Built Issue
The various stages in the book built issue can be broadly described as under:
? In a Book Built Issue, the applicant submits his IPO application along with the
cheque / DD to the syndicate member / sub syndicate member for entering bids in
the Bid Book.
? It is mandatory for the applicant to indicate his demat account particulars in the
application form. Thus it is mandatory for an IPO applicant to have a demat
account while making application in an IPO. Further, for the purpose of refund of
application money, the bank details of the applicant are downloaded by the RTI
from the depository system and therefore it is mandatory for the demat account
holder / IPO applicant to indicate his bank details in the depository account.
Therefore, opening of bank account and Demat account can be considered as the
first stage in making application in book built issue.
? Upon receipt of IPO application along with the Cheque / DD, the syndicate / sub
syndicate member verifies the same and thereafter the syndicate / sub syndicate
member enters the bid in the BSE / NSE system and forwards the physical
applications along with the cheques / DDs to the collecting bank.
? The collecting bank separates the cheques / DDs from the application forms and
sends the cheques / DDs for collection and simultaneously forwards the IPO
application to the registrar to issue for preparation of application master.
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? Upon realization of cheques, Banker to the issue (i.e. Collecting Bank) submits
the details of the cheques realized along with bank serial number which forms the
basis for the RTI to reject application where cheques have not been realized.
? The master database is prepared by Registrar to an Issue for the purpose of
working out the basis of allotment after weeding out invalid and multiple
applications as per applicable criteria.
? The Registrar to an Issue, the Post Issue Lead Manager, representative of stock
exchange and an official of the issuer company in a meeting decide the basis of
allotment and finalise the ratio of allotment.
? Based on the approved basis of allotment, registrar to an issue makes allotment to
eligible investors and through a process of corporate action, electronic allotment
is made to the demat account of the allottee through depository.
? Concurrently, the Confirmation of Allotment Note (CAN) is dispatched along
with the refund order or refund details (in case of direct credit to the bank
account).
6.4. The above process is completed within 15 days from the date of closure of the IPO.
Thus, it can be seen from the above process that essential steps for applying in book
built issue are broadly as under:
1. Opening BANK ACCOUNT and DEMAT ACCOUNT
2. Arranging IPO FINANCE
3. Submission of application along with payment instrument (cheque / DD) to
syndicate member and BIDDING
4. Receipt of ALLOTMENT / REFUND ORDER
6.5. Karvy group’s presence in the entire chain of IPO process
I note that on the basis of data on record, Karvy group entities were ubiquitously present
in the entire gamut of the IPO process running from introducing bank accounts, opening
of dematerialized accounts, arranging IPO finance, bidding of applications, making
Page 26 of 191
allotment, issuing refund, making off-market transfers (DIS) and sale of IPO shares on
the stock exchanges. The role of Karvy group entities at each stage of the process has
been examined for uncovering Karvy’s role at every stage and to ascertain overall control
beginning from opening of bank and dematerialized accounts till making refund and off-
market transfer of IPO shares.
The group’s presence in the entire IPO process is schematically depicted as under:
7.0. Applicable Guidelines
7.1. While opening dematerialized accounts, the DP has to comply with the Know Your
Customer (KYC) norms laid down by SEBI through circulars dated August 4, 2000
and August 24, 2004. SEBI vide circular dated SMDRP/Policy/CIR- 36/2000 dated
August 4, 2000, has prescribed detailed procedure to be followed by all depository
Opening of demat a/cts (KCL / KSBL – DP)
Introduction of Bank A/cts through tie-up with banks (KCL / KSBL / KSL / KISL)
Arranging bank finance / providing IPO finance (KCL - NBFC)
Bidding of applns / RTGS (KSBL - broker)
Refund (KCPL - RTI)
Allotment (KCPL – RTI)
Off Market transfers (KCL / KSBL - DP)
Sale of shares on the stock exchange (KSBL - Broker)
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participants at the time of opening beneficiary account. The said circular prescribed
the documents which can be accepted by the DPs for the purpose of proof of
identity and proof of address. In respect of proof of identity the documents
prescribed are PAN Id, Voter Id, Ration Card, Passport etc and for proof of address
the documents prescribed are Telephone Bill, Electricity bill etc. Subsequently, vide
circular ref: MRD/DoP/Dep/Cir-29/2004 dated August 24, 2004 SEBI stipulated
that an identity card / document issued by Scheduled Commercial Banks containing
the applicant’s photo / address may be accepted as POI and POA. The circular
further clarified that “the aforesaid documents are the minimum requirement for
opening a BO Account. The Depository Participants (DPs) must verify the copy of
the document with the original before accepting the same as valid. While opening a
BO Account, the DPs are required to exercise due diligence while establishing the
identity of the person to ensure the safety and integrity of the depository system.”
7.2. In terms of clause 16 of Regulation 20A of SEBI (Depositories and Participants)
Regulations, 1996, “A Participant shall follow the Maker-Checker concept in all of
its activities to ensure the accuracy of the data and as a mechanism to check
unauthorized transaction.”
7.3. While opening bank accounts, the banks have to comply with the applicable KYC
norms laid down by RBI and also comply with their internal guidelines in this
regard. While providing IPO finance, Banks and NBFCs have to comply with the
relevant RBI guidelines including KYC norms.
7.4. The process of public issue is governed by the SEBI (Disclosure and Investor
Protection) Guidelines, 2000. As regards, bidding of application forms in the retail
category, in terms of Guideline 11.3.1 clause xvii (a), “The broker may collect an
amount to the extent of 100% of the application money as marging money from the
clients / investors before he places an order on their behalf… ”
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8.0. For the purpose of this order, the abbreviations occurring in various places in the
order would mean :
Karvy: Karvy Group including Karvy Stock Broking Limited ( KSBL), Karvy
Consulatnts Limited ( KCL), Karvy Computershare Private Limited (KCPL),
Karvy Securities Limited (KSL) and Karvy Investor Services Limited ( KISL).
8.1. The DP in its reply dated May 19, 2007 contended that, it was not liable for the
violations committed by KCL. In support of its contention, the DP relied upon the
judgment of the Hon’ble High Court of Bombay in the matter of SEBI Vs. SKDC
Consultants Ltd. However, at the time of the hearing, the counsel for the DP had not
pressed the said contention and further submitted that the DP would be responsible
for the acts done by KCL in its capacity as the DP and not as NBFC. The said
submission has been further strengthened by the following statement made by the
DP in its reply dated May 19, 2007; “In this regard it is submitted that for the
activities carried out by KCL, other than the DP activities, the company cannot be
held liable for violations committed by KCL, if any“. However, I note that in its
written submission dated June 6, 2007, the DP further contended that it is not liable
for the alleged violations of KCL as a DP. KSBL further stated that it only took
over the business obligations of KCL and not the proceedings in connection with
any alleged violation committed by KCL.
8.2. In this context, I note that SEBI had approved the transfer of depository business of
KCL to KSBL, inter alia pursuant to the request made by KSBL through NSDL. I
observe that NSDL vide letter dated June 16, 2005 informed SEBI about the
intention of KCL to transfer its depository business to KSBL and further stated that
the infrastructure of KCL would be used by KSBL, pursuant to the transfer
arrangement ( between KCL and KSBL). In its letter cited above, NSDL had also
enclosed the application (Form ‘E’) of KSBL for the grant of certificate of
registration as a DP. In the said application, KSBL inter alia stated that KCL was
Page 29 of 191
one of its group companies and further undertaken to comply with the provisions of
the Act, the DP Regulations and such other guidelines/ instructions which may be
announced by SEBI from time to time. I also note that KSBL vide its letter dated
April 30, 2005 had inter alia given the following undertaking to NSDL. “On
completion of the transfer, all assets, liabilities, rights and obligations pertaining to
DP business will transfer from KCL to KSBL.”
8.3. In the aforesaid application (Form E), KSBL had inter alia given the details of the
directors and the share holding pattern of KCL vis a vis KSBL. The details of such
information given by KSBL are given below:
a) Details of directors
Name of the
intermediary
Name of the Directors
KCL Mr.C. Parthasarathy
(Chairman)
Mr. M. Yugandhar
(Managing Director)
Mr.
M.S.Ramakrishna
Mr.
Prasad V.
Potluri
KSBL Mr.C. Parthasarathy
(Chairman and
Managing Director)
Mr. M. Yugandhar
(Managing Director)
Mr.
M.S.Ramakrishna
-
b) Shareholding Pattern
Number of shares %age of total capital Sr. No. Name of the
shareholder KCL KSBL KCL KSBL
1 C. Parthasarathy 69,539 259304 1.64 19.42
2 M. Yugandhar 4,09,998 188728 9.69 14.13
3 Compar Investments
P. Ltd.
11,24,304 343310 26.58 25.71
4 Adhiraj
Parthasarathy
68,000 2366 1.61 0.18
Page 30 of 191
5 Rajat Parthasarathy 68,000 2366 1.61 0.18
6 M. Rajini 5,27,419 35238 12.47 2.64
7 M.S.Ramakrishna
(HUF)
95,640 223966 2.26 16.77
8 C. Parthasarathy -
HUF
20,000 666 0.47 0.49
9 Kokila Parthasarathy 64,000 100 1.51 0.007
Total ( sr. no. 1 to 9) * 57. 84% 79.527%
10 M. Gangadhara Rao 45,280 - 1.07 -
11 M. S. Ramakrishna 4,19,197 - 9.91 -
12 M. Spandana 97,000 - 2.30 -
13 M. Ahalya 84,120 - 1.99 -
14 M. Rushyanth 1,33,280 - 3.15 -
15 M. Meena 61,600 - 1.46 -
16 M Susheela Dei 19,540 - 0.46 -
17 Prasad V Potluri 9,23,078 - 21.82 -
18 Karvy Consultants
Limited
- 230480 - 17.26
19 C.R. Rajagopalan - 100 - 0.007
20 Adhirajat Inv. Pvt. Ltd. - 48704 - 3.65
21 Karvy Investor
Services Ltd.
- 300000 - -
*Common shareholders
8.4. From the above table it can be seen that KCL and KSBL were having certain
common directors and shareholders at the time of the transfer of business
undertaking. Further, the shareholders specified at serial nos. 1 to 9 were common
to both KCL and KSBL and they collectively hold 57% and 79% of the total capital
of KCL and KSBL respectively. Therefore, even at the time of transfer of business
undertaking of KCL to KSBL, both the entities were administered and controlled by
the same management. In this context, I also note the reply of the DP to the show
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cause notice dated May 4, 2007, wherein it was stated that both KCL and KSBL
were group companies. In view of the common control and management, KSBL is
the alter ego of KCL. In any event KSBL is liable for all obligations of KCL as per
the agreement with NSDL. At the time of hearing, the advocate appearing for DP
did not press this point, while conceding that the liability of KSBL, in so far as it
relates to the transfer of DP business from KCL would be restricted to that arising
from DP business. In that view of the matter, the subsequent plea in the written
submissions denying such liability besides citing the decision of the Hon’ble
Bombay High Court in support smacks not only of a departure from the stand at the
time of hearing but also betokens a desperate attempt to somehow wriggle out of
the liability staring in the face. Such contradiction in the pleas raised by the DP
seriously impairs the creditability of their defense.
8.5. Further, the DP in support of its contention relied upon the judgment of the Hon’ble
Court of Bombay in the matter of SEBI vs. SKDC Consultants Ltd. I note that the
facts of the said case and the present case are different and can not be compared on
equal footing. In the said case, SKDC Consultants Ltd. which was incorporated in
the year 1998 entered into a Memorandum of Understanding with the proprietrix of
Shree Krishna Data Center and it had subsequently took over the business of Shree
Krishna Data Center as a going concern with effect from April 1, 1998.
Subsequently, in the wake of certain violations relating to public issue of shares
which took place in the month of November / December 1995, SEBI ordered
adjudication proceedings against SKDC consultants Ltd. and the adjudicating
officer imposed a penalty against SKDC Consultants Ltd. The said order of the
adjudicating officer was set aside by the SAT inter alia on the gound that SKDC
Consultants Ltd. was a distinct legal personality from Shree Krishna Data Center. In
the said case, the said Shree Krishna Data Center was owned by the sole proprietrix
and she was only one of the seven subscribers to the Memorandum of Association
and only one of the first directors out of the four directors of SKDC Consultants
Ltd. According to SAT, the same was not sufficient to hold that Shree Krishna Data
Center and SKDC Consultants Ltd. were one and the same entity for all purposes.
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The above proposition of SAT was upheld by the Hon’ble High Court of Bombay
in the matter SEBI vs. SKDC Consultants Ltd. However, in the present case, both
the entities [transferor (KCL) and the transferee (KSBL)] were under the same
management and control and continued to be so at the time transfer of business
undertaking. As per the shareholding pattern of both the entities (as given by
KSBL), the common shareholders were holding 57% and 79% of the total capital of
KCL and KSBL respectively. In such circumstances, the DP can not contend that
KSBL is not liable for the violations of KCL. The presence of common directors
and shareholders (with majority of the shareholding) serves to demonstrate unity of
control and in that view the cited case is totally irrelevant so far as the facts of the
instant case are concerned.
8.6. In view of the above coupled with the undertaking given by KSBL to NSDL to
takeover inter alia the rights and obligations pertaining to Depository business of
KCL, I am unable to accept the contention of the DP that SEBI cannot take action
against the DP for the violations of KCL and accordingly the same is rejected.
8.7. I further note that, such a plea does not brook countenance, as any entity arraigned
for market misfeasance could seek easy exculpation and avoid punishment through
such subterfuges by transferring the business to another group entity.
8.8. In addition to the above, I note that the DP had not taken the aforesaid plea either
before the Hon’ble High Court of Andhra Pradesh or before the SAT wherein it had
challenged the interim order of SEBI. Therefore, the said contention of the DP
which even otherwise is not acceptable cannot be entertained at this belated stage.
8.9. In view of the fact that both the intermediaries were under the same management
and the business undertaking of KCL was transferred to KSBL as per their request,
I am unable to accept the contention of DP that it is not laible for the alleged
violations committed by KCL.
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8.10. The DP has further taken an objection that SEBI (Chairman or the Whole Time
Member) can not consider any fresh allegations (which were not considered by the
Enquiry Officer) based on new materials. It has been further contended that SEBI is
duty bound to pass order based on the findings in the Enquiry Report. In this
context, the DP has claimed that the Authority can not travel beyond the Enquiry
Report and what was considered therein. The DP has further contended that the
show cause notice was merely a formality to show the procedural fairness as the
Whole Time Member has categorically concluded that the prohibition of 18 months
should be enhanced to 3 years. The DP clarified that the Authority had already
prejudged the matter and therefore there was no scope for any effective
representation. The DP further asserted that the suo moto finding of violation of law
and quantification of penalty even before the hearing the defense was in violation of
principles of natural justice. In addition to the above, the DP has contended that the
authority can not enhance the penalty which was recommended by the Enquiry
Officer.
8.11. The DP contended that SEBI could not travel beyond the Enquiry Report in the
context of 37 bank account opening forms of Smt. Roopalben Panchal with Indian
Overseas Bank, Thaltej Branch, Ahmedabad. I note that in the show cause notice
dated May 4, 2007 it has been inter alia mentioned “Your kind attention is drawn
to pages 54-55 (paras 11.3.3 and 11.3.4) of the enquiry report regarding the
introduction of 37 savings bank accounts of Roopal Panchal to the Indian
Overseas Bank (IOB), Thaltej Branch, Ahmedabad. IOB vide its letter dated
March 4, 2006 had enclosed copies of the sample bank account opening forms of
Roopal Panchal. Out of these, copies of the bank account opening forms in
respect of account numbers 12004, 12140, 12149 and 12150 are enclosed as
Annexure- 1. Various observations regarding the said bank accounts and the
manner in which the demat accounts in names of persons figuring in the last
attached with each such account were opened are enclosed as Annexure-2”.
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8.12. On a perusal of the said show cause notice, it can be seen that no fresh allegations
are leveled against the DP and the observation mentioned therein was only an
extension of the findings of the Enquiry Officer (para 11.3.3 and 11.3.4 of the
Enquiry Report). Further the Enquiry Officer in his report had discussed certain
instances (9 accounts) out of the said 37 bank accounts. The Enquiry Officer had
also mentioned the letter dated March 4, 2006 received from the Indian Overseas
Bank, Thaltej Branch, Ahmedabad. The contention that the said letter suffers from
factual inconsistencies is not correct in view of the following discussion.
8.13. I note that the above letter listed out (by way of annexure) 37 savings account nos.
and the names of the said savings accounts. The said letter specified that to the
said 37 bank accounts which were introduced by the DP, 50 additional names
were added and the said names were attached in a separate sheet with the
respective account opening form. Therefore, the contention of the DP that there
were inconsistencies/ contradictions in the letter of IOB dated March 04, 2006 can
not be accepted. The Enquiry Officer had given his findings on the said issues in
paras 11.3.3 and 11.3.4 of the Enquiry Report. The Enquiry Officer had discussed
some of the accounts out of the said 37 accounts on an illustrative basis. In a case
of this magnitude, it would be well neigh impossible in an order to deal with all
the afferent accounts (about 50, 000 acccounts) with all their devious features.
Accordingly, typical samples are taken for detailed examination. The same would
not mean that the evidences available in other afferent accounts are shut out. As
the modus of operandi in all the above 37 bank accounts were similar, the Enquiry
Officer considered it appropriate to discuss about certain specific instances. The
observations of the Enquiry Officer in respect of certain bank accounts opening
forms (by way of illustration) can not by any stretch of imagination would lead to
a conclusion that other bank accounts are out side the purview of the enquiry
proceedings against the DP.
8.14. In addition to the above, the DP in its appeal memorandum (Appeal No. 92 of
2006) inter alia stated “… … … ..The Respondent has not provided any proof for
Page 35 of 191
the introduction as stated in the impugned Order at para 6.35. The Appellant will
be in a position to explain only on receipt of the documents relied upon by the
Respondent to arrive at the said observation. It is stated tat the Appellant had not
introduced the said 50 clients to IOB Thaltej. The Appellant had only certified,
pursuant to the request of IPO sub broker, that the said 50 clients had demat
account with the Appellant. It is submitted that all the said 50 clients had, as per
Appellant’s records, bank accounts with BhOB. Therefore the certification given
by the Appellant was for existence of demat account as sought to be suggested.”
The aforesaid ground taken by the DP before SAT was nothing but an admission
in respect of its role in certifying the additional 50 names in the said 37 accounts.
Further, KSBL in its capacity as a Broker in the reply dated May 19, 2007 stated
“simply because its employees had introduced the accounts and perhaps put the
address or stamp of the company on the forms, it cannot be concluded that the
company was aware of the activities of the employees.” The said submission
would fortify the fact that Karvy actively participated in the introduction of bank
accounts of Smt Roopalben Panchal and the other additional 50 names who were
nothing but fictitious. Such contradiction in the pleas raised by Karvy Group
(before SAT and before SEBI) seriously impairs the credibility of their defence.
8.15. Further, SEBI in its orders dated April 27, 2006 and May 26, 2006, prima facie
found that the DP had introduced the bank accounts of certain groups and
facilitated the entire process starting from making IPO applications for them after
collecting pay orders from the bank, arranging finance for them till collecting and
distributing their refund orders. Therefore, the reference of 37 bank accounts with
additional 50 names in the show cause notice was based on the documents which
were already considered at the time of passing the orders of SEBI dated April 27,
2006 and May 26, 2006, documents which were provided to the Karvy Group at
the time of the appeal before SAT and in the present enquiry proceedings.
Therefore, the contention of the DP that the documents pertaining to 50 additional
names attached to the Bank account introduction form of Smt Roopalben Panchal
were not considered by the Enquiry Officer is not correct and the same is rejected.
Page 36 of 191
8.16. Further, I note that regulation 13 (2) of the SEBI (Procedure for Holding Enquiry
by Enquiry Officer and Imposing Penalty) Regulations, 2002 empowers the
Chairman or the Member, as the case may be to consider the Enquiry Report and
to issue a show cause notice, as to why action as it considers appropriate should
not be taken. Thus, the powers of the Chairman/ Member while considering the
Enquiry Report is wide and he can take any action as it considers appropriate.
Further, in terms of regulation 13(4) of the Enquiry Regulations, the Chairman or
Member, upon the receipt of enquiry report is empowered to “pass such order as
he may deem fit” after considering the reply filed by the intermediary concerned.
The expression “pass such order as he may deem fit” has to be interpreted
broadly and the power of SEBI is not restricted to imposing penalty as
recommended by the Enquiry Officer. If the competent authority has the
jurisdiction to pass any order in reference to a specific case called for by it as it
thinks fit, obviously it can come to a different conclusion/ finding from the one to
which the Enquiry Officer had arrived, on the same set of facts. Obviously the
competent authority can also impose a different penalty from that was
recommended by the Enquiry Officer. It is settled that the question of imposing
punishment can only arise after enquiry is made and the report of the Enquiry
Officer is received. The competent authority may agree with the report or may
differ, either wholly or partially, from the conclusions recorded in the report. i.e
neither the conclusion on the evidence nor the punishment which the enquiring
authority may regard as appropriate is binding upon the punishing authority.
8.17. Further, the contention of the DP that the authority has concluded to enhance the
prohibition from 18 months to 3 years is also not acceptable. The proposal to
enhance the prohibition from 18 months to 3 years (as mentioned in the show
cause notice) was only a prima facie/tentative observation after considering the
Enquiry Report and the materials available on record. Further, the penalty was not
enhanced by SEBI and the object of the show cause notice dated May 04, 2007
was to give an opportunity to the DP to submit its case on the proposed
Page 37 of 191
enhancement in penalty. The DP was also granted an opportunity of hearing on
various dates. The said opportunities were provided by SEBI to the DP towards
the compliance of the principles of natural justice, so that the DP could make its
submission/explanation, if any, against the proposal to enhance the penalty. The
penalty has only been indicative and not finally determined and therefore, no
prejudice has been caused to the DP.
8.18. Further, the contention of the DP that, if the Whole Time Member had
categorically concluded that the prohibition of 18 months should be enhanced to 3
years, then the show cause notice was merely a formality to show the procedural
fairness is not acceptable. I wish to add that the penalty was not increased vide the
show cause notice and the proposal to enhance the penalty was only a tentative
decision. Communicating the tentative decision in no way would cause prejudice
to the party. On the other hand, if at all the disciplinary authority gave detailed
tentative decision before seeking explanation from the appellants, it would enable
the party to give an effective representation and the principles of natural justice
are thus fully complied with.
8.19. As discussed above, the findings of the Enquiry Officer are only his opinion on
the materials, but such findings are not binding on the decision making authority
and the latter can come to its own conclusion. That apart, the issuance of show
cause notice provides an opportunity to submit its reply in relation to the proposed
enhanced penalty and no prejudice is caused by the same. In view of the above, I
am unable to accept the above contention of the DP.
9.0. Consideration of Factual Issues
9.1. In order to consider the issues as above, I now propose to examine the role of
Karvy group companies in the entire process of IPO beginning with the opening
of afferent dematerialized accounts, introduction of bank accounts of key
operators, afferent accounts and the addition of fictitious / benami names to the
bank accounts for availing IPO finance, providing of IPO finance to the fictitious /
benami entities through the medium of key operators, bidding of the application
Page 38 of 191
forms of fictitious / benami entities without the corresponding payment (100%
IPO margin), issue of consolidated refund cheques, issue of directions for
appropriation of refund money and execution of synchronized off-market
transfers including issue and processing of DIS.
9.2. The manner of opening bank accounts and dematerialized accounts clearly
demonstrates Karvy’s control and their knowledge of the fictitious / benami
nature of these accounts. In effect, Karvy was dealing only with the key operators
and not with anyone else. The IPO process, IPO financing, RTGS transfer to the
escrow account, issuance of consolidated refund order and issues relating to DIS,
the discussion of which follow hereinunder, further strengthen the above finding
with tell tale strands of Karvy’s control with full knowledge at each and every
stage of IPO process. They constitute additional material evidences to confirm the
obvious as arising from the discussion relating to bank accounts and demat
accounts elsewhere in the order.
9.3. Even a single instance of incontrovertible data establishing Karvy’s active
involvement, anywhere in the chain, in abusing the allotment process is good
enough and in that view, the overwhelming body of additional material evidences
only serves to exacerbate the gravity of such misconduct.
SCHEMATIC REPRESENTATION OF GAMUT OF KARVY’S OPERATIONS
Opening of demat a/cts of key operators and afferent entites
Introduction of Bank A/cts of key operators and afferent entities
Arranging bank finance / providing IPO finance (self)
Bidding of applns without cheques/ RTGS
Refund (Consolidated refund order)
Allotment
Off Market transfers (pre-printed DIS & NO DIS)
Page 39 of 191
9.4. Introduction of Bank Accounts by Karvy I note that during June 2003 when there were public issues of many premier
companies such as Maruti Udyog Ltd, UCO Bank, Vijaya Bank etc., Karvy had
presented to BhOB an idea paper and a process flow. As per the process flow, the
IPO applications would be filled in by the investor and a cheque/DD in favour of
the Bank towards the margin amount shall be deposited. The investor would need to
open the Demat account with Karvy who would place a lien on the shares deposited
into the investor's account until the investor clears the loan with the Bank. The
client would deposit the payment instrument and bid form with the Bank along with
the account opening document and documents for the loan. The Bank would ensure
that the Savings Bank (SB) account opened by the Bank is mentioned in the
relevant column in the bid form as the Bank account to which the refund is to be
sent. The Bank would issue Pay order for the amount of the application by debiting
loan account and margin money of the respective applicants. If the investor is not
allotted shares against the IPO application, refunds are made to investor by the
registrar through the Bank and the refund order credited to the account, after
liquidating the loan. In case of allotment, the investor is required to bring in the
required amount if there is shortfall and fulfill the obligation with the Bank along
with the interest after which the lien is released by the Bank and informed to the DP
for release of Bank's lien on the demat account.
9.5. A perusal of the process flow envisaged for IPO funding as spelt out by Karvy
shows that there was a specific assuring clause to the effect that there were no
chances for cases such as benami applications, multiple applications, fraudulent
investors etc. thereby providing comfort to the bank.
9.6. Pursuant to the arrangement, it is seen that Karvy had introduced numerous bank
account holders to BhOB, Ahmedabad branch. In what is seen as first of such bank
accounts introduced by Karvy to BhOB Ahmedabad, there is a set of account with
Page 40 of 191
numbers starting with ‘50795’. The observations on these bank accounts with
BhOB Ahmedabad branch beginning with the number ‘50795’ is given below:
9.7. Introduction of bank account no. 50795 with BhOB Ahmedabad by Karvy
It was observed that following bank accounts starting with 50795 were held in the
name of Devangi Dipak Panchal as first holder and certified copies of the following
bank accounts were submitted. These accounts were introduced by Karvy Securities
Ltd / Karvy Investor Services Ltd. These were opened for the purpose of availing
finance in the IPO of Maruti Udyog Ltd on June 17, 2003 and closed on October
27, 2003:
1. 50795/1 to 50795/ 2 2. 50795/ 5 3. 50795/14, 4. 50795/16 5. 50795/18 to 50795/24 6. 50795/26 to 50795/60 7. 50795/ 62 to 50795/ 64 8. 50795/ 67 to 50795/127 9. 50795/130 to 50795/131 10. 50795/137 to 50795/150 11. 50795/152 to 50795/153
9.8. On a random selection basis, the bank account opening form pertaining to SB
account no 50795 / 081 was examined. It is seen that this account was initially
opened in the name of Devangi D Panchal on the introduction of Karvy Securities
Ltd. Further, it is observed that the names of Shah Manjula K and Pritesh K Shah
were added to this account on the introduction of Karvy Investors Services Ltd.
Similarly, a perusal of the bank account opening forms of SB account no 50795 /
082 revealed that this account was initially opened in the name of Devangi D
Panchal on the introduction of Karvy Securities Ltd. Further, it is observed that the
names of Pravin K Shah and Bhagwanti P Shah were added to this account on the
introduction of Karvy Investors Services Ltd. Similar pattern of addition of names
to the existing accounts is observed with regard to many of the above accounts. This
Page 41 of 191
indicates that as early as June 2003 Karvy group was indulging in the practice of
introducing names at will which were added to the bank accounts of the key
operators. The same script continues later, albeit on a larger canvass.
9.9. It was further observed that the above banks accounts were used for opening
afferent demat accounts with Karvy DP in the month of June 2003. The details of
such afferent demat accounts are mentioned in the table below.
Sr. No.
Demat Client ID Name of client Address
Bank acct no Bank
Date of opening demat account
Date of closing demat account
1. 12312738 PANCHAL DIPAK J
402-403 SHASHWAT 50795/60
BHOB, Ahmedabad 6/27/2003 11/15/2005
2. 12312746 PANCHAL DINESH J
402-403 SHASHWAT 50795/60
BHOB, Ahmedabad 6/27/2003 11/15/2005
3. 12312754 PANCHAL DILIP J
402-403 SHASHWAT 50795/60
BHOB, Ahmedabad 6/27/2003 11/15/2005
4. 12312762
PANCHAL DEVANGI D
402-403 SHASHWAT 50795/77
BHOB, Ahmedabad 6/27/2003 11/15/2005
5. 12312779 PANCHAL ROOPA D
402-403 SHASHWAT 50795/60
BHOB, Ahmedabad 6/27/2003 11/15/2005
6. 12312787 PANCHAL DHRUV D
402-403 SHASHWAT 50795/61
BHOB, Ahmedabad 6/27/2003 11/15/2005
7. 12312795 PANCHAL DEVAL D
402-403 SHASHWAT 50795/61
BHOB, Ahmedabad 6/27/2003 11/15/2005
8. 12312809 PANCHAL DEVESH D
402-403 SHASHWAT 50795/61
BHOB, Ahmedabad 6/27/2003 11/15/2005
9. 12312818
PANCHAL MANUSHI D
402-403 SHASHWAT 50795/62
BHOB, Ahmedabad 6/27/2003 11/15/2005
10. 12312826 PANCHAL MOXI D
402-403 SHASHWAT 50795/67
BHOB, Ahmedabad 6/27/2003 11/15/2005
11. 12312834
PANCHAL RANCHHODLAL N
402-403 SHASHWAT 50795/67
BHOB, Ahmedabad 6/27/2003 11/15/2005
12. 12312842
PAUCHAL PRAMILABEN R
402-403 SHASHWAT 50795/63
BHOB, Ahmedabad 6/27/2003 11/15/2005
13. 12312859
PANCHAL NARMADABEN M
402-403 SHASHWAT 50795/63
BHOB, Ahmedabad 6/27/2003 11/15/2005
14. 12312867
PANCHAL BHARGAV R
402-403 SHASHWAT 50795/63
BHOB, Ahmedabad 6/27/2003 11/15/2005
15. 12312875 PANCHAL HIMA B
402-403 SHASHWAT 50795/64
BHOB, Ahmedabad 6/27/2003 11/15/2005
16. 12312883 PANCHAL MALAV B
402-403 SHASHWAT 50795/64
BHOB, Ahmedabad 6/27/2003 11/15/2005
17. 12312890
PANCHAL SRINAND B
402-403 SHASHWAT 50795/64
BHOB, Ahmedabad 6/27/2003 11/15/2005
18. 12312906 PANCHAL HETA U
402-403 SHASHWAT 50795/65
BHOB, Ahmedabad 6/27/2003 11/15/2005
19. 12312914
PANCHAL KIRITBHAI R
402-403 SHASHWAT 50795/65
BHOB, Ahmedabad 6/27/2003 11/15/2005
20. 12312922
PANCHAL CHHAYABEN K
402-403 SHASHWAT 50795/65
BHOB, Ahmedabad 6/27/2003 11/15/2005
21. 12312939
PANCHAL NARESH N
402-403 SHASHWAT 50795/66
BHOB, Ahmedabad 6/27/2003 11/15/2005
22. 12312947
PANCHAL ROOPAL N
402-403 SHASHWAT 50795/66
BHOB, Ahmedabad 6/27/2003 11/15/2005
23. 12312963 PANCHAL AYUSHI N
402-403 SHASHWAT 50795/67
BHOB, Ahmedabad 6/27/2003 11/15/2005
24. 12312970 PANCHAL 402-403 50795/67 BHOB, 6/27/2003 11/15/2005
Page 42 of 191
Sr. No.
Demat Client ID Name of client Address
Bank acct no Bank
Date of opening demat account
Date of closing demat account
NATVARLAL SHASHWAT Ahmedabad
25. 12312989
PANCHAL RAMABEN N
402-403 SHASHWAT 50795/67
BHOB, Ahmedabad 6/27/2003 11/15/2005
26. 12312998 KHALAS VIJAY G
402-403 SHASHWAT 50795/68
BHOB, Ahmedabad 6/27/2003 11/15/2005
27. 12313005 KHALAS SANJAY G
402-403 SHASHWAT 50795/68
BHOB, Ahmedabad 6/27/2003 11/15/2005
28. 12313013 KHALAS SANDIP G
402-403 SHASHWAT 50795/68
BHOB, Ahmedabad 6/27/2003 11/15/2005
29. 12313039
KHALAS GOVINDBHAI N
402-403 SHASHWAT 50795/69
BHOB, Ahmedabad 6/27/2003 11/15/2005
30. 12313048 MODI NIKUNJ B
402-403 SHASHWAT 50795/69
BHOB, Ahmedabad 6/27/2003 11/15/2005
31. 12313056 MODI HETAL N
402-403 SHASHWAT 50795/70
BHOB, Ahmedabad 6/27/2003 11/15/2005
32. 12313064
MODI MADHU BALA B
402-403 SHASHWAT 50795/70
BHOB, Ahmedabad 6/30/2003 11/15/2005
33. 12313072 MODI BABULAL S
402-403 SHASHWAT 50795/70
BHOB, Ahmedabad 6/27/2003 11/15/2005
34. 12313089
PARMAR NATVARLAL N
402-403 SHASHWAT 50795/71
BHOB, Ahmedabad 6/27/2003 11/15/2005
35. 12313097
PARMAR USHABEN N
402-403 SHASHWAT 50795/71
BHOB, Ahmedabad 6/27/2003 11/15/2005
36. 12313100
PARMAR KIRITBHAI N
402-403 SHASHWAT 50795/71
BHOB, Ahmedabad 6/27/2003 11/15/2005
37. 12313119
PARMAR RAMILABEN K
402-403 SHASHWAT 50795/72
BHOB, Ahmedabad 6/27/2003 11/15/2005
38. 12313128 PARMAR AMIT K
402-403 SHASHWAT 50795/72
BHOB, Ahmedabad 6/27/2003 11/15/2005
39. 12313136 PARMAR MONIKA K
402-403 SHASHWAT 50795/72
BHOB, Ahmedabad 6/27/2003 11/15/2005
40. 12313144 PARMAR SONIKA K
402-403 SHASHWAT 50795/73
BHOB, Ahmedabad 6/27/2003 11/15/2005
41. 12313152 PARMAR YUVRAJ K
402-403 SHASHWAT 50795/73
BHOB, Ahmedabad 6/27/2003 11/15/2005
42. 12313169 PARMAR ASHVIN N
402-403 SHASHWAT 50795/73
BHOB, Ahmedabad 6/27/2003 11/15/2005
43. 12313177
PARMAR BHANUBEN A
402-403 SHASHWAT 50795/74
BHOB, Ahmedabad 6/27/2003 11/15/2005
44. 12313185
PARMAR PRIYANSHU A
402-403 SHASHWAT 50795/74
BHOB, Ahmedabad 6/27/2003 11/15/2005
45. 12313193
PARMAR MADHUSUDAN M
402-403 SHASHWAT 50795/74
BHOB, Ahmedabad 6/27/2003 11/15/2005
46. 12313208 PARMAR KARTIK N
402-403 SHASHWAT 50795/75
BHOB, Ahmedabad 6/27/2003 11/15/2005
47. 12313216 PARMAR DONIKA N
402-403 SHASHWAT 50795/75
BHOB, Ahmedabad 6/27/2003 11/15/2005
48. 12313224
PARMAR DEVENDRABHAI K
402-403 SHASHWAT 50795/75
BHOB, Ahmedabad 6/27/2003 11/15/2005
49. 12313232
RAVAL KRISHNABEN D
402-403 SHASHWAT 50795/76
BHOB, Ahmedabad 6/30/2003 11/15/2005
50. 12313249 RAVAL VISHAKHA D
402-403 SHASHWAT 50795/77
BHOB, Ahmedabad 6/30/2003 11/15/2005
51. 12313257 RAVAL KOMAL D
402-403 SHASHWAT 50795\77
BHOB, Ahmedabad 6/30/2003 11/15/2005
52. 12313265 RAVAL DIPAK N
402-403 SHASHWAT 50795\77
BHOB, Ahmedabad 6/30/2003 11/15/2005
53. 12313273 SHAH LATA D
402-403 SHASHWAT 50795\78
BHOB, Ahmedabad 6/30/2003 11/15/2005
54. 12313280 SHAH NEELAM D
402-403 SHASHWAT 50795\78
BHOB, Ahmedabad 6/30/2003 11/15/2005
55. 12313299 SHAH SONAM D
402-403 SHASHWAT 50795\78
BHOB, Ahmedabad 6/30/2003 11/15/2005
Page 43 of 191
Sr. No.
Demat Client ID Name of client Address
Bank acct no Bank
Date of opening demat account
Date of closing demat account
56. 12313304 SHAH ZEEL D
402-403 SHASHWAT 50795\79
BHOB, Ahmedabad 6/30/2003 11/15/2005
57. 12313312 SHAH BHARAT K
402-403 SHASHWAT 50795\79
BHOB, Ahmedabad 6/30/2003 11/15/2005
58. 12313329 SHAH BHAGVANTI B
402-403 SHASHWAT 50795\79
BHOB, Ahmedabad 6/30/2003 11/15/2005
59. 12313337 SHAH NIPA B
402-403 SHASHWAT 50795\80
BHOB, Ahmedabad 6/30/2003 11/15/2005
60. 12313345 SHAH NIHIR B
402-403 SHASHWAT 50795\80
BHOB, Ahmedabad 6/30/2003 11/15/2005
61. 12313353 SHAH MUNJAL B
402-403 SHASHWAT 50795\80
BHOB, Ahmedabad 6/30/2003 11/15/2005
62. 12313360 SHAH KANTILAL K
402-403 SHASHWAT 50795\81
BHOB, Ahmedabad 6/30/2003 11/15/2005
63. 12313379 SHAH MANJULA K
402-403 SHASHWAT 50795\81
BHOB, Ahmedabad 6/30/2003 11/15/2005
64. 12313388 SHAH PRITESH K
402-403 SHASHWAT 50795\81
BHOB, Ahmedabad 6/30/2003 11/15/2005
65. 12313396 SHAH VISHAL K
402-403 SHASHWAT 50795\82
BHOB, Ahmedabad 6/30/2003 11/15/2005
66. 12313407 SHAH PRAVIN K
402-403 SHASHWAT 50795\82
BHOB, Ahmedabad 6/30/2003 11/15/2005
67. 12313415
SHAH BHAGWANTI P
402-403 SHASHWAT 50795\82
BHOB, Ahmedabad 6/30/2003 11/15/2005
68. 12313423 SHAH SURBHI P
402-403 SHASHWAT 50795\83
BHOB, Ahmedabad 6/30/2003 11/15/2005
69. 12313430 SHAH LALU P
402-403 SHASHWAT 50795\83
BHOB, Ahmedabad 6/30/2003 11/15/2005
70. 12313449 SHAH SHAILESH N
402-403 SHASHWAT 50795\83
BHOB, Ahmedabad 6/30/2003 11/15/2005
71. 12313458 SHAH JAGRUTI S
402-403 SHASHWAT 50795\84
BHOB, Ahmedabad 6/30/2003 11/15/2005
72. 12313466 SHAH ANERI S
402-403 SHASHWAT 50795\84
BHOB, Ahmedabad 6/30/2003 11/15/2005
73. 12313474 SHAH AYUSHI S
402-403 SHASHWAT 50795\84
BHOB, Ahmedabad 6/30/2003 11/15/2005
74. 12313482 SHAH ROHIT N
402-403 SHASHWAT 50795\85
BHOB, Ahmedabad 6/30/2003 11/15/2005
75. 12313499 SHAH ANJU R
402-403 SHASHWAT 50795\85
BHOB, Ahmedabad 6/30/2003 11/15/2005
76. 12313503 SHAH ROOPA R
402-403 SHASHWAT 50795\85
BHOB, Ahmedabad 6/30/2003 11/15/2005
77. 12313510 SHAH POOJA R
402-403 SHASHWAT 50795\86
BHOB, Ahmedabad 6/30/2003 11/15/2005
78. 12313529 SHAH NANCHAND K
402-403 SHASHWAT 50795\86
BHOB, Ahmedabad 6/30/2003 11/15/2005
79. 12313538 SHAH KUSUM N
402-403 SHASHWAT 50795\86
BHOB, Ahmedabad 6/30/2003 11/15/2005
80. 12313546 SHAH BHARTI V
402-403 SHASHWAT 50795\87
BHOB, Ahmedabad 6/30/2003 11/15/2005
81. 12313554 SHAH VINOD T
402-403 SHASHWAT 50795\87
BHOB, Ahmedabad 6/30/2003 11/15/2005
82. 12313562 SHAH SANDIP V
402-403 SHASHWAT 50795\87
BHOB, Ahmedabad 6/30/2003 11/15/2005
83. 12313579 SHAH JITENDRA P
402-403 SHASHWAT 50795\88
BHOB, Ahmedabad 6/30/2003 11/15/2005
84. 12313587 SHAH SANGEETA J
402-403 SHASHWAT 50795\88
BHOB, Ahmedabad 6/30/2003 11/15/2005
85. 12313595 SHAH DHIREN J
402-403 SHASHWAT 50795\88
BHOB, Ahmedabad 6/30/2003 11/15/2005
86. 12313609 SHAH MANEK J
402-403 SHASHWAT 50795\89
BHOB, Ahmedabad 6/30/2003 11/15/2005
87. 12313618 SHAH MOHAN M
402-403 SHASHWAT 50795\89
BHOB, Ahmedabad 6/30/2003 11/15/2005
Page 44 of 191
Sr. No.
Demat Client ID Name of client Address
Bank acct no Bank
Date of opening demat account
Date of closing demat account
88. 12313626 SHAH SOBHNA M
402-403 SHASHWAT 50795\89
BHOB, Ahmedabad 6/30/2003 11/15/2005
89. 12313634 SHAH SUNITA M
402-403 SHASHWAT 50795\90
BHOB, Ahmedabad 6/30/2003 11/15/2005
90. 12313642 SHAH SURBHI M
402-403 SHASHWAT 50795\90
BHOB, Ahmedabad 6/30/2003 11/15/2005
91. 12313659 SHAH NIMESH M
402-403 SHASHWAT 50795\90
BHOB, Ahmedabad 6/30/2003 11/15/2005
92. 12313667
SHAH DEVICHAND M
402-403 SHASHWAT 50795\91
BHOB, Ahmedabad 6/30/2003 11/15/2005
93. 12313675 SHAH LEELA D
402-403 SHASHWAT 50795\91
BHOB, Ahmedabad 6/30/2003 11/15/2005
94. 12313683 SHAH MAHAVIR D
402-403 SHASHWAT 50795\91
BHOB, Ahmedabad 6/30/2003 11/15/2005
95. 12313690 SHAH MAMTA D
402-403 SHASHWAT 50795\92
BHOB, Ahmedabad 6/30/2003 11/15/2005
96. 12313706 SHAH AMBICA D
402-403 SHASHWAT 50795\92
BHOB, Ahmedabad 6/30/2003 11/15/2005
97. 12313714 SHAH PAWAN D
402-403 SHASHWAT 50795\92
BHOB, Ahmedabad 6/30/2003 11/15/2005
98. 12313722 SHAH NIKITA D
402-403 SHASHWAT 50795/93
BHOB, Ahmedabad 6/30/2003 11/15/2005
99. 12313747 DINESH PANCHAL
402-403 SHASHWAT 50795/26
BHOB, Ahmedabad 6/27/2003 11/15/2005
100.12313755 DILIP PANCHAL
402-403 SHASHWAT 50795/26
BHOB, Ahmedabad 6/27/2003 11/15/2005
101.12313763 DEVANGI PANCHAL
402-403 SHASHWAT 50795/44
BHOB, Ahmedabad 6/27/2003 11/15/2005
102.12313770 ROOPA PANCHAL
402-403 SHASHWAT 50795/26
BHOB, Ahmedabad 6/27/2003 11/15/2005
103.12313789 DHRUV PANCHAL
402-403 SHASHWAT 50795/27
BHOB, Ahmedabad 6/27/2003 11/15/2005
104.12313798 DEVAL PANCHAL
402-403 SHASHWAT 50795/27
BHOB, Ahmedabad 6/27/2003 11/15/2005
105.12313802 DEVESH PANCHAL
402-403 SHASHWAT 50795/27
BHOB, Ahmedabad 6/27/2003 11/15/2005
106.12313819 MANUSHI PANCHAL
402-403 SHASHWAT 50795/28
BHOB, Ahmedabad 6/27/2003 11/15/2005
107.12313827 MOXI PANCHAL
402-403 SHASHWAT 50795/28
BHOB, Ahmedabad 6/27/2003 11/15/2005
108.12313835
RANCHHODLAL PANCHAL
402-403 SHASHWAT 50795/28
BHOB, Ahmedabad 6/27/2003 11/15/2005
109.12313843
PRAMILABEN PANCHAL
402-403 SHASHWAT 50795/29
BHOB, Ahmedabad 6/27/2003 11/15/2005
110.12313850
NARMADABEN PANCHAL
402-403 SHASHWAT 50795/29
BHOB, Ahmedabad 6/27/2003 11/15/2005
111.12313869 BHARGAV PANCHAL
402-403 SHASHWAT 50795/29
BHOB, Ahmedabad 6/27/2003 11/15/2005
112.12313878 HINA PANCHAL
402-403 SHASHWAT 50795/30
BHOB, Ahmedabad 6/27/2003 11/15/2005
113.12313886 MALAV PANCHAL
402-403 SHASHWAT 50795/30
BHOB, Ahmedabad 6/27/2003 11/15/2005
114.12313894 SRINAND PANCHAL
402-403 SHASHWAT 50795/30
BHOB, Ahmedabad 6/27/2003 11/15/2005
115.12313909 HETA PANCHAL
402-403 SHASHWAT 50795/31
BHOB, Ahmedabad 6/27/2003 11/15/2005
116.12313917
KIRITBHAI PANCHAL
402-403 SHASHWAT 50795/31
BHOB, Ahmedabad 6/27/2003 11/15/2005
117.12313925
CHHAYABEN PANCHAL
402-403 SHASHWAT 50795/31
BHOB, Ahmedabad 6/27/2003 11/15/2005
118.12313933 NARESH PANCHAL
402-403 SHASHWAT 50795/32
BHOB, Ahmedabad 6/27/2003 NA
119.12313940 ROOPAL PANCHAL
402-403 SHASHWAT 50795/32
BHOB, Ahmedabad 6/27/2003 NA
Page 45 of 191
Sr. No.
Demat Client ID Name of client Address
Bank acct no Bank
Date of opening demat account
Date of closing demat account
120.12313959 ARJAV PANCHAL
402-403 SHASHWAT 50795/32
BHOB, Ahmedabad 6/27/2003 1/5/2006
121.12313968 AYUSHI PANCHAL
402-403 SHASHWAT 50795/33
BHOB, Ahmedabad 6/27/2003 1/4/2006
122.12313976
NATVARLAL PANCHAL
402-403 SHASHWAT 50795/33
BHOB, Ahmedabad 6/27/2003 11/15/2005
123.12313984
RAMABEN PANCHAL
402-403 SHASHWAT 50795/33
BHOB, Ahmedabad 6/27/2003 11/15/2005
124.12313992 VIJAY KHALAS
402-403 SHASHWAT 50795/34
BHOB, Ahmedabad 6/27/2003 11/15/2005
125.12314008 SANJAY KHALAS
402-403 SHASHWAT 50795/31
BHOB, Ahmedabad 6/27/2003 11/15/2005
126.12314016 SANDIP KHALAS
402-403 SHASHWAT 50795/34
BHOB, Ahmedabad 6/27/2003 11/15/2005
127.12314024
RAMILABEN KHALAS
402-403 SHASHWAT 50795/35
BHOB, Ahmedabad 6/27/2003 11/15/2005
128.12314032
GOVINDBHAI KHALAS
402-403 SHASHWAT 50795/35
BHOB, Ahmedabad 6/27/2003 11/15/2005
129.12314049 NIKUNJ MODI
402-403 SHASHWAT 50795/35
BHOB, Ahmedabad 6/27/2003 11/15/2005
130.12314057 HETAL MODI
402-403 SHASHWAT 50795/36
BHOB, Ahmedabad 6/27/2003 11/15/2005
131.12314065 MADHUBALA MODI
402-403 SHASHWAT 50795/36
BHOB, Ahmedabad 6/27/2003 11/15/2005
132.12314073 BABULAL MODI
402-403 SHASHWAT 50795/36
BHOB, Ahmedabad 6/27/2003 11/15/2005
133.12314080
NATVARLAL PARMAR
402-403 SHASHWAT 50795/37
BHOB, Ahmedabad 6/27/2003 11/15/2005
134.12314099 USHABEN PARMAR
402-403 SHASHWAT 50795/37
BHOB, Ahmedabad 6/27/2003 11/15/2005
135.12314104 KIRITBHAI PARMAR
402-403 SHASHWAT 50795/37
BHOB, Ahmedabad 6/27/2003 11/15/2005
136.12314112
RAMILABEN PARMAR
402-403 SHASHWAT 50795/38
BHOB, Ahmedabad 6/27/2003 11/15/2005
137.12314129 AMIT PARMAR
402-403 SHASHWAT 50795/38
BHOB, Ahmedabad 6/27/2003 11/15/2005
138.12314137 MONIKA PARMAR
402-403 SHASHWAT 50795/38
BHOB, Ahmedabad 6/27/2003 11/15/2005
139.12314145 SONIKA PARMAR
402-403 SHASHWAT 50795/39
BHOB, Ahmedabad 6/27/2003 11/15/2005
140.12314153 YUVRAJ PARMAR
402-403 SHASHWAT 50795/39
BHOB, Ahmedabad 6/27/2003 11/15/2005
141.12314160
ASHVINKUMAR PARMAR
402-403 SHASHWAT 50795/39
BHOB, Ahmedabad 6/27/2003 11/15/2005
142.12314179
BHANUBEN PARMAR
402-403 SHASHWAT 50795/40
BHOB, Ahmedabad 6/27/2003 11/15/2005
143.12314188
PRIYANSHU PARMAR
402-403 SHASHWAT 50795/40
BHOB, Ahmedabad 6/27/2003 11/15/2005
144.12314196
MADHUSUDAN PARMAR
402-403 SHASHWAT 50795/40
BHOB, Ahmedabad 6/27/2003 11/15/2005
145.12314207 KARTIK PARMAR
402-403 SHASHWAT 50795/41
BHOB, Ahmedabad 6/27/2003 11/15/2005
146.12314215 DONIKA PARMAR
402-403 SHASHWAT 50795/41
BHOB, Ahmedabad 6/27/2003 11/15/2005
147.12314223 DEVENBHAI RAVAL
402-403 SHASHWAT 50795/41
BHOB, Ahmedabad 6/27/2003 11/15/2005
148.12314230
KRISHNABEN RAVAL
402-403 SHASHWAT 50795142
BHOB, Ahmedabad 6/27/2003 11/15/2005
149.12314249 VISHAKHA RAVAL
402-403 SHASHWAT 50795/43
BHOB, Ahmedabad 6/27/2003 11/15/2005
150.12314258 KOMAL RAVAL
402-403 SHASHWAT 50795/43
BHOB, Ahmedabad 6/27/2003 11/15/2005
151.12314266 DIPAK SHAH
402-403 SHASHWAT 50795/43
BHOB, Ahmedabad 6/27/2003 11/15/2005
Page 46 of 191
Sr. No.
Demat Client ID Name of client Address
Bank acct no Bank
Date of opening demat account
Date of closing demat account
152.12314274 LATA SHAH
402-403 SHASHWAT 50795/44
BHOB, Ahmedabad 6/27/2003 11/15/2005
153.12314282 NEELAM SHAH
402-403 SHASHWAT 50795/44
BHOB, Ahmedabad 6/27/2003 11/15/2005
154.12314299 SONAM SHAH
402-403 SHASHWAT 50795/44
BHOB, Ahmedabad 6/27/2003 11/15/2005
155.12314303 ZEEL SHAH
402-403 SHASHWAT 50795/45
BHOB, Ahmedabad 6/27/2003 11/15/2005
156.12314310 BHARAT SHAH
402-403 SHASHWAT 50795/45
BHOB, Ahmedabad 6/27/2003 11/15/2005
157.12314329 BHAGVANTI SHAH
402-403 SHASHWAT 50795/45
BHOB, Ahmedabad 6/27/2003 11/15/2005
158.12314338 NIPA SHAH
402-403 SHASHWAT 50795/46
BHOB, Ahmedabad 6/27/2003 11/15/2005
159.12314346 NIHIR SHAH
402-403 SHASHWAT 50795/46
BHOB, Ahmedabad 6/27/2003 11/15/2005
160.12314354 MUNJAL SHAH
402-403 SHASHWAT 50795/46
BHOB, Ahmedabad 6/27/2003 11/15/2005
161.12314362 KANTILAL SHAH
402-403 SHASHWAT 50795/47
BHOB, Ahmedabad 6/27/2003 11/15/2005
162.12314379 MANJULA SHAH
402-403 SHASHWAT 50795/47
BHOB, Ahmedabad 6/27/2003 11/15/2005
163.12314387 PRITESH SHAH
402-403 SHASHWAT 50795/47
BHOB, Ahmedabad 6/27/2003 11/15/2005
164.12314395 VISHAL SHAH
402-403 SHASHWAT 50795/48
BHOB, Ahmedabad 6/27/2003 11/15/2005
165.12314409 PRAVIN SHAH
402-403 SHASHWAT 50795/48
BHOB, Ahmedabad 6/27/2003 11/15/2005
166.12314418 BHAGWANTI SHAH
402-403 SHASHWAT 50795/48
BHOB, Ahmedabad 6/27/2003 11/15/2005
167.12314426 SURBHI SHAH
402-403 SHASHWAT 50795/49
BHOB, Ahmedabad 6/27/2003 11/15/2005
168.12314434 LALU SHAH
402-403 SHASHWAT 50795/49
BHOB, Ahmedabad 6/27/2003 11/15/2005
169.12314442 SHAILESH SHAH
402-403 SHASHWAT 50795/49
BHOB, Ahmedabad 6/27/2003 11/15/2005
170.12314459 JAGRUTI SHAH
402-403 SHASHWAT 50795/50
BHOB, Ahmedabad 6/27/2003 11/15/2005
171.12314467 ANERI SHAH
402-403 SHASHWAT 50795/50
BHOB, Ahmedabad 6/27/2003 11/15/2005
172.12314475 AYUSHI SHAH
402-403 SHASHWAT 50795/50
BHOB, Ahmedabad 6/27/2003 11/15/2005
173.12314483 ROHIT SHAH
402-403 SHASHWAT 50795/51
BHOB, Ahmedabad 6/27/2003 11/15/2005
174.12314490 ANJU SHAH
402-403 SHASHWAT 50795/51
BHOB, Ahmedabad 6/27/2003 11/15/2005
175.12314506 ROOPA T SHAH
402-403 SHASHWAT 50795/51
BHOB, Ahmedabad 6/27/2003 11/15/2005
176.12314514 POOJA SHAH
402-403 SHASHWAT 50795/52
BHOB, Ahmedabad 6/27/2003 11/15/2005
177.12314522 NANCHAND SHAH
402-403 SHASHWAT 50795/52
BHOB, Ahmedabad 6/27/2003 11/15/2005
178.12314539 KUSUM SHAH
402-403 SHASHWAT 50795/52
BHOB, Ahmedabad 6/27/2003 11/15/2005
179.12314547 BHARTI SHAH
402-403 SHASHWAT 50795/53
BHOB, Ahmedabad 6/27/2003 11/15/2005
180.12314555 VINOD SHAH
402-403 SHASHWAT 50795/53
BHOB, Ahmedabad 6/27/2003 11/15/2005
181.12314563 SANDIP SHAH
402-403 SHASHWAT 50795/53
BHOB, Ahmedabad 6/27/2003 11/15/2005
182.12314570 JITENDRA SHAH
402-403 SHASHWAT 50795/54
BHOB, Ahmedabad 6/27/2003 11/15/2005
183.12314589 SANGEETA SHAH
402-403 SHASHWAT 50795/54
BHOB, Ahmedabad 6/27/2003 11/15/2005
Page 47 of 191
Sr. No.
Demat Client ID Name of client Address
Bank acct no Bank
Date of opening demat account
Date of closing demat account
184.12314598 DHIREN SHAH
402-403 SHASHWAT 50795/54
BHOB, Ahmedabad 6/27/2003 11/15/2005
185.12314602 MANEK SHAH
402-403 SHASHWAT 50795/55
BHOB, Ahmedabad 6/27/2003 11/15/2005
186.12314619 MOHAN SHAH
402-403 SHASHWAT 50795/55
BHOB, Ahmedabad 6/27/2003 11/15/2005
187.12314627 SOBHNA SHAH
402-403 SHASHWAT 50795/55
BHOB, Ahmedabad 6/27/2003 11/15/2005
188.12314635 SUNITA SHAH
402-403 SHASHWAT 50795/56
BHOB, Ahmedabad 6/27/2003 11/15/2005
189.12314643 SURBHI SHAH
402-403 SHASHWAT 50795/56
BHOB, Ahmedabad 6/27/2003 11/15/2005
190.12314650 NIMESH SHAH
402-403 SHASHWAT 50795/56
BHOB, Ahmedabad 6/27/2003 11/15/2005
191.12314669 DEVICHAND SHAH
402-403 SHASHWAT 50795/57
BHOB, Ahmedabad 6/27/2003 11/15/2005
192.12314678 LEELA SHAH
402-403 SHASHWAT 50795/57
BHOB, Ahmedabad 6/27/2003 11/15/2005
193.12314686 MAHAVIR SHAH
402-403 SHASHWAT 50795/57
BHOB, Ahmedabad 6/27/2003 11/15/2005
194.12314694 MAMTA SHAH
402-403 SHASHWAT 50795/58
BHOB, Ahmedabad 6/27/2003 11/15/2005
195.12314709 AMBICA SHAH
402-403 SHASHWAT 50795/58
BHOB, Ahmedabad 6/27/2003 11/15/2005
196.12314717 PAWAN SHAH
402-403 SHASHWAT 50795/58
BHOB, Ahmedabad 6/27/2003 11/15/2005
197.12314725 NIKITA SHAH
402-403 SHASHWAT 50795/59
BHOB, Ahmedabad 6/27/2003 11/15/2005
198.12314733
DIPAK JASHVANTLAL
402-403 SHASHWAT 50795/94
BHOB, Ahmedabad 6/30/2003 11/15/2005
199.12314740
DINESH JASHVANTLAL
402-403 SHASHWAT 50795/94
BHOB, Ahmedabad 6/30/2003 11/15/2005
200.12314759 DILIP JASHVANTLAL
402-403 SHASHWAT 50795/94
BHOB, Ahmedabad 6/30/2003 11/15/2005
201.12314768
DEVANGI DIPAKBHAI
402-403 SHASHWAT 50795/111
BHOB, Ahmedabad 6/30/2003 11/15/2005
202.12314776 ROOPA DIPAK
402-403 SHASHWAT 50795/94
BHOB, Ahmedabad 6/30/2003 11/15/2005
203.12314784 DHRUV DIPAKBHAI
402-403 SHASHWAT 50795/95
BHOB, Ahmedabad 6/30/2003 11/15/2005
204.12314792 DEVAL DIPAKBHAI
402-403 SHASHWAT 50795/95
BHOB, Ahmedabad 6/30/2003 11/15/2005
205.12314805 DEVESH DIPAKBHAI
402-403 SHASHWAT 50795/95
BHOB, Ahmedabad 6/30/2003 11/15/2005
206.12314813
MANUSHI DIPAKBHAI
402-403 SHASHWAT 50795/96
BHOB, Ahmedabad 6/30/2003 11/15/2005
207.12314820 MOXI DIPAKBHAI
402-403 SHASHWAT 50795/96
BHOB, Ahmedabad 6/30/2003 11/15/2005
208.12314839
RANCHHODLAL NANALAL
402-403 SHASHWAT 50795/96
BHOB, Ahmedabad 6/30/2003 11/15/2005
209.12314848
PRAMILABEN RANCHHODLAL
402-403 SHASHWAT 50795/95
BHOB, Ahmedabad 6/30/2003 11/15/2005
210.12314856
NARMADABEN MANEKLAL
402-403 SHASHWAT 50795/97
BHOB, Ahmedabad 6/30/2003 11/15/2005
211.12314864
BHARGAV RANCHHODLAL
402-403 SHASHWAT 50795/97
BHOB, Ahmedabad 6/30/2003 11/15/2005
212.12314872
HINA BHARGAVBHAI
402-403 SHASHWAT 50795/98
BHOB, Ahmedabad 6/30/2003 11/15/2005
213.12314889
MALAV BHARGAVBHAI
402-403 SHASHWAT 50795/98
BHOB, Ahmedabad 6/30/2003 11/15/2005
214.12314897
SRIMAND BHARGAVBHAI
402-403 SHASHWAT 50795/98
BHOB, Ahmedabad 6/30/2003 11/15/2005
215.12314900
HETA UTTAMKUMAR
402-403 SHASHWAT 50795/99
BHOB, Ahmedabad 6/30/2003 11/15/2005
Page 48 of 191
Sr. No.
Demat Client ID Name of client Address
Bank acct no Bank
Date of opening demat account
Date of closing demat account
216.12314919
KIRITBHAI RASIKLAL
402-403 SHASHWAT 50795/99
BHOB, Ahmedabad 6/30/2003 11/15/2005
217.12314928
CHHAYABEN KIRITBHAI
402-403 SHASHWAT 50795/99
BHOB, Ahmedabad 6/30/2003 11/15/2005
218.12314936
NARESH NATVARLAL
402-403 SHASHWAT 50795/100
BHOB, Ahmedabad 6/30/2003 11/15/2005
219.12314944
ROOPAL NARESHBHAI
402-403 SHASHWAT 50795/100
BHOB, Ahmedabad 6/30/2003 11/15/2005
220.12314952 ARJAV NARESHBHAI
402-403 SHASHWAT 50795/100
BHOB, Ahmedabad 6/30/2003 11/15/2005
221.12314969
AYUSHI NARESHBHAI
402-403 SHASHWAT 50795/101
BHOB, Ahmedabad 6/30/2003 11/15/2005
222.12314977
NATVARLAL BHALCHAND
402-403 SHASHWAT 50795/101
BHOB, Ahmedabad 6/30/2003 11/15/2005
223.12314985
RAMABEN NATVARLAL
402-403 SHASHWAT 50795/101
BHOB, Ahmedabad 6/30/2003 11/15/2005
224.12314993 VIJAY GOVINDBHAI
402-403 SHASHWAT 50795/102
BHOB, Ahmedabad 6/30/2003 11/15/2005
225.12315003
SANJAY GOVINDBHAI
402-403 SHASHWAT 50795/102
BHOB, Ahmedabad 6/30/2003 11/15/2005
226.12315010
SANDIP GOVINDBHAI
402-403 SHASHWAT 50795/102
BHOB, Ahmedabad 6/30/2003 11/15/2005
227.12315029
RAMILABEN GOVINDBHAI
402-403 SHASHWAT 50795/103
BHOB, Ahmedabad 6/30/2003 11/15/2005
228.12315038
GOVINDBHAI NARANDAS
402-403 SHASHWAT 50795/103
BHOB, Ahmedabad 6/30/2003 11/15/2005
229.12315046 NIKUNJ BABULAL
402-403 SHASHWAT 50795\103
BHOB, Ahmedabad 6/30/2003 11/15/2005
230.12315054 HETAL NIKUNJBHAI
402-403 SHASHWAT 50795\104
BHOB, Ahmedabad 6/30/2003 11/15/2005
231.12315062
MADHUBALA BABULAL
402-403 SHASHWAT 50795/104
BHOB, Ahmedabad 6/30/2003 11/15/2005
232.12315079
BABULAL SHANTILAL
402-403 SHASHWAT 50795\104
BHOB, Ahmedabad 6/30/2003 11/15/2005
233.12315087
NATVARLAL NARSINHBHAI
402-403 SHASHWAT 50795\105
BHOB, Ahmedabad 6/30/2003 11/15/2005
234.12315095
USHABEN NATVARLAL
402-403 SHASHWAT 50795\105
BHOB, Ahmedabad 6/30/2003 11/15/2005
235.12315109
KIRITBHAI NATVARLAL
402-403 SHASHWAT 50795\105
BHOB, Ahmedabad 6/30/2003 11/15/2005
236.12315118
RAMILABEN KIRITBHAI
402-403 SHASHWAT 50795\106
BHOB, Ahmedabad 6/30/2003 11/15/2005
237.12315126 AMIT KIRITBHAI
402-403 SHASHWAT 50795\106
BHOB, Ahmedabad 6/30/2003 11/15/2005
238.12315134 MONIKA KIRITBHAI
402-403 SHASHWAT 50795\106
BHOB, Ahmedabad 6/30/2003 11/15/2005
239.12315142 SONIKA KIRITBHAI
402-403 SHASHWAT 50795\107
BHOB, Ahmedabad 6/30/2003 11/15/2005
240.12315159 YUVRAJ KIRITBHAI
402-403 SHASHWAT 50795\107
BHOB, Ahmedabad 6/30/2003 11/15/2005
241.12315167
ASHVINKUMAR NATVARLAL
402-403 SHASHWAT 50795\107
BHOB, Ahmedabad 6/30/2003 11/15/2005
242.12315175
BHANUBEN ASHVINKUMAR
402-403 SHASHWAT 50795\108
BHOB, Ahmedabad 6/30/2003 11/15/2005
243.12315183
PRIYANSHU ASHVINKUMAR
402-403 SHASHWAT 50795\108
BHOB, Ahmedabad 6/30/2003 11/15/2005
244.12315190
MADHUSUDAN NATVARLAL
402-403 SHASHWAT 50795\108
BHOB, Ahmedabad 6/30/2003 11/15/2005
245.12315206
KARTIK NATVARLAL
402-403 SHASHWAT 50795\109
BHOB, Ahmedabad 6/30/2003 11/15/2005
246.12315214
DONIKA NATVARLAL
402-403 SHASHWAT 50795\109
BHOB, Ahmedabad 6/30/2003 11/15/2005
247.12315222
DEVENBHAI KANAIYALAL
402-403 SHASHWAT 50795\109
BHOB, Ahmedabad 6/30/2003 11/15/2005
Page 49 of 191
Sr. No.
Demat Client ID Name of client Address
Bank acct no Bank
Date of opening demat account
Date of closing demat account
248.12315239
KRISHNABEN DEVENBHAI
402-403 SHASHWAT 50795/110
BHOB, Ahmedabad 6/27/2003 11/15/2005
249.12315247
VISHAKHA DEVENBHAI
402-403 SHASHWAT 50795/111
BHOB, Ahmedabad 6/27/2003 11/15/2005
250.12315255 KOMAL DEVENBHAI
402-403 SHASHWAT 50795/111
BHOB, Ahmedabad 6/27/2003 11/15/2005
251.12315263 DIPAK NANCHAND
402-403 SHASHWAT 50795/111
BHOB, Ahmedabad 6/27/2003 11/15/2005
252.12315270 LATA DIPAK
402-403 SHASHWAT 50795/112
BHOB, Ahmedabad 6/27/2003 11/15/2005
253.12315289 NEELAM DIPAK
402-403 SHASHWAT 50795/112
BHOB, Ahmedabad 6/27/2003 11/15/2005
254.12315298 SONAM DIPAK
402-403 SHASHWAT 50795/112
BHOB, Ahmedabad 6/27/2003 11/15/2005
255.12315302 ZEEL DIPAK
402-403 SHASHWAT 50795/113
BHOB, Ahmedabad 6/27/2003 11/15/2005
256.12315319
BHARAT KESHRIMAL
402-403 SHASHWAT 50795/113
BHOB, Ahmedabad 6/27/2003 11/15/2005
257.12315327
BHAGWANTI BHARAT
402-403 SHASHWAT 50795/113
BHOB, Ahmedabad 6/27/2003 11/15/2005
258.12315335 NIPA BHARAT
402-403 SHASHWAT 50795/114
BHOB, Ahmedabad 6/27/2003 11/15/2005
259.12315343 NIHIR BHARAT
402-403 SHASHWAT 50795/114
BHOB, Ahmedabad 6/27/2003 11/15/2005
260.12315350 MUNJAL BHARAT
402-403 SHASHWAT 50795/114
BHOB, Ahmedabad 6/27/2003 11/15/2005
261.12315369
KANTILAL KESHRIMAL
402-403 SHASHWAT 50795/115
BHOB, Ahmedabad 6/27/2003 11/15/2005
262.12315378
MANJULA KANTILAL
402-403 SHASHWAT 50795/115
BHOB, Ahmedabad 6/27/2003 11/15/2005
263.12315386 PRITESH KANTILAL
402-403 SHASHWAT 50795/115
BHOB, Ahmedabad 6/27/2003 11/15/2005
264.12315394 VISHAL KANTILAL
402-403 SHASHWAT 50795/116
BHOB, Ahmedabad 6/27/2003 11/15/2005
265.12315409 PRAVIN KANTILAL
402-403 SHASHWAT 50795/116
BHOB, Ahmedabad 6/27/2003 11/15/2005
266.12315417
BHAGWANTI PRAVIN
402-403 SHASHWAT 50795/116
BHOB, Ahmedabad 6/27/2003 11/15/2005
267.12315425 SURBHI PRAVIN
402-403 SHASHWAT 50795/117
BHOB, Ahmedabad 6/27/2003 11/15/2005
268.12315433 LALU PRAVIN
402-403 SHASHWAT 50795/117
BHOB, Ahmedabad 6/27/2003 12/30/2005
269.12315440
SHAILESH NANCHAND
402-403 SHASHWAT 50795/117
BHOB, Ahmedabad 6/27/2003 11/15/2005
270.12315459 JAGRUTI SHAILESH
402-403 SHASHWAT 50795/118
BHOB, Ahmedabad 6/27/2003 11/15/2005
271.12315468 ANERI SHAILESH
402-403 SHASHWAT 50795/118
BHOB, Ahmedabad 6/27/2003 11/15/2005
272.12315476 AYUSHI SHAILESH
402-403 SHASHWAT 50795/118
BHOB, Ahmedabad 6/27/2003 11/15/2005
273.12315484 ROHIT NANCHAND
402-403 SHASHWAT 50795/119
BHOB, Ahmedabad 6/27/2003 11/15/2005
274.12315492 ANJU ROHIT
402-403 SHASHWAT 50795/119
BHOB, Ahmedabad 6/27/2003 11/15/2005
275.12315505 ROOPA ROHIT
402-403 SHASHWAT 50795/119
BHOB, Ahmedabad 6/27/2003 11/15/2005
276.12315513 POOJA ROHIT
402-403 SHASHWAT 50795/120
BHOB, Ahmedabad 6/27/2003 11/15/2005
277.12315520 NANCHAND KALUJI
402-403 SHASHWAT 50795/120
BHOB, Ahmedabad 6/27/2003 11/15/2005
278.12315539 KUSUM NANCHAND
402-403 SHASHWAT 50795/120
BHOB, Ahmedabad 6/27/2003 11/15/2005
279.12315548 BHARTI VINOD
402-403 SHASHWAT 50795/121
BHOB, Ahmedabad 6/27/2003 11/15/2005
Page 50 of 191
Sr. No.
Demat Client ID Name of client Address
Bank acct no Bank
Date of opening demat account
Date of closing demat account
280.12315556
VINOD TILAKCHAND
402-403 SHASHWAT 50795/121
BHOB, Ahmedabad 6/27/2003 11/15/2005
281.12315564 SANDIP VINOD
402-403 SHASHWAT 50795/121
BHOB, Ahmedabad 6/27/2003 11/15/2005
282.12315572 JITENDRA PUKHRAJ
402-403 SHASHWAT 50795/122
BHOB, Ahmedabad 6/27/2003 11/15/2005
283.12315589
SANGEETA JITENDRA
402-403 SHASHWAT 50795/122
BHOB, Ahmedabad 6/27/2003 11/15/2005
284.12315597 DHIREN JITENDRA
402-403 SHASHWAT 50795/122
BHOB, Ahmedabad 6/27/2003 11/15/2005
285.12315600 MANEK JITENDRA
402-403 SHASHWAT 50795/123
BHOB, Ahmedabad 6/27/2003 11/15/2005
286.12315619 MOHAN MANGILAL
402-403 SHASHWAT 50795/123
BHOB, Ahmedabad 6/27/2003 11/15/2005
287.12315628 SOBHNA MOHAN
402-403 SHASHWAT 50795/123
BHOB, Ahmedabad 6/27/2003 11/15/2005
288.12315636 SUNITA MOHAN
402-403 SHASHWAT 50795/124
BHOB, Ahmedabad 6/27/2003 11/15/2005
289.12315644 SURBHI MOHAN
402-403 SHASHWAT 50795/124
BHOB, Ahmedabad 6/27/2003 11/15/2005
290.12315652 NIMISH MOHAN
402-403 SHASHWAT 50795/124
BHOB, Ahmedabad 6/27/2003 11/15/2005
291.12315669
DEVICHAND MOHAN
402-403 SHASHWAT 50795/125
BHOB, Ahmedabad 6/27/2003 11/15/2005
292.12315677 LEELA DEVICHAND
402-403 SHASHWAT 50795/125
BHOB, Ahmedabad 6/27/2003 11/15/2005
293.12315685
MAHAVIR DEVICHAND
402-403 SHASHWAT 50795/125
BHOB, Ahmedabad 6/27/2003 11/15/2005
294.12315693
MAMTA DEVICHAND
402-403 SHASHWAT 50795/126
BHOB, Ahmedabad 6/27/2003 11/15/2005
295.12315708
AMBICA DEVICHAND
402-403 SHASHWAT 50795/126
BHOB, Ahmedabad 6/27/2003 11/15/2005
296.12315716 PAWAN DEVICHAND
402-403 SHASHWAT 50795/126
BHOB, Ahmedabad 6/27/2003 11/15/2005
297.12315724 NIKITA DEVICHAND
402-403 SHASHWAT 50795/127
BHOB, Ahmedabad 6/27/2003 11/15/2005
9.10. The 297 demat accounts indicated in the table above were opened by Karvy DP on
June 27 / 30, 2003. The bank account no. 50795 that was indicated as the bank
account of the dematerialized account-holders was closed on October 27, 2003.
However, these demat accounts continued to be operative till November 15, 2005
(when these were closed pursuant to verification by Karvy DP in the wake of SEBI
examination of the matter of IPO irregularities). These 297 demat accounts were
part of the 37,240 afferent accounts in NSDL identified by SEBI.
9.11. Thus, it may be seen that Karvy had introduced the bank account no.50795 of the
key operator to BhOB, Ahmedabad. Thereafter, Karvy had introduced two
additional names to the bank account. Then, Karvy DP had opened afferent
dematerialized accounts indicating the bank account no.50795 and the
Page 51 of 191
dematerialized accounts continued to be held with Karvy DP after the closure of the
bank accounts.
9.12. It appears that Karvy had introduced various such bank accounts to BhOB,
Ahmedabad branch. The observations emerging from an examination of one such
account no.54119 is narrated below:
9.13. Introduction of Bank account no.54119 with BhOB, Ahmedabad by Karvy
It was observed that savings bank account no 54119 in the name and style of
“Devangi Dipakbhai Panchal - GROUP ACCOUNT” was introduced by Karvy
Securities Ltd. on December 4, 2003. From the bank account opening form, this is
seen to be a GROUP ACCOUNT of Devangi Panchal. There were no specific
names indicated as joint account holders. Further, this bank account was closed on
April 24, 2004.
9.14. In this context it may be mentioned that Karvy DP in its reply dated May 19, 2007
to the post-enquiry show-cause notice dated May 4, 2007, had stated that “The Idea
Paper and process flow submitted to BhOB clearly mentions that the proposal is for
financing investors who wish to subscribing book building issue of Maruti IPO
only.” It may be noted the Public Issue of Maruti closed in June 2003 whereas the
subject bank account number 54119 was introduced by Karvy to BhOB Ahmedabad
on December 04,2003. Therefore, it is clear that the arrangement between Karvy
and BhOB continued even after the Maruti IPO.
9.15. Based on examination of the details of afferent dematerialized accounts held with
Karvy DP, it is observed that 3450 afferent demat accounts pertaining to the key
operator, Roopal Panchal had indicated their bank account as BHOB bank account
no. 54119. These demat accounts were part of the 29,309 afferent accounts held
with Karvy DP on NSDL. It is seen that these dematerialized accounts had been
opened on various dates during December, 2003 / January, 2004.
Page 52 of 191
9.16. Though the bank account no.54119 was closed on April 24, 2004, the
corresponding 3450 afferent demat accounts continued to be operative till
November 15, 2005. On November 15, 2005, Karvy DP closed these dematerialized
accounts pursuant to verification conducted in the wake of SEBI preliminary
enquiry into the IPO irregularities. The details of 3450 afferent demat accounts held
with Karvy DP with bank account no 54119 are given below:
Starting Name
Last Name No. Of Demat Accts.
Date Of Opening Bank Account No.
Daksha Luhar Induben Luhar 600 December 17, 2003 54119 / 1 to 54119 /600
Daksha Pari Induben Pari 600 December 17, 2003 54119 / 451 to 54119 / 950
Daksha Mistri Induben Mistri 600 January 5/6 , 2004 54119 / 1 to 54119 / 600
Daksha Shroff Induben Shroff 600 January 5/6 , 2004 54119 / 601 to 54119 / 1200
Dasharath Seth Badri Seth 50 February 18, 2004 54119 / 2201 to 54119 /2250
Kunal Seth** Babitha Seth 1000 January 5 /6, 2004 54119 / 1201 to 54119 / 2200
Total 3450 ** - includes the series of names from ‘SURESH SETH’ to ‘ADITI SETH’ which would
be discussed in detail later for the successive repeat appearances in various morphed
forms.
9.17. Thus, the bank account number 54119 held with BhOB, Ahmedabad had resulted in
3450 dematerialized accounts with Karvy DP. It may be seen that the
dematerialized account-holders were having the same surnames. A sample of 100
such dematerialized account-holders sharing the surname of ‘Luhar’ is given below:
Sr. No.
CLIENT ID
DP NAME
NAME OF SOURCE CLIENT
ADDRESS OF SOURCE CLIENT
DATE OF OPENING OF DEMAT ACCOUNT
DATE OF CLOSURE OF DEMAT (IF APPLICABLE)
ACCOUNT STATUS
1. 13015876 KARVY STOCK BROKING LIMITED
DAKSHA LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
2. 13015884 KARVY STOCK BROKING LIMITED
DAKSHITA LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
Page 53 of 191
Sr. No.
CLIENT ID
DP NAME
NAME OF SOURCE CLIENT
ADDRESS OF SOURCE CLIENT
DATE OF OPENING OF DEMAT ACCOUNT
DATE OF CLOSURE OF DEMAT (IF APPLICABLE)
ACCOUNT STATUS
3. 13015892 KARVY STOCK BROKING LIMITED
DAMINI LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
4. 13015905 KARVY STOCK BROKING LIMITED
DARPITA LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
5. 13015913 KARVY STOCK BROKING LIMITED
DARSHA LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
6. 13015920 KARVY STOCK BROKING LIMITED
DARSHI LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
7. 13015939 KARVY STOCK BROKING LIMITED
DARSHIKA LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
8. 13015948 KARVY STOCK BROKING LIMITED
DARSHINI LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
9. 13015956 KARVY STOCK BROKING LIMITED
DEHAL LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
10. 13015964 KARVY STOCK BROKING LIMITED
DEVAKI LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
11. 13015972 KARVY STOCK BROKING LIMITED
DEVANA LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
12. 13015989 KARVY STOCK BROKING LIMITED
DEVANGANA LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
13. 13015997 KARVY STOCK BROKING LIMITED
DEVANGI LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
14. 13016004 KARVY STOCK BROKING LIMITED
DEVANI LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
15. 13016012 KARVY STOCK BROKING LIMITED
DEVANSHI LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
16. 13016029 KARVY STOCK BROKING LIMITED
DEVIKA LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
17. 13016037 KARVY STOCK BROKING LIMITED
DEVYANI LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
Page 54 of 191
Sr. No.
CLIENT ID
DP NAME
NAME OF SOURCE CLIENT
ADDRESS OF SOURCE CLIENT
DATE OF OPENING OF DEMAT ACCOUNT
DATE OF CLOSURE OF DEMAT (IF APPLICABLE)
ACCOUNT STATUS
18. 13016045 KARVY STOCK BROKING LIMITED
DIPALI LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
19. 13016053 KARVY STOCK BROKING LIMITED
DIPANGI LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
20. 13016060 KARVY STOCK BROKING LIMITED
DIPTI LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
21. 13016079 KARVY STOCK BROKING LIMITED
DITI LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
22. 13016088 KARVY STOCK BROKING LIMITED
DIVENTI LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
23. 13016096 KARVY STOCK BROKING LIMITED
DIVITA LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
24. 13016107 KARVY STOCK BROKING LIMITED
DIVYA LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
25. 13016115 KARVY STOCK BROKING LIMITED
DWIPA LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
26. 13016123 KARVY STOCK BROKING LIMITED
DAKSHANT LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
27. 13016130 KARVY STOCK BROKING LIMITED
DAKSHESH LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
28. 13016149 KARVY STOCK BROKING LIMITED
DARPESH LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
29. 13016158 KARVY STOCK BROKING LIMITED
DARSH LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
30. 13016166 KARVY STOCK BROKING LIMITED
DARSHIL LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
31. 13016174 KARVY STOCK BROKING LIMITED
DARSHIT LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
32. 13016182 KARVY STOCK BROKING LIMITED
DEVPIYA LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
Page 55 of 191
Sr. No.
CLIENT ID
DP NAME
NAME OF SOURCE CLIENT
ADDRESS OF SOURCE CLIENT
DATE OF OPENING OF DEMAT ACCOUNT
DATE OF CLOSURE OF DEMAT (IF APPLICABLE)
ACCOUNT STATUS
33. 13016199 KARVY STOCK BROKING LIMITED
DESHAL LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
34. 13016203 KARVY STOCK BROKING LIMITED
DEV LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
35. 13016210 KARVY STOCK BROKING LIMITED
DEVAJ LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
36. 13016229 KARVY STOCK BROKING LIMITED
DEVAJYA LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
37. 13016238 KARVY STOCK BROKING LIMITED
DEVAL LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
38. 13016246 KARVY STOCK BROKING LIMITED
DEVAM LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
39. 13016254 KARVY STOCK BROKING LIMITED
DEVANG LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
40. 13016262 KARVY STOCK BROKING LIMITED
DEVARSH LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
41. 13016279 KARVY STOCK BROKING LIMITED
DEVAT LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
42. 13016287 KARVY STOCK BROKING LIMITED
DEVENDRA LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
43. 13016295 KARVY STOCK BROKING LIMITED
DEVESH LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
44. 13016309 KARVY STOCK BROKING LIMITED
DEVKARAN LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
45. 13016318 KARVY STOCK BROKING LIMITED
DHRUV LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
46. 13016326 KARVY STOCK BROKING LIMITED
DIGESH LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
47. 13016334 KARVY STOCK BROKING LIMITED
DIVAKAR LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
Page 56 of 191
Sr. No.
CLIENT ID
DP NAME
NAME OF SOURCE CLIENT
ADDRESS OF SOURCE CLIENT
DATE OF OPENING OF DEMAT ACCOUNT
DATE OF CLOSURE OF DEMAT (IF APPLICABLE)
ACCOUNT STATUS
48. 13016342 KARVY STOCK BROKING LIMITED
DRASHYA LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
49. 13016359 KARVY STOCK BROKING LIMITED
DRUMESH LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
50. 13016367 KARVY STOCK BROKING LIMITED
DRUMIL LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/17/2003 11/15/2005 CLOSED
51. 13021373 KARVY STOCK BROKING LIMITED
SAJAN LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
52. 13021380 KARVY STOCK BROKING LIMITED
SATYAM LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
53. 13021399 KARVY STOCK BROKING LIMITED
SATEN LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
54. 13021404 KARVY STOCK BROKING LIMITED
SANNI LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
55. 13021412 KARVY STOCK BROKING LIMITED
SATYAJIT LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
56. 13021429 KARVY STOCK BROKING LIMITED
SARACHI LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
57. 13021437 KARVY STOCK BROKING LIMITED
SACHIN LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
58. 13021445 KARVY STOCK BROKING LIMITED
SAMIP LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
59. 13021453 KARVY STOCK BROKING LIMITED
SARJIT LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
60. 13021460 KARVY STOCK BROKING LIMITED
SALENDRA LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
61. 13021479 KARVY STOCK BROKING LIMITED
SASHIR LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
62. 13021488 KARVY STOCK BROKING LIMITED
SANGESH LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
Page 57 of 191
Sr. No.
CLIENT ID
DP NAME
NAME OF SOURCE CLIENT
ADDRESS OF SOURCE CLIENT
DATE OF OPENING OF DEMAT ACCOUNT
DATE OF CLOSURE OF DEMAT (IF APPLICABLE)
ACCOUNT STATUS
63. 13021496 KARVY STOCK BROKING LIMITED
SAMYA LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
64. 13021507 KARVY STOCK BROKING LIMITED
SANDAN LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
65. 13021515 KARVY STOCK BROKING LIMITED
SIMIT LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
66. 13021523 KARVY STOCK BROKING LIMITED
SAVAN LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
67. 13021530 KARVY STOCK BROKING LIMITED
SARTH LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
68. 13021549 KARVY STOCK BROKING LIMITED
SOMIL LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
69. 13021558 KARVY STOCK BROKING LIMITED
SEHAL LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
70. 13021566 KARVY STOCK BROKING LIMITED
SURAJ LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
71. 13021574 KARVY STOCK BROKING LIMITED
SPAND LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
72. 13021582 KARVY STOCK BROKING LIMITED
SVEJ LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
73. 13021599 KARVY STOCK BROKING LIMITED
SAUNIL LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
74. 13021603 KARVY STOCK BROKING LIMITED
SAUMYA LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
75. 13021610 KARVY STOCK BROKING LIMITED
SAURIN LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
76. 13021629 KARVY STOCK BROKING LIMITED
MANJUALA LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
77. 13021638 KARVY STOCK BROKING LIMITED
RASIKLAL LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
Page 58 of 191
Sr. No.
CLIENT ID
DP NAME
NAME OF SOURCE CLIENT
ADDRESS OF SOURCE CLIENT
DATE OF OPENING OF DEMAT ACCOUNT
DATE OF CLOSURE OF DEMAT (IF APPLICABLE)
ACCOUNT STATUS
78. 13021646 KARVY STOCK BROKING LIMITED
POOJA LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
79. 13021654 KARVY STOCK BROKING LIMITED
VISHAL LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
80. 13021662 KARVY STOCK BROKING LIMITED
DAKSHA LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
81. 13021679 KARVY STOCK BROKING LIMITED
HANSA LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
82. 13021687 KARVY STOCK BROKING LIMITED
NARENDRA LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
83. 13021695 KARVY STOCK BROKING LIMITED
KUNDANBEN LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
84. 13021709 KARVY STOCK BROKING LIMITED
GITABEN LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
85. 13021718 KARVY STOCK BROKING LIMITED
NIRUBEN LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
86. 13021726 KARVY STOCK BROKING LIMITED
SUNITA LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
87. 13021734 KARVY STOCK BROKING LIMITED
ALPA LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
88. 13021742 KARVY STOCK BROKING LIMITED
AARTI LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
89. 13021759 KARVY STOCK BROKING LIMITED
HETAL LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
90. 13021767 KARVY STOCK BROKING LIMITED
BINDU LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
91. 13021775 KARVY STOCK BROKING LIMITED
DIPTI LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
92. 13021783 KARVY STOCK BROKING LIMITED
BHAKTI LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
Page 59 of 191
Sr. No.
CLIENT ID
DP NAME
NAME OF SOURCE CLIENT
ADDRESS OF SOURCE CLIENT
DATE OF OPENING OF DEMAT ACCOUNT
DATE OF CLOSURE OF DEMAT (IF APPLICABLE)
ACCOUNT STATUS
93. 13021790 KARVY STOCK BROKING LIMITED
HIREN LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
94. 13021806 KARVY STOCK BROKING LIMITED
NILESH LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
95. 13021814 KARVY STOCK BROKING LIMITED
URVASI LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
96. 13021822 KARVY STOCK BROKING LIMITED
AMIT LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
97. 13021839 KARVY STOCK BROKING LIMITED
DAKSHA LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
98. 13021847 KARVY STOCK BROKING LIMITED
RADHIKA LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
99. 13021855 KARVY STOCK BROKING LIMITED
RAVI LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
100. 13021863 KARVY STOCK BROKING LIMITED
INDUBEN LUHAR
402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
12/16/2003 11/16/2005 CLOSED
9.18. From the above discussions, it may be noted that Karvy had introduced a bank
account to BhOB, Ahmedabad during June 2003 and thereafter introduced
another bank account to BhOB, Ahmedabad during December 2003.
Additional names were added to each of these bank accounts and in certain
instances, the addition of the names was certified by Karvy. Using these bank
accounts and the names added thereto, thousands of dematerialized accounts
were opened with Karvy DP. These dematerialized accounts were fake
accounts pertaining to the key operators. While the bank accounts were closed
during the year 2004, the dematerialized accounts continued to exist till
November – December 2005, when they were closed pursuant to verification of
genuineness by Karvy DP in the wake SEBI preliminary enquiry into the IPO
irregularities.
Page 60 of 191
9.19. Bank Accounts introduced by Karvy to IOB
Subsequent to entering into an arrangement with BhOB and introducing the bank
accounts of key operators and afferent entities for availing IPO finance, it was
found that Karvy had entered into an arrangement with IOB for the same purpose.
As per the arrangement of Karvy DP with IOB, IOB provided IPO finance to the
persons who had their dematerialized accounts either with the DP IOB or with
Karvy DP. Pursuant the arrangement with IOB, it was found that Karvy DP had
introduced 40 bank accounts of the key operators Roopal Panchal and Kelan Atul
Doshi. The details are narrated below:
9.20. During the verifications conducted by SEBI at the Indian Overseas Bank, Thaltej
branch, vide letter dated March 4, 2006, at para 4, IOB submitted a list of 37 saving
account numbers (which includes the account no 12140 taken for detailed
discussions later) and names of saving account holders belonging to Roopal Panchal
group. Thereafter, IOB vide letter dated October 13, 2006 submitted copies of 39
account opening forms containing list of 50 names attached with the account
opening forms. Based on the details above, the tally of 40 accounts with list of 50
names added is set out in the table hereinunder.
9.21. A perusal of the 40 IOB bank account opening forms shows that 19 savings bank
accounts, pertaining to the key operators Roopal Panchal and Kelan Atul Doshi,
were introduced by Karvy Stock Broking Ltd and a list of 50 names attached with
these forms were also certified by Karvy stock Broking Ltd. The remaining 21
saving bank accounts (40 nos. – 19 nos.) pertaining to Roopal Panchal were not
introduced by Karvy stock broking Ltd. In respect of these 21 savings bank
accounts it was observed that a list of 50 names were attached to each account and
the list attached to as many as 19 savings bank accounts were certified by Karvy
Consultants Ltd. (except in 2 cases) with the rubber stamp of Karvy Consultants
and signature of Karvy’s official affixed on the list of 50 names. The list of 40
bank accounts held with IOB Thaltej Branch is given below.
Page 61 of 191
IOB Thaltej Branch Bank Accounts
Sr No.
Name of the Bank Account Holder Bank Account No
Date of Opening Bank Account
Name of the Introducer
Remark
1. Roopal Naresh Bhai Panchal and 50 others List of 50 applicants attached starting with DAKSHA PANCHAL To DRUMIL PANCHAL
11954 09.10.2004 Deepak J Panchal – SB 11407
-
2. Arjav N Panchal and Roopal Nareshbhai Panchal List of 50 applicants attached starting with MADHURI PANCHAL To PADMA PANCHAL
11969 11.10.2004 - KCL had identified the list of name by affixing a signature and rubber stamp.
3. Narmadaben M Panchal and Roopal N Panchal List of 50 applicants attached starting with PADMINI PANCHAL To DILESH PANCHAL
11970 11.10.2004 - KCL had identified the list of name by affixing a signature and rubber stamp.
4. Ranchhodlal N Panchal and Roopal Naresh Bhai Panchal List of 50 applicants attached starting with DILIP PANCHAL To HANISHA PANCHAL
11971 11.10.2004 SB 11407 (Dipak Panchal)
KCL had identified the list of name by affixing a signature and rubber stamp
5. Naresh N Panchal and Roopal Naresh Bhai Panchal List of 50 applicants attached starting with PANCHAL To DRUMIL PANCHAL
11972 11.10.2004 SB 11407 (Dipak Panchal)
KCL had identified the list of name by affixing a signature and rubber stamp
6. Devangi D Panchal and Roopal Naresh Bhai Panchal List of 50 applicants attached starting with SAMAR PANCHAL To UJAS PANCHAL
11973 11.10.2004 SB 11407 (Dipak Panchal)
KCL had identified the list of name by affixing a signature and rubber stamp
7. Dipak J Panchal and Roopal Naresh Bhai Panchal list of 50 applicants attached starting with KANWAL PANCHAL To NAMRESH PANCHAL
11974 11.10.2004 SB 11407 (Dipak Panchal)
KCL had identified the list of name by affixing a signature and rubber stamp
8. Nikunj B Modi and Roopal Naresh Bhai Panchal List of 50 applicants attached starting with UJJVAL PANCHAL To KANDAR PANCHAL
11975 11.10.2004 - KCL had identified the list of name by affixing a signature and rubber stamp
9. Pramilaben R Panchal and Roopal Naresh Bhai Panchal List of 50 applicants attached starting with AJEY PANCHAL To NAREN MODI
11976 11.10.2004 SB 11407 (Dipak Panchal)
KCL had identified the list of name by affixing a signature and rubber stamp
10. Vijay G Kalas and Roopal N Panchal List of 50 applicants attached starting with NANDAN PANCHAL To AJAY PANCHAL
11977 11.10.2004 SB 11407 (Dipak Panchal)
KCL had identified the list of name by affixing a signature and rubber stamp
Page 62 of 191
Sr No.
Name of the Bank Account Holder Bank Account No
Date of Opening Bank Account
Name of the Introducer
Remark
11. Roopal Naresh Bhai Panchal and 50 others List of 50 applicants attached starting with BANSI SETH To BEENA SETH
11982 11.10.2004 SB 11407 (Dipak Panchal)
KCL had identified the list of name by affixing a signature and rubber stamp
12. Roopal Nareshb bhai Panchal List of 50 applicants attached starting with DIPAK JASVANTLAL To DEVENBHAI KANAIYALAL
11983 11.10.2004 SB 11407 (Dipak Panchal)
KCL had identified the list of name by affixing a signature and rubber stamp
13. Govindbhai N Khala and Roopal N Panchal List of 50 applicants attached starting with HASIT SETH To KAMALA SETH
11984 11.10.2004 SB 11407 (Dipak Panchal)
KCL had identified the list of name by affixing a signature and rubber stamp
14. Ramilaben G Kalas and Roopal N Panchal List of 50 applicants attached starting with LITESH SETH To SHAILESH SETH
11985 11.10.2004 SB 11407 (Dipak Panchal)
KCL had identified the list of name by affixing a signature and rubber stamp
15. Khalas Sanjay Govindbhai and Roopal N Panchal List of 50 applicants attached starting with BIMAL SETH To DISHIT SETH
11986 11.10.2004 SB 11407 (Dipak Panchal)
KCL had identified the list of name by affixing a signature and rubber stamp
16. Sandeep G Kalas and Roopal N Panchal List of 50 applicants attached starting with AMRIT SETH To BRAHMI SETH
11987 11.10.2004 SB 11407 (Dipak Panchal)
KCL had identified the list of name by affixing a signature and rubber stamp
17. Modi Babulal S and Roopal N Panchal List of 50 applicants attached starting with DHAVAL SETH To TIRTHAL SETH
11988 11.10.2004 SB 11407 (Dipak Panchal)
KCL had identified the list of name by affixing a signature and rubber stamp
18. Modi Madhubala B and Roopal N Panchal List of 50 applicants attached starting with LAPESH SETH To LAVANYA SETH
11989 11.10.2004 SB 11407 (Dipak Panchal)
KCL had identified the list of name by affixing a signature and rubber stamp
19. Hetal N Modi and Roopal N Panchal List of 50 applicants attached starting with NAINESH SETH To ALKA SETH
11990 11.10.2004 SB 11407 (Dipak Panchal)
KCL had identified the list of name by affixing a signature and rubber stamp
20. Hinaben B Panchal and Roopal N Panchal List of 50 applicants attached starting with ANJAL KADIA To VEDANT KADIA
12000 13.10.2004 SB 11407 (Dipak Panchal)
KCL had identified the list of name by affixing a signature and rubber stamp
21. Kantilal J Shah and Roopal N Panchal List of 50 applicants attached starting with RELIKA KADIA To ANITA KADIA
12001 13.10.2004 SB 11407 (Dipak Panchal)
-
22. Kelan Atul Doshi and 50 others 12004 N.A. KSBL KSBL had identified the list of
Page 63 of 191
Sr No.
Name of the Bank Account Holder Bank Account No
Date of Opening Bank Account
Name of the Introducer
Remark
List of 50 applicants attached starting with DARPAN RAJESH SHAH To NEHA MANILAL THAKKAR
name by affixing a signature and rubber stamp
23. Roopal N Panchal & DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with BADRI SHROFF to MAHENDRA SHROFF
12131
9.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp
24. ROOPAL N PANCHAL& DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with MAHIPAL SHROFF to HEJHAL SHROFF
12132
9.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp
25. ROOPAL N PANCHAL& DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with HELENA SHROFF to KANAK SHROFF
12133
9.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp
26. ROOPAL N PANCHAL7 DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with KAPIL SHROFF to CHANDAN SHROFF
12134
9.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp
27. ROOPAL N PANCHAL& DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with CHANDRA SHROFF to RAMANI SHROFF
12135
9.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp
28. ROOPAL N PANCHAL& DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with RASHMI SHROFF to AGRIKA SHROFF
12136
9.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp
29. ROOPAL N PANCHAL& DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with AISHVARYA SHROFF to VIDUR SHROFF
12137
9.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp
30. ROOPAL N PANCHAL& DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with VINAT SHROFF to AMIT SHROFF
12138
9.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp
31. ROOPAL N PANCHAL& DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting
12139
9.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp
Page 64 of 191
Sr No.
Name of the Bank Account Holder Bank Account No
Date of Opening Bank Account
Name of the Introducer
Remark
with RADHIKA SHROFF to NIRMAN SETH
32. ROOPAL N PANCHAL DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with SURESH SETH to ADITI SETH
12140
9.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp
33. ROOPAL N PANCHAL& DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with RAGHU SHROFF to NALANDA SHROFF
12145
10.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp
34. ROOPAL N PANCHAL & DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with DAKSHANT SHROFF to MUSKAN SHROFF
12146
10.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp
35. ROOPAL N PANCHAL& DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with NAMRATA SHROFF to BADRESH SHROFF
12147
10.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp
36. ROOPAL N PANCHAL& DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with NITIN DABHI to ROMI DABHI
12148
10.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp
37. ROOPAL N PANCHAL& DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with TVATA DABHI to BHAGYESH DABHI
12149
10.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp
38. ROOPAL N PANCHAL& DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with DHIREN DABHI to TISHA DABHI
12150
10.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp
39. ROOPAL N PANCHAL& DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with KAHAN DABHI to MANTHAN DABHI
12151
10.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp
40. ROOPAL N PANCHAL& DEVANGI DIPAKBHAI PANCHAL list of 22 applicants attached starting with NRUPAL DABHI to ALKA DABHI list of 20 applicants attached starting
12152
10.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp
Page 65 of 191
Sr No.
Name of the Bank Account Holder Bank Account No
Date of Opening Bank Account
Name of the Introducer
Remark
with DARSHI SHROFF to DWIPA SHROFF
9.22. When KSBL introduced the said accounts in March 2005, it was not a DP.
9.23. From the above table, it may be seen that in most of the instances, the 50 account-
holders added to each bank account number were sharing the same surnames. The
names added to the bank accounts were in the same order as that in which the
dematerialized accounts were held with Karvy DP. For instance, the list of 50
names added to the bank account no. 11954, began with Daksha Panchal and ended
with Drumil Panchal. It may be recalled that, as narrated in an earlier part of this
order, in the set of 100 dematerialized account-holders of Karvy DP having the
surname of ‘Luhar’, the names of ‘Daksha’ to ‘Drumil’ appeared as the first 50
names. Further, in many instances, the bank accounts to which the 50 names were
added were bearing continuous numbers. It is observed that such an arrangement
was made for availing IPO finance from IOB.
9.24. On perusal of the documents pertaining to the bank accounts, it is seen that all the
signatures have been made with the same pen and by the same person in one go. It
may be noted that all the names contained in the list attached to the application
forms had dematerialized accounts with Karvy DP and had been identified as
afferent accounts.
9.25. In this regard, I note that at para 14.10 of its reply dated May 19, 2007, Karvy DP
stated “It is not understood as to on what basis it has been held that KCL had
certified that all the respective applicants are maintaining their demat accounts with
them and that KCL had also certified their signatures. For any such certification,
any person of normal intelligence would have sought the demat account number
along with the name and signature, which is not the case in the list that has been
brought out.”
Page 66 of 191
9.26. In this context, I note that the DP in its appeal memorandum (Appeal NO. 92 of
2006) inter alia stated that “… … … .. the Appellant had not introduced the said 50
clients to IOB Thaltej. The appellant has only certified pursuant to IPO sub- broker,
that the said 50 demat accounts with the Appellant. It is submitted that all the said
50 clients had, as per appellant’s record, bank accounts with BHOB. Therefore, the
certification given by the Appellant was for existence of demat account as sought to
be suggested”.
9.27. The submissions of Karvy DP in its reply dated May 19, 2007 contradicts the earlier
submissions made by it before the Hon’ble SAT. In any case, I note that the bank
account opening forms did contain enclosures listing out the dematerialized account
particulars of the 50 names added to the IOB bank account.Also, the names added
to the bank accounts were in the same order as that in which the dematerialized
accounts were held with Karvy DP. Therefore, the denial of Karvy that it did not
certify to IOB that the 50 names added to the bank accounts had dematerialized
accounts with Kavy DP is merely a denial of convenience.
9.28. Observations on Savings Bank Account No. 12140 with IOB, Ahmedabad
Introduced By Karvy
Out of the 19 bank accounts of Roopal Panchal group that were introduced by
KSBL and where there were additions of 50 names certified by KSBL, one bank
account having no.12140 was randomly selected for examination. The observations
emerging from the same is narrated below:
9.29. A perusal of account opening form of savings bank account number 12140 with
IOB, Thaltej Branch, Ahmedabad in the name of Roopal Nareshbhai Panchal and
Devangi Dipakbhai Panchal bearing the address 402, Shashwat Opp Gujarat
College, Ellisbrdige, Ahmedabad 3800006 reveals as under:
Page 67 of 191
? The said account (opened on March 9, 2005) was introduced by M/s. Karvy Stock
Broking Ltd.
? A list of 50 names and specimen signatures is attached to the account opening
form and the list is certified by Karvy Stock Broking Ltd. with their rubber stamp
affixed.
? The rubber stamp of Karvy on the main bank account introduction column and
that in the attached list is similar.
? The signature of the representative of Karvy as appearing on the main bank
account introduction column and that in the attached list appears to have been
made with the same pen.
? The list of 50 names and signatures bears the account number 12140 on the top
right hand side of the list.
? The 50 applicants bear common surname “SETH” starting from SURESH SETH
and ending with ADITI SETH.
? The signatures of the 50 applicants are in English, Hindi and Gujarathi and appear
to have been made by the same person.
9.30. Further, it is seen that Karvy DP held the dematerialized accounts of the 50 names
that were added to the bank account no.12140 and the dematerialized accounts had
been opened prior to the opening of the bank account. The details are as below:
Sr. No.
DP ID CLIENT ID
IOB Thaltej Bank Account No.
Name Of The Demat / Bank Account Holder
Date Of Opening Of Demat Account
Date Of Opening Of Bank Account
1. IN300394 13130266 12140 SURESH SETH 05.01.2004 9.03.2005 2. IN300394 13130274 12140 ABHAY SETH 05.01.2004 9.03.2005 3. IN300394 13130299 12140 DEVANSHI SETH 05.01.2004 9.03.2005 4. IN300394 13130303 12140 GULJAR SETH 05.01.2004 9.03.2005 5. IN300394 13130310 12140 JENNY SETH 05.01.2004 9.03.2005 6. IN300394 13130329 12140 LABDHA SETH 05.01.2004 9.03.2005 7. IN300394 13130338 12140 YASHI SETH 05.01.2004 9.03.2005 8. IN300394 13130346 12140 NIRU SETH 05.01.2004 9.03.2005 9. IN300394 13130354 12140 NITA SETH 05.01.2004 9.03.2005 10. IN300394 13130362 12140 UTPALL SETH 05.01.2004 9.03.2005 11. IN300394 13130379 12140 ABHIGNA SETH 05.01.2004 9.03.2005 12. IN300394 13130387 12140 BALWANT SETH 05.01.2004 9.03.2005 13. IN300394 13130395 12140 DEVARSHI SETH 05.01.2004 9.03.2005 14. IN300394 13130409 12140 GUMAN SETH 05.01.2004 9.03.2005 15. IN300394 13130418 12140 JHANKI SETH 05.01.2004 9.03.2005
Page 68 of 191
16. IN300394 13130426 12140 LAGNI SETH 05.01.2004 9.03.2005 17. IN300394 13130434 12140 YASHU SETH 05.01.2004 9.03.2005 18. IN300394 13130442 12140 NIRUPAMA SETH 05.01.2004 9.03.2005 19. IN300394 13130459 12140 NITANSH SETH 05.01.2004 9.03.2005 20. IN300394 13130467 12140 SWATI SETH 05.01.2004 9.03.2005 21. IN300394 13130475 12140 ABHILASH SETH 05.01.2004 9.03.2005 22. IN300394 13130483 12140 BALWIR SETH 05.01.2004 9.03.2005 23. IN300394 13130490 12140 DEVASYA SETH 05.01.2004 9.03.2005 24. IN300394 13130506 12140 GUNISH SETH 05.01.2004 9.03.2005 25. IN300394 13130514 12140 JIGAR SETH 05.01.2004 9.03.2005 26. IN300394 13130522 12140 LAHAR SETH 05.01.2004 9.03.2005 27. IN300394 13130539 12140 YATNA SETH 05.01.2004 9.03.2005 28. IN300394 13130547 12140 NIRVI SETH 05.01.2004 9.03.2005 29. IN300394 13130555 12140 NITIN SETH 05.01.2004 9.03.2005 30. IN300394 13130563 12140 TRUSHIT SETH 05.01.2004 9.03.2005 31. IN300394 13130570 12140 ABHISHEK SETH 05.01.2004 9.03.2005 32. IN300394 13130589 12140 BANJUL 05.01.2004 9.03.2005 33. IN300394 13130598 12140 DEVENDRA SETH 05.01.2004 9.03.2005 34. IN300394 13130602 12140 GUNJAK SETH 05.01.2004 9.03.2005 35. IN300394 13130619 12140 JIGISH SETH 05.01.2004 9.03.2005 36. IN300394 13130627 12140 LAJJA SETH 05.01.2004 9.03.2005 37. IN300394 13130635 12140 YATRI SETH 05.01.2004 9.03.2005 38. IN300394 13130643 12140 NISAR SETH 05.01.2004 9.03.2005 39. IN300394 13130650 12140 DEPARV SETH 05.01.2004 9.03.2005 40. IN300394 13130669 12140 TUKHAR SETH 05.01.2004 9.03.2005 41. IN300394 13130678 12140 ADIP SETH 05.01.2004 9.03.2005 42. IN300394 13130686 12140 BANKIM SETH 05.01.2004 9.03.2005 43. IN300394 13130694 12140 DEVI SETH 05.01.2004 9.03.2005 44. IN300394 13130717 12140 JIMISH SETH 05.01.2004 9.03.2005 45. IN300394 13130725 12140 LAKENDRA SETH 05.01.2004 9.03.2005 46. IN300394 13130733 12140 YAVAN SETH 05.01.2004 9.03.2005 47. IN300394 13130740 12140 MIYA SETH 05.01.2004 9.03.2005 48. IN300394 13130759 12140 ROHINI SETH 05.01.2004 9.03.2005 49. IN300394 13130768 12140 TURANG SETH 05.01.2004 9.03.2005 50. IN300394 13130776 12140 ADITI SETH 05.01.2004 9.03.2005
9.31. A cursory look at the names appearing in the list suggests that they could be names
of fictitious persons in view of the pattern of the names mentioned in the list i.e. 50
different names with same surname of SETH. The signatures of the 50 persons also
appear similar and appear to have been made by one person only. Anyway all
afferent accounts have been found to be fictitious. Accordingly it would follow that
only one central / control person could have signed. Therefore, from the above
observations on the bank account opening form (account no. 12140) wherein Karvy
Stock Broking Ltd had certified the account holders, it stands to reason that Karvy
were aware that the names and signatures are of fictitious persons.
Page 69 of 191
9.32. In this regard, KSBL in its reply dated May 19, 2007 has contended that the list of
50 names is a separate document and is not connected to the savings connected. I do
not find merit in the argument of Karvy since the relevant documents were
submitted by the concerned bank i.e. IOB. If the documents were not relating to
savings account, the bank would not have come to possess the document.
9.33. Karvy had further contended that the documents attached to the bank account no.
12140 pertain to another bank account bearing no.11983. In this regard I note that
the documents are in one set kept together with the savings account opening form of
account no.12140. Also the list of 50 names attached to the account no. 12140
mentions in the account no.12140 in the top right hand corner. In any case, I note
that the savings account 11983 also had a list of 50 names added and the name
addition in that case was certified by KCL. Therefore, I do not find merit in this
argument of Karvy.
9.34. Further Karvy had contended that “it can’t be held that the employee of the
company had introduced 50 additional names.” In this context it is relevant to note
that Karvy DP in its appeal memorandum (Appeal NO. 92 of 2006) inter alia stated
that “… … … .. the Appellant had not introduced the said 50 clients to IOB Thaltej.
The appellant has only certified pursuant to IOB sub- broker, that the said 50 demat
accounts with the Appellant. It is submitted that all the said 50 clients had, as per
appellant’s record, bank accounts with BHOB. Therefore, the certification given by
the Appellant was for existence of demat account as sought to be suggested”.
9.35. Therefore, I find that indeed 50 names were added to the SB account no.12140 of
Roopal Panchal group held with IOB, Thaltej branch and Karvy had indeed
introduced the bank account and certified the names added to the bank account. In
this regard, I note that Karvy DP had an arrangement with IOB along the same lines
as that with BhOB, whereby, IOB provided IPO finance to the dematerialized
account-holders of Karvy DP.
Page 70 of 191
9.36. In the demat system, the bank accounts of all the above afferent dematerialized
account-holders have indicated as being held with BhOB and the account number
indicated is 54119. It may be recalled that the BhOB account no.54119 is Devangi
Dipakbhai Panchal group account that had been introduced by Karvy Securities Ltd.
on December 4, 2003. Threfore, it follows that after the opening of bank group
account of Devangi Dipakbhai Panchal on December 4, 2003, Karvy DP
opened their dematerialized accounts on January 5, 2004 and thereafter, the
DP introduced these names to IOB Thaltej during March 2005 for the purpose
of opening bank accounts and availing IPO finance. In this context, it may
recalled that Karvy DP had an arrangement with IOB also on the same lines as
with BhOB.
9.37. The various unique characteristics relating to the add-on list of the IOB bank
account demonstrates a common modus operandi with a common control. All the
above 50 are existing dematerialized account holders with Karvy and their demat
accounts were opened in January 2004 on the basis of single BHOB account with
sub-numbers opened in December 2003 with the introduction of Karvy Securities
Ltd. Thus there is a clear nexus between the genesis of these accounts and their
subsequent reappearance with IOB in March 2005 for availing IPO finance. These
are all incontrovertible factual data.
9.38. Further, there is a continuity in the said pattern from December 2003 to March 2005
and thereafter as well which can hardly escape anybody’s attention. Also the key
operators account had been introduced by KSBL, while the add-on list had been
certified by KSBL by affixing rubber stamp and signature as admitted in the
grounds of appeal before SAT. KSBL has taken the stand in its reply dated May
19, 2007 in the present proceedings that “simply because employees of Karvy had
introduced the accounts and perhaps put the address or stamp of the company on the
forms it cannot be concluded that the company was aware of the activities of the
employees.” Such a shifting stance hardly canvasses any strength for Karvy’s
defence.
Page 71 of 191
9.39. Further as per the arrangement with IOB, IOB was to provide IPO finance only to
those borrowers having demat accounts with Karvy DP or IOB DP. Therefore
Karvy cannot distance itself from the arrangement by putting the blame on
employees. In any event Karvy is responsible.
9.40. In such a context, Karvy was not only aware of fictitious accounts but also was
actively involved in scouting financial package for such non-existing persons, on
the basis of fictitious demat accounts (afferent accounts). It is a matter of record
that Karvy was only dealing with the key operators and as such was a privy to the
arrangement Karvy had with the key operators in opening bank accounts and
afferent demat accounts and arranging IPO finance.
9.41. Combinations of 50 Names with different surnames in Karvy DP on CDSL
The dematerialized accounts cited above beginning from ‘SURESH SETH’ to
‘ADITI SETH’ were held with Karvy DP on NSDL. Further examination revealed
that demat accounts were opened with Karvy DP on CDSL in the 50 names starting
from SURESH and ending with ADITI with 25 different combinations of changing
surnames. The details of 15 such accounts opened on July 15-16, 2005 are
mentioned in the table below.
Sr. No. Surname No. of CDSL Demat Accounts 1. Zala 50 2. Rathod 50 3. Vania 50 4. Patil 50 5. Ranka 50 6. Pandya 50 7. Desai 50 8. Rathi 50 9. Verma 50 10. Trivedi 50 11. Gandhi 50 12. Barot 50 13. Vala 50 14. Pathak 50 15. Bhatt 50
Page 72 of 191
Sr. No. Surname No. of CDSL Demat Accounts Total 750
9.42. The details of dematerialized accounts in respect of two such surnames viz. Zala
and Pandya are as below:
BOID Acc Op Date BOName BOAdd BOCity
Bank Acc No
BenBank Name
1301440000056768 15072005 SURESH ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10048 BHOB
1301440000056772 15072005 ABHAY ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10049 BHOB
1301440000056787 15072005 DEVANSHI ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10050 BHOB
1301440000056791 15072005 GULJAR ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10051 BHOB
1301440000056808 15072005 JENNY ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10052 BHOB
1301440000056812 15072005 LABDHA ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10053 BHOB
1301440000056827 15072005 YASHI ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10054 BHOB
1301440000056831 15072005 NIRU ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10055 BHOB
1301440000056846 15072005 NITA ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10056 BHOB
1301440000056850 15072005 UTPALL ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10057 BHOB
1301440000056865 15072005 ABHIGNA ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10058 BHOB
1301440000056871 15072005 BALWANT ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10059 BHOB
1301440000056884 15072005 DEVARSHI ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10060 BHOB
1301440000056899 15072005 GUMAN ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10061 BHOB
1301440000056905 15072005 JHANKI ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10062 BHOB
1301440000056911 15072005 LAGNI ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10063 BHOB
1301440000056924 15072005 YASHU ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10064 BHOB
1301440000056939 15072005 NIRUPAMA ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10065 BHOB
1301440000056943 15072005 NITANSH ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10066 BHOB
1301440000056958 15072005 SWATI ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10067 BHOB
1301440000056962 15072005 ABHILASH ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10068 BHOB
1301440000056977 15072005 BALWIR ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10069 BHOB
1301440000056981 15072005 DEVASYA ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10070 BHOB
1301440000056996 15072005 GUNISH ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10071 BHOB
1301440000057003 15072005 JIGAR ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10072 BHOB
1301440000057018 15072005 LAHAR ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10073 BHOB
1301440000057022 15072005 YATNA ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10074 BHOB
1301440000057037 15072005 NIRVI ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10075 BHOB
Page 73 of 191
1301440000057041 15072005 NITIN ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10076 BHOB
1301440000057056 15072005 TRUSHIT ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10077 BHOB
1301440000057060 15072005 ABHISHEK ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10078 BHOB
1301440000057075 15072005 BANJUL . Office No.403, Shashwat Bldg. AHMEDABAD 9550-10079 BHOB
1301440000057081 15072005 DEVENDRA ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10080 BHOB
1301440000057094 15072005 GUNJAK ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10081 BHOB
1301440000057100 15072005 JIGISH ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10082 BHOB
1301440000057115 15072005 LAJJA ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10083 BHOB
1301440000057121 15072005 YATRI ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10084 BHOB
1301440000057134 15072005 NISAR ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10085 BHOB
1301440000057149 15072005 DEPARV ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10086 BHOB
1301440000057153 15072005 TUKHAR ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10087 BHOB
1301440000057168 15072005 ADIP ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10088 BHOB
1301440000057172 15072005 BANKIM ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10089 BHOB
1301440000057187 15072005 DEVI ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10090 BHOB
1301440000057191 15072005 JIMISH ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10091 BHOB
1301440000057208 15072005 LAKENDRA ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10092 BHOB
1301440000057212 15072005 YAVAN ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10093 BHOB
1301440000057227 15072005 MIYA ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10094 BHOB
1301440000057231 15072005 ROHINI ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10095 BHOB
1301440000057246 15072005 TURANG ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10096 BHOB
1301440000057250 15072005 ADITI ZALA .
Office No.403, Shashwat Bldg. AHMEDABAD 9550-10097 BHOB
Page 74 of 191
BOID AccOp Date BOName BOAdd BOCity
Ben Bank AccNo Bank Status
1301440000106761 16072005 SURESH PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-48 BHOB Closed
1301440000106774 16072005 ABHAY PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-49 BHOB Closed
1301440000106789 16072005 DEVANSHI PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-50 BHOB Closed
1301440000106793 16072005 GULJAR PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-51 BHOB Closed
1301440000106801 16072005 JENNY PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-52 BHOB Closed
1301440000106814 16072005 LABDHA PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-53 BHOB Closed
1301440000106829 16072005 YASHI PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-54 BHOB Closed
1301440000106833 16072005 NIRU PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-55 BHOB Closed
1301440000106848 16072005 NITA PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-56 BHOB Closed
1301440000106852 16072005 UTPALL PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-57 BHOB Closed
1301440000106867 16072005 ABHIGNA PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-58 BHOB Closed
1301440000106871 16072005 BALWANT PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-59 BHOB Closed
1301440000106886 16072005 DEVARSHI PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-60 BHOB Closed
1301440000106890 16072005 GUMAN PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-61 BHOB Closed
1301440000106907 16072005 JHANKI PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-62 BHOB Closed
1301440000106911 16072005 LAGNI PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-63 BHOB Closed
1301440000106926 16072005 YASHU PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-64 BHOB Closed
1301440000106930 16072005 NIRUPAMA PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-65 BHOB Closed
1301440000106945 16072005 NITANSH PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-66 BHOB Closed
1301440000106951 16072005 SWATI PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-67 BHOB Closed
1301440000106964 16072005 ABHILASH PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-68 BHOB Closed
1301440000106979 16072005 BALWIR PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-69 BHOB Closed
Page 75 of 191
1301440000106983 16072005 DEVASYA PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-70 BHOB Closed
1301440000106998 16072005 GUNISH PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-71 BHOB Closed
1301440000107005 16072005 JIGAR PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-72 BHOB Closed
1301440000107011 16072005 LAHAR PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-73 BHOB Closed
1301440000107024 16072005 YATNA PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-74 BHOB Closed
1301440000107039 16072005 NIRVI PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-75 BHOB Closed
1301440000107043 16072005 NITIN PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-76 BHOB Closed
1301440000107058 16072005 TRUSHIT PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-77 BHOB Closed
1301440000107062 16072005 ABHISHEK PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-78 BHOB Closed
1301440000107077 16072005 BANJUL PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-79 BHOB Closed
1301440000107081 16072005 DEVENDRA PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-80 BHOB Closed
1301440000107096 16072005 GUNJAK PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-81 BHOB Closed
1301440000107102 16072005 JIGISH PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-82 BHOB Closed
1301440000107117 16072005 LAJJA PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-83 BHOB Closed
1301440000107121 16072005 YATRI PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-84 BHOB Closed
1301440000107136 16072005 NISAR PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-85 BHOB Closed
1301440000107140 16072005 DEPARV PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-86 BHOB Closed
1301440000107155 16072005 TUKHAR PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-87 BHOB Closed
1301440000107161 16072005 ADIP PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-88 BHOB Closed
1301440000107174 16072005 BANKIM PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-89 BHOB Closed
1301440000107189 16072005 DEVI PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-90 BHOB Closed
1301440000107193 16072005 JIMISH PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-91 BHOB Closed
1301440000107201 16072005 LAKENDRA PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-92 BHOB Closed
Page 76 of 191
Note: It may be seen from discussions in later paragraphs that KCL had provided IPO finance in respect of the above dematerialized account-holders i.e. SURESH PANDYA to ADITI PANDYA 9.43. The BHOB bank account number 9550 is indicated as the bank account of the
above demat account holders. Upon perusal of the account opening form of the
BHOB bank account number 9550 it is seen that the said account is held in the
name of ‘Arjav Naresh Panchal’ and the account had been introduced by Devangi
Dipak Panchal having the address 402-403, Shashwat, Opp Gujarat College,
Ellisbridge, Ahmedabad 380 006. The account had been opened in December 2004.
9.44. It is observed that the 750 demat accounts were opened on CDSL during July 15 –
16, 2005 and were activated on July 15-16, 2005 i.e. during the period of IDFC
IPO. Thereafter, during the course of verification of genuineness of demat clients in
the wake of SEBI’s preliminary enquiry in the matter of Yes Bank IPO, the
dematerialized accounts were closed. These afferent accounts closely match the
ones noticed in the context of IOB accounts opened earlier in March 2005. The
CDSL demat accounts were opened for making applications in IDFC IPO and it is
seen that KCL had provided IPO finance to the fictitious applicants having their
demat accounts with CDSL. The details of the same have been discussed elsewhere
in this order.
9.45. Karvy DP CDSL Accounts pending Activation with names of Suresh to Aditi
It was found that the same pattern of opening of demat accounts with the same 50
first names from ‘SURESH’ to ‘ADITI’ and various surnames had been adopted in
1301440000107214 16072005 YAVAN PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-93 BHOB Closed
1301440000107229 16072005 MIYA PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-94 BHOB Closed
1301440000107233 16072005 ROHINI PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-95 BHOB Closed
1301440000107248 16072005 TURANG PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-96 BHOB Closed
1301440000107252 16072005 ADITI PANDYA .
406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-97 BHOB Closed
Page 77 of 191
respect of 500 dematerialized accounts opened with Karvy DP on September 22,
2005 that were pending for activation. The table below indicates the details of the
demat accounts which are pending for activation:
Sr. No. Surname No. of CDSL Demat Accounts
Date of Opening demat accounts
Remarks
1. Kapur 50 September 22, 2005
Demat accounts opened and pending activation
2. Tated 50 As above As above 3. Kela 50 As above As above 4. Sen 50 As above As above 5. Roy 50 As above As above 6. Irani 50 As above As above 7. Jha 50 As above As above 8. Mehta 50 As above As above 9. Das 50 As above As above 10. Prasad 50 As above As above Total 500
9.46. The details of the above 500 CDSL dematerialized accounts held with Karvy DP
opened on September 22, 2005 and pending activation is given below:
BOID AccOpDate BOName BO Address BOCity BenBankAccNo BANK NAME
1301440000410188 22092005 SURESH TATED . Office No.402, Shashwat Bldg.
AHD 2611-16048 IOB
1301440000410192 22092005 ABHAY TATED . Office No.402, Shashwat Bldg.
AHD 2611-16049 IOB
1301440000410209 22092005 DEVANSHI TATED .
Office No.402, Shashwat Bldg.
AHD 2611-16050 IOB
1301440000410213 22092005 GULJAR TATED . Office No.402, Shashwat Bldg.
AHD 2611-16051 IOB
1301440000410228 22092005 JENNY TATED . Office No.402, Shashwat Bldg.
AHD 2611-16052 IOB
1301440000410232 22092005 LABDHA TATED . Office No.402, Shashwat Bldg.
AHD 2611-16053 IOB
1301440000410247 22092005 YASHI TATED . Office No.402, Shashwat Bldg.
AHD 2611-16054 IOB
1301440000410251 22092005 NIRU TATED . Office No.402, Shashwat Bldg.
AHD 2611-16055 IOB
1301440000410266 22092005 NITA TATED . Office No.402, Shashwat Bldg.
AHD 2611-16056 IOB
1301440000410270 22092005 UTPALL TATED . Office No.402, Shashwat Bldg.
AHD 2611-16057 IOB
1301440000410285 22092005 ABHIGNA TATED .
Office No.402, Shashwat Bldg.
AHD 2611-16058 IOB
1301440000410291 22092005 BALWANT TATED .
Office No.402, Shashwat Bldg.
AHD 2611-16059 IOB
1301440000410306 22092005 DEVARSHI TATED .
Office No.402, Shashwat Bldg.
AHD 2611-16060 IOB
1301440000410310 22092005 GUMAN TATED . Office No.402, Shashwat Bldg.
AHD 2611-16061 IOB
1301440000410325 22092005 JHANKI TATED . Office No.402, Shashwat Bldg.
AHD 2611-16062 IOB
Page 78 of 191
BOID AccOpDate BOName BO Address BOCity BenBankAccNo BANK NAME
1301440000410331 22092005 LAGNI TATED . Office No.402, Shashwat Bldg.
AHD 2611-16063 IOB
1301440000410344 22092005 YASHU TATED . Office No.402, Shashwat Bldg.
AHD 2611-16064 IOB
1301440000410359 22092005 NIRUPAMA TATED .
Office No.402, Shashwat Bldg.
AHD 2611-16065 IOB
1301440000410363 22092005 NITANSH TATED .
Office No.402, Shashwat Bldg.
AHD 2611-16066 IOB
1301440000410378 22092005 SWATI TATED . Office No.402, Shashwat Bldg.
AHD 2611-16067 IOB
1301440000410382 22092005 ABHILASH TATED .
Office No.402, Shashwat Bldg.
AHD 2611-16068 IOB
1301440000410397 22092005 BALWIR TATED . Office No.402, Shashwat Bldg.
AHD 2611-16069 IOB
1301440000410403 22092005 DEVASYA TATED .
Office No.402, Shashwat Bldg.
AHD 2611-16070 IOB
1301440000410418 22092005 GUNISH TATED . Office No.402, Shashwat Bldg.
AHD 2611-16071 IOB
1301440000410422 22092005 JIGAR TATED . Office No.402, Shashwat Bldg.
AHD 2611-16072 IOB
1301440000410437 22092005 LAHAR TATED . Office No.402, Shashwat Bldg.
AHD 2611-16073 IOB
1301440000410441 22092005 YATNA TATED . Office No.402, Shashwat Bldg.
AHD 2611-16074 IOB
1301440000410456 22092005 NIRVI TATED . Office No.402, Shashwat Bldg.
AHD 2611-16075 IOB
1301440000410460 22092005 NITIN TATED . Office No.402, Shashwat Bldg.
AHD 2611-16076 IOB
1301440000410475 22092005 TRUSHIT TATED . Office No.402, Shashwat Bldg.
AHD 2611-16077 IOB
1301440000410481 22092005 ABHISHEK TATED .
Office No.402, Shashwat Bldg.
AHD 2611-16078 IOB
1301440000410494 22092005 BANJUL . . Office No.402, Shashwat Bldg.
AHD 2611-16079 IOB
1301440000410500 22092005 DEVENDRA TATED .
Office No.402, Shashwat Bldg.
AHD 2611-16080 IOB
1301440000410515 22092005 GUNJAK TATED . Office No.402, Shashwat Bldg.
AHD 2611-16081 IOB
1301440000410521 22092005 JIGISH TATED . Office No.402, Shashwat Bldg.
AHD 2611-16082 IOB
1301440000410534 22092005 LAJJA TATED . Office No.402, Shashwat Bldg.
AHD 2611-16083 IOB
1301440000410549 22092005 YATRI TATED . Office No.402, Shashwat Bldg.
AHD 2611-16084 IOB
1301440000410553 22092005 NISAR TATED . Office No.402, Shashwat Bldg.
AHD 2611-16085 IOB
1301440000410568 22092005 DEPARV TATED . Office No.402, Shashwat Bldg.
AHD 2611-16086 IOB
1301440000410572 22092005 TUKHAR TATED . Office No.402, Shashwat Bldg.
AHD 2611-16087 IOB
1301440000410587 22092005 ADIP TATED . Office No.402, Shashwat Bldg.
AHD 2611-16088 IOB
1301440000410591 22092005 BANKIM TATED . Office No.402, Shashwat Bldg.
AHD 2611-16089 IOB
1301440000410608 22092005 DEVI TATED . Office No.402, Shashwat Bldg.
AHD 2611-16090 IOB
1301440000410612 22092005 JIMISH TATED . Office No.402, Shashwat Bldg.
AHD 2611-16091 IOB
1301440000410627 22092005 LAKENDRA TATED .
Office No.402, Shashwat Bldg.
AHD 2611-16092 IOB
1301440000410631 22092005 YAVAN TATED . Office No.402, Shashwat Bldg.
AHD 2611-16093 IOB
1301440000410646 22092005 MIYA TATED . Office No.402, Shashwat Bldg.
AHD 2611-16094 IOB
1301440000410650 22092005 ROHINI TATED . Office No.402, Shashwat Bldg.
AHD 2611-16095 IOB
Page 79 of 191
BOID AccOpDate BOName BO Address BOCity BenBankAccNo BANK NAME
1301440000410665 22092005 TURANG TATED . Office No.402, Shashwat Bldg.
AHD 2611-16096 IOB
1301440000410671 22092005 ADITI TATED . Office No.402, Shashwat Bldg.
AHD 2611-16097 IOB
9.47. Examination Demat Account opening forms in respect of names added to IOB
Thaltej branch Account 12140
During the course of the instant proceedings, as required by SEBI, Karvy had
submitted a few NSDL demat account opening forms in respect of the demat
accounts list of names attached to the IOB Thaltej branch account no. 12140. The
observations on the documents submitted by Karvy DP are tabulated below:
Demat Account No
Name Of The Applicant
Address Bank Account
POI / POA (Observations Of SEBI in bracket)
Remarks Of SEBI
13130303 GULJAR SETH
402, Shashwat Opp Guj College, Ellisbridge, Ahmedabad
54119 / 1253
Letter from BHOB (No photograph affixed)
Bank account 54119 (group account) introduced by Karvy Securities
13130475 ABHILASH SETH
402, Shashwat Opp Guj College, Ellisbridge, Ahmedabad
54119 / 1270
Letter from BHOB (No photograph affixed)
Bank account 54119 (group account) introduced by Karvy Securities
13130506 GUNISH SETH
402, Shashwat Opp Guj College, Ellisbridge, Ahmedabad
54119 / 1273
Letter from BHOB (No photograph affixed)
Bank account 54119 (group account) introduced by Karvy Securities
13130539 YATNA SETH
402, Shashwat Opp Guj College, Ellisbridge, Ahmedabad
54119 / 1276
Letter from BHOB (No photograph affixed)
Bank account 54119 (group account) introduced by Karvy Securities
13130547 NIRVI SETH
402, Shashwat Opp Guj College, Ellisbridge, Ahmedabad
54119 / 1277
Letter from BHOB (No photograph affixed)
Bank account 54119 (group account) introduced by Karvy Securities
13130570 ABHISHOK SETH
402, Shashwat Opp Guj College, Ellisbridge, Ahmedabad
54119 / 1280
Letter from BHOB (No photograph affixed)
Bank account 54119 (group account) introduced by Karvy Securities
Page 80 of 191
13130598 DEVANDRA SETH
402, Shashwat Opp Guj College, Ellisbridge, Ahmedabad
54119 / 1282
Letter from BHOB (No photograph affixed)
Bank account 54119 (group account) introduced by Karvy Securities
13130650 DEPARV SETH
402, Shashwat Opp Guj College, Ellisbridge, Ahmedabad
54119 / 1288
Letter from BHOB (No photograph affixed)
Bank account 54119 (group account) introduced by Karvy Securities
9.48. From the above table it may be seen that the IOB bank account holders introduced
by Karvy to IOB Thaltej branch had indicated in the depository system, the BHOB
bank account number 54119 as their bank account. It may be recalled that the said
BHOB bank account number 54119 had been introduced by Karvy Securities Ltd.
during December 2003.
9.49. Financing by KCL in respect of Names added to IOB Thaltej Bank account
no.12140
It has been observed that out of the above set of demat accounts opened on CDSL
on July 15-16, 2005 with various combination of names starting with SURESH TO
ADITI, in respect of following set of names, KCL had also financed in the IPO of
IDFC and KCPL had issued consolidated refund order no. 69001 in respect of these
applicants. Further, it was also observed that Karvy DP had issued loose DIS slips
bearing continuous serial numbers which were used for making off-market transfers
from these dematerialized accounts to the dematerialized account of Roopalben
Panchal.
9.50. In its reply dated May 19, 2007, Karvy DP had at para 15.2 (ii) stated “KCL had not
extended finance to any of the applicants, for any of the IPOs, whose names are
appearing in the sheet attached to the savings bank account opening application
forms as contained in Annexure 1 to the Notice in any of the Issues. Admittedly,
IOB Thaltej branch Ahmedabad, had provided IPO funding in respect of the said
Page 81 of 191
applicants in IDFC.” The details as culled out from the allotment master and from
the DIS data furnished by CDSL in respect of those dematerialized accounts / IPO
applicants where KCL had provided finance in the IPO of IDFC shows that KCL
had indeed provided IPO finance through various combinations of surnames of the
fictitious / benami names that were added to the IOB bank account. In fact, the
application money in respect of these applicants was directly remitted by KCL to
the IDFC public issue escrow account through RTGS transfer and it never went
through the bank accounts of the afferent entities. The details of the applications
made, refund and allotment details are given below: Mode of Financing
Place of Bidding
Appl_No Name of Applicant
Bid Amt (Rs.)
Amt of Refund (Rs.)
Refund Order No.
No. of Shares Allotted
DIS No
RTGS HYDERABAD 32985831 SURESH PANDYA 47600 38556 690001 266 74919
RTGS HYDERABAD 32985830 ABHAY PANDYA 47600 38556 690001 266 74920
RTGS HYDERABAD 32985829 DEVANSHI PANDYA 47600 38556 690001 266 74921
RTGS HYDERABAD 32985828 GULJAR PANDYA 47600 38556 690001 266 74922
RTGS HYDERABAD 32985827 JENNY PANDYA 47600 38556 690001 266 74923
RTGS HYDERABAD 32985826 LABOHA PANDYA 47600 38556 690001 266 74924
RTGS HYDERABAD 32985825 YASHI PANDYA 47600 38556 690001 266 74925
RTGS HYDERABAD 32985824 NIRU PANDYA 47600 38556 690001 266 74926
RTGS HYDERABAD 32985823 NITA PANDYA 47600 38556 690001 266 74927
RTGS HYDERABAD 32985822 UTAPLL PANDYA 47600 38556 690001 266 74928
RTGS HYDERABAD 32985821 ABHIGNA PANDYA 47600 38556 690001 266 74929
RTGS HYDERABAD 32985820 BALWANT PANDYA 47600 38556 690001 266 74930
RTGS HYDERABAD 32985819 DEVARSHI PANDYA 47600 38556 690001 266 74931
RTGS HYDERABAD 32985818 GUMAN PANDYA 47600 38556 690001 266 74932
RTGS HYDERABAD 32985817 JHANKI PANDYA 47600 38556 690001 266 74933
RTGS HYDERABAD 32985816 LAGNI PANDYA 47600 38556 690001 266 74934
RTGS HYDERABAD 32985815 KASHU PANDYA 47600 38556 690001 266 74935
RTGS HYDERABAD 32985554 NIRUPAMA PANDYA 47600 38556 690001 266 74936
RTGS HYDERABAD 32985553 NITANSH PANDYA 47600 38556 690001 266 74937
RTGS HYDERABAD 32985552 SWATI PANDYA 47600 38556 690001 266 74938
RTGS HYDERABAD 32985776 ABHILASH PANDY 47600 38556 690001 266 74939
RTGS HYDERABAD 32985771 BALWIR PANDYA 47600 38556 690001 266 74940
RTGS HYDERABAD 32985770 DEVASPA PANDYA 47600 38556 690001 266 74941
RTGS HYDERABAD 32985769 GUNISH PANDYA 47600 38556 690001 266 74942
RTGS HYDERABAD 32985768 JIGAR PANDYA 47600 38556 690001 266 74943
RTGS HYDERABAD 33016532 LAHAR PANDYA 47600 38556 690001 266 74944
RTGS HYDERABAD 32985766 YATNA PANDYA 47600 38556 690001 266 74945
RTGS HYDERABAD 32985765 NIRVI PANDYA 47600 38556 690001 266 74946
RTGS HYDERABAD 32985764 NITIN PANDYA 47600 38556 690001 266 74947
RTGS HYDERABAD 32985763 TRUSHIT PANDYA 47600 38556 690001 266 74948
RTGS HYDERABAD 32985813 ABHISHEK PANDYA 47600 38556 690001 266 74949
Page 82 of 191
Mode of Financing
Place of Bidding
Appl_No Name of Applicant
Bid Amt (Rs.)
Amt of Refund (Rs.)
Refund Order No.
No. of Shares Allotted
DIS No
RTGS HYDERABAD 32985812 BANJUL PANDYA 47600 38556 690001 266 74950
RTGS HYDERABAD 32985811
DEVENDRA PANDYA
47600 38556 690001 266
74951
RTGS HYDERABAD 32985810 GUNJAK PANDYA 47600 38556 690001 266 74952
RTGS HYDERABAD 32985809 JIGISH PANDYA 47600 38556 690001 266 74953
RTGS HYDERABAD 32985808 LAJJA PANDYA 47600 38556 690001 266 74954
RTGS HYDERABAD 32985789 YATRI PANDYA 47600 38556 690001 266 74955
RTGS HYDERABAD 32985788 NISAR PANDYA 47600 38556 690001 266 74956
RTGS HYDERABAD 32985787 DEPARV PANDYA 47600 38556 690001 266 74957
RTGS HYDERABAD 32985807 TUKHAR PANDYA 47600 38556 690001 266 74958
RTGS HYDERABAD 32985805 ADIP PANDYA 47600 38556 690001 266 74959
RTGS HYDERABAD 32985804 BANKIM PANDYA 47600 38556 690001 266 74960
RTGS HYDERABAD 32985803 DEVI PANDYA 47600 38556 690001 266 74961
RTGS HYDERABAD 32985802 JIMISH PANDYA 47600 38556 690001 266 74962
RTGS HYDERABAD 32985801
LAKENDRA PANDYA
47600 38556 690001 266
74963
RTGS HYDERABAD 32985800 YAVAN PANDYA 47600 38556 690001 266 74964
RTGS HYDERABAD 32985799 MIYA PANDYA 47600 38556 690001 266 74965
RTGS HYDERABAD 32985798 ROHINI PANDYA 47600 38556 690001 266 74966
RTGS HYDERABAD 32985797 TURANG PANDYA 47600 38556 690001 266 74967
RTGS HYDERABAD 32985796 ADITI PANDYA 47600 38556 690001 266 74968
9.51. From the above table it may be seen that KCL had done RTGS transfer of
application money to the IDFC escrow account. KSBL bid the applications without
obtaining application money and KCPL (RTI) issued consolidated refund order no.
690001 in respect of these fictitious applicants. Thereafter, KSBL (DP) transferred
the IPO shares from the demat accounts of the fictitious/benami entities to the
demat accounts of the key operators using the DIS numbers indicated in the last
column of the table. It is noted that the DIS pertaining to different applicants were
in continous serial numbers indicating the control of one or few persons in the
maintenance and operation of the numerous demat accounts held in
fictitious/benami names. That Karvy DP accepted consolidated payments from the
key operators towards maintenance of these demat accounts also supports this
finding.
9.52. It is also observed that while the details pertaining to the series of applications from
‘SURESH PANDYA’ to ‘ADITI PANDYA’ has been indicated in the table, there
were also other sets of applications wherein the same features were observed. While
Page 83 of 191
the first names in respect of these applications were in the same series beginning
from ‘SURESH’ and ending with ‘ADITI’, the surnames that were used instead of
‘Pandya’ were Verma, Gandhi, Trivedi and Desai.
9.53. Issuance of Consolidated Refund by KCPL in respect of Names added to IOB
Thaltej Bank account no.12140
Based on the allotment master in the IPO of IDFC, as submitted by KCPL, it is seen
that the list of names of the IPO applicants starting from SURESH SETH to ADITI
SETH are in the same order as the list of names attached to the IOB Thaltej branch
account no 12140. Further, it is also seen that KCPL (which is RTI in the IPO of
IDFC) had issued a consolidated refund order no. 660004 in favour of IOB for Rs
61.24 crores in respect of 15,751 applications including those made by the set of 50
applicants starting from Suresh Seth to Aditi Seth.
9.54. Thus, from the above, it is clear that Karvy had initially introduced BhOB
Ahmedabad bank account no. 54119 in the month of December 2003. Subsequently
demat accounts were opened with Karvy DP on NSDL in the month of December
2003 / January 2004 indicating the bank details of BHOB. The said NSDL
dematerialized accounts include the 50 names beginning from SURESH SETH to
ADITI SETH. The said bank account no.54119 was thereafter closed on April 24,
2004. The dematerialized accounts continued to exist with Karvy DP even after the
closure of the bank account.
9.55. Thereafter, in March 2005, Karvy introduced bank account of Devangi Dipakbhai
Panchal (account no: 12140), a key operator belonging to the Panchal group, to
IOB Thaltej Branch and also certified the list of names attached with the said bank
account (SURESH SETH to ADITI SETH) for the purpose of arranging IPO
finance. It is observed that in the IPO of IDFC (July 2005), IOB had financed
15,751 applications which include the 50 names beginning with SURESH SETH till
ADITI SETH.
Page 84 of 191
Further, Karvy Computer share Pvt. Ltd, RTI in the IPO of IDFC had issued consolidated
refund order no. 660004 to IOB.
9.56. Synchronised Off-market transfers from Afferent Accounts to Key Operators
After the allotment of shares on August 6, 2005 the shares were transferred through
off-market transactions from the dematerialized accounts of the allottees (including
SURESH SETH till ADITI SETH) to the demat account of Roopal Panchal (client
ID: 11920868) on August 8, 2005. With regard to these off-market transfers, it was
observed that Karvy DP had issued loose DIS slips which had continuous serial
numbers. The details of the off market transfers in the IPO of IDFC in respect of
these transactions are given in the table below:
Sr. No.
CLIENT ID
NAME OF THE DEMAT ACCOUNT HOLDER
TARGET CLIENT NAME
Date of execution NO OF SHARES
SLIPNO
1. 13130266 SURESH SETH Roopal Panchal August 8, 2005 266 200167245 2. 13130274 ABHAY SETH Roopal Panchal August 8, 2005 266 200167246 3. 13130299 DEVANSHI SETH Roopal Panchal August 8, 2005 266 200167248 4. 13130329 LABDHA SETH Roopal Panchal August 8, 2005 266 200167249 5. 13130338 YASHI SETH Roopal Panchal August 8, 2005 266 200167250 6. 13130346 NIRU SETH Roopal Panchal August 8, 2005 266 200167251 7. 13130354 NITA SETH Roopal Panchal August 8, 2005 266 200167252 8. 13130362 UTPALL SETH Roopal Panchal August 8, 2005 266 200167253 9. 13130379 ABHIGNA SETH Roopal Panchal August 8, 2005 266 200167254 10. 13130387 BALWANT SETH Roopal Panchal August 8, 2005 266 200167255 11. 13130395 DEVARSHI SETH Roopal Panchal August 8, 2005 266 200167256 12. 13130409 GUMAN SETH Roopal Panchal August 8, 2005 266 200167257 13. 13130418 JHANKI SETH Roopal Panchal August 8, 2005 266 200167258 14. 13130426 LAGNI SETH Roopal Panchal August 8, 2005 266 200167259 15. 13130434 YASHU SETH Roopal Panchal August 8, 2005 266 200167260 16. 13130442 NIRUPAMA SETH Roopal Panchal August 8, 2005 266 200167261 17. 13130459 NITANSH SETH Roopal Panchal August 8, 2005 266 200167262 18. 13130467 SWATI SETH Roopal Panchal August 8, 2005 266 200167263 19. 13130475 ABHILASH SETH Roopal Panchal August 8, 2005 266 200167264 20. 13130483 BALWIR SETH Roopal Panchal August 8, 2005 266 200167265 21. 13130490 DEVASYA SETH Roopal Panchal August 8, 2005 266 200167266 22. 13130506 GUNISH SETH Roopal Panchal August 8, 2005 266 200167267 23. 13130514 JIGAR SETH Roopal Panchal August 8, 2005 266 200167268 24. 13130522 LAHAR SETH Roopal Panchal August 8, 2005 266 200167269 25. 13130539 YATNA SETH Roopal Panchal August 8, 2005 266 200167270 26. 13130547 NIRVI SETH Roopal Panchal August 8, 2005 266 200167271
Page 85 of 191
Sr. No.
CLIENT ID
NAME OF THE DEMAT ACCOUNT HOLDER
TARGET CLIENT NAME
Date of execution NO OF SHARES
SLIPNO
27. 13130555 NITIN SETH Roopal Panchal August 8, 2005 266 200167272 28. 13130563 TRUSHIT SETH Roopal Panchal August 8, 2005 266 200167273 29. 13130570 ABHISHEK SETH Roopal Panchal August 8, 2005 266 200167274 30. 13130589 BANJUL Roopal Panchal August 8, 2005 266 200167275 31. 13130598 DEVENDRA SETH Roopal Panchal August 8, 2005 266 200167276 32. 13130602 GUNJAK SETH Roopal Panchal August 8, 2005 266 200167277 33. 13130619 JIGISH SETH Roopal Panchal August 8, 2005 266 120204845 34. 13130627 LAJJA SETH Roopal Panchal August 8, 2005 266 200167278 35. 13130635 YATRI SETH Roopal Panchal August 8, 2005 266 200167279 36. 13130643 NISAR SETH Roopal Panchal August 8, 2005 266 200167280 37. 13130650 DEPARV SETH Roopal Panchal August 8, 2005 266 200167281 38. 13130669 TUKHAR SETH Roopal Panchal August 8, 2005 266 200167282 39. 13130678 ADIP SETH Roopal Panchal August 8, 2005 266 200167283 40. 13130686 BANKIM SETH Roopal Panchal August 8, 2005 266 200167284 41. 13130694 DEVI SETH Roopal Panchal August 8, 2005 266 200167285 42. 13130717 JIMISH SETH Roopal Panchal August 8, 2005 266 200167287 43. 13130725 LAKENDRA SETH Roopal Panchal August 8, 2005 266 200167288 44. 13130733 YAVAN SETH Roopal Panchal August 8, 2005 266 200167289 45. 13130740 MIYA SETH Roopal Panchal August 8, 2005 266 200167290 46. 13130759 ROHINI SETH Roopal Panchal August 8, 2005 266 200167291 47. 13130768 TURANG SETH Roopal Panchal August 8, 2005 266 200167292 48. 13130776 ADITI SETH Roopal Panchal August 8, 2005 266 200167293
9.57. The allotted shares were immediately transferred from the afferent demat accounts
to the demat account of Roopal Panchal (client ID 11920868) using DIS bearing
continuous serial numbers as seen from the table above, all the events happening
within Karvy DP’s system.
9.58. Thus Karvy group entities were involved in all the activities of cornering of IPO
shares by the key operators beginning from the introduction of bank account
(no.54119 with BhOB Ahmedabad), the opening of demat account in NSDL,
arrangement of finance from IOB, issue of consolidated Refund Order to IOB and
making off-market transfers from the dematerialized accounts of fictitious/benami
entities to the dematerialized accounts of the key operators.
9.59. Afferent Accounts Introduced by Karvy Group with BhOB Goregaon Branch
It was observed that Karvy had not only introduced bank accounts at BhOB,
Ahmedabad and IOB, Thaltej branch but had also introduced bank accounts to
BhOB Goregaon branch. Pradeep Bhogale, employee of Karvy Consultants Ltd.
Page 86 of 191
had introduced the following bank accounts with BhOB, Goregaon. 121 afferent
dematerialized account-holders with Karvy DP had indicated these bank accounts
introduced by KCL as their bank accounts. The details are given below:
Sr. No.
SOURCE CLIENT ID
SOURCE CLIENT NAME ADDRESS1
BANK ACCOUNT
1. 40082103
JAGDISH MITHILAKSHA A
Mahalaxmi CHS R No 22, Chatrapati Shivaji Nagar, Asalpha Village Ghatkopar W, Mumbai 1971320
2. 40081887 ACHARYA JAGDISH M
Mahalaxmi CHS R No 22, Chatrapati Shivaji Nagar, Asalpha Village Ghatkopar W, Mumbai 1971320
3. 40082089 BINDI BISHIR M B 5 Nilkanth Dhara, 90 Feet Road, Ghatkopar East, Mumbai 1971320 4.
40082646 MEHTA G DHARMESH Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971318
5. 40082863 G DHARMESH MEHTA
Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971318
6. 40081758 MEHTA CHETNA D
Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971318
7. 40081766 MEHTA GRISHMA D
Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971318
8. 40081782
MEHTA BHUPENDRA K
Flat No 19/20 5th Floor Parijat, R B Mehta Marg, Ghatkopar E, Mumbai 1971318
9. 40082216
GRISHMABEN DHARMESHBHAI M
Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971318
10. 40082662 MEHTA B KUVARJI
Flat No 19/20 5th Floor Parijat, R B Mehta Marg, Ghatkopar E, Mumbai 1971318
11. 40082888 B KUVARJI MEHTA 6/1 Damodar Park R No 904, L B S Marg, Ghatkopar W, Mumbai 1971318 12.
40082208 CHETNABEN DHARMESHBHAI
Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971318
13. 40081976
CHETNA DHARMESH M
Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971318
14. 40082638 MEHTA C DHARMESH
Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971318
15. 40082855 C DHARMESH MEHTA
Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971318
16. 40082232
BHUPENDRA BHAI KUVARJIBHAI M
Flat No 19/20 5th Floor Parijat, R B Mehta Marg, Ghatkopar E, Mumbai 1971318
17. 40082402 DHARMESHLAL B M 501 Parijat Plot No 60, 60 Feet Road, Ghatkopar East, Mumbai 1971318 18.
40082419 CHETNADEVI D M Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971318
19. 40082427 GRISHMADEVI D M
R No 4 Mahadik Niwas, Jamili Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971318
20. 40082445 BHUPENDRALAL K M 6/1 Damodar Park R No 904, L B S Marg, Ghatkopar W, Mumbai 1971318 21.
40082620 MEHTA D BHUPENDRA
Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971318
22. 40081993
GRISHMA DHARMESH M
Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971318
23. 40082654 MEHTA V DHARMESH
Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971306
24. 40082436 VIRAJLAL D M
Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971306
25. 40082926 U KETAN MEHTA B 5 Nilkanth Dhara, 90 Feet Road, Ghatkopar East, Mumbai 1971306 26.
40081774 MEHTA VIRAJ D Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971306
27. 40082870 V DHARMESH MEHTA
Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971306
28. 40082224
VIRAJBHAI DHARMESHBHAI
Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971306
29. 40082048 UDVIT KETAN M 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971306 30. 40081820 MEHTA UDVIT K 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971306 31. 40082486 UDVITLAL K M B 5 Nilkanth Dhara, 90 Feet Road, Ghatkopar East, Mumbai 1971306
Page 87 of 191
Sr. No.
SOURCE CLIENT ID
SOURCE CLIENT NAME ADDRESS1
BANK ACCOUNT
32. 40081985 VIRAJ DHARMESH M
Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971306
33. 40082696 MEHTA UDVIT KETAN 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971306 34.
40082275 UDVITBHAI KETANBHAI M 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971306
35. 40082152
KAMAL CHANDRAKANT W
R No 4 Mahadik Niwas, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971290
36. 40082812 WAUGH C LAXMAN
R No 4 Mahadik Niwas, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971290
37. 40082829
WAUGH K CHANDRAKANT
R No 4 Mahadik Niwas, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971290
38. 40082613 KAMLADEVI C W
R No 4 Mahadik Niwas, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971290
39. 40082605
CHANDRA KANTLAL L W
R No 4 Mahadik Niwas, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971290
40. 40081942 WAUGH KAMAL C
Mahadik Niwas, R No. 4, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971290
41. 40083057
K CHANDRAKANT WAUGH
R No 4 Mahadik Niwas, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971290
42. 40083049 C LAXMAN WAUGH
R No 4 Mahadik Niwas, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971290
43. 40082177
CHANDRAKANT LAXMAN W
R No 4 Mahadik Niwas, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971290
44. 40081926
WAUGH CHANDRAKANT L
R No 4 Mahadik Niwas, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971290
45.
40082398
KAMALBEN CHANDRA KANTBHAI W
R No 4 Mahadik Niwas, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971290
46. 40082380
CHANDRA KANTBHAI LAXMANBHAI W
R No 4 Mahadik Niwas, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971290
47. 40081799 MEHTA KETAN B 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971288 48. 40082687 MEHTA D KETAN 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971288 49. 40082460 DARSHNADEVI K M 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971288 50. 40082453 KETANLAL B M 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971288 51.
40082679 MEHTA K BHUPENDRA 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971288
52. 40082558 SATISHLAL M A
Mahalaxmi Chsl 1 R No 22, Chatrapati Shivaji Nagar, Asalpha Village Ghatkopar W, Mumbai 1971288
53. 40081805 MEHTA DARSHNA K 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971288 54. 40082023 DARSHNA KETAN M 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971288 55.
40082896 K BHUPENDRA MEHTA 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971288
56. 40082015
KETAN BHUPENDRA M 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971288
57. 40082478 UMANGLAL K M 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971276 58. 40082917 UMANG K MEHTA 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971276 59.
40081959 WAUGH SASHIKALA L
Mahadik Niwas, R No 4 Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971276
60. 40082169
SASHIKALA LAXMAN W
R No 4 Mahadik Niwas, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971276
61. 40082266
UMANGBHAI KETANBHAI M 501 Parijat Plot No 60, 60 Feet Road, Ghatkopar East, Mumbai 1971276
62. 40082599 SASHIDEVI L W
R No 4 Mahadik Niwas, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971276
63. 40082837
WAUGH SASHI LAXMAN 501 Parijat Plot No 60, 60 Feet Road, Ghatkopar East, Mumbai 1971276
64. 40081813 MEHTA UMANG K 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971276 65. 40082700 MEHTA U KETAN 501 Parijat Plot No 60, 60 Feet Road, Ghatkopar East, Mumbai 1971276 66. 40082030 UMANG KETAN M 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971276 67. 40081896 ACHARYA SATISH M Mahalaxmi Chsl 1 R No 22, Chatrapati Shivaji Nagar, Asalpha 1971264
Page 88 of 191
Sr. No.
SOURCE CLIENT ID
SOURCE CLIENT NAME ADDRESS1
BANK ACCOUNT
Village Ghatkopar W, Mumbai
68. 40082136
MITHILAKSHA RUDRAYYA A
Mahalaxmi Chsl R No 22, Chatrapati Shivaji Nagar, Asalpha Village Ghatkopar W, Mumbai 1971264
69. 40082776
ACHARYA S MITHILAKSHA
Mahalaxmi Chsl 1 R No 22, Chatrapati Shivaji Nagar, Asalpha Village Ghatkopar W, Mumbai 1971264
70. 40082992
S MITHILAKSHA ACHARYA
Mahalaxmi Chsl 1 R No 22, Chatrapati Shivaji Nagar, Asalpha Village Ghatkopar W, Mumbai 1971264
71. 40083016
M RUDRAYYA ACHARYA
Mahalaxmi Chsl 1 R No 22, Chatrapati Shivaji Nagar, Asalpha Village Ghatkopar W, Mumbai 1971264
72. 40082574
MITHILAKSHALAL R A 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971264
73. 40082793
ACHARYA MITHILAKSHA R 501 Parijat Plot No 60, 60 Feet Road, Ghatkopar East, Mumbai 1971264
74. 40082110
SATISH MITHILAKSHA A
Mahalaxmi CHS R No 22, Chatrapati Shivaji Nagar, Asalpha Village Ghatkopar W, Mumbai 1971264
75. 40081918
ACHARYA MITHILAKSHA R
Mahalaxmi CHS R No 22, Chatrapati Shivaji Nagar, Asalpha Village Ghatkopar W, Mumbai 1971264
76. 40082950 H BISHIR MEHTA B 5 Nilkanth Dhara, 90 Feet Road, Ghatkopar East, Mumbai 1971252 77.
40082290 HELLYBEN BISHIRBHAI M A 17/18 Nilkanth Dhara, 90 Feet Road, Ghatkopar East, Mumbai 1971252
78. 40082306
RADHIBEN BISHIRBHAI M B 5 Nilkanth Dhara, 90 Feet Road, Ghatkopar East, Mumbai 1971252
79. 40082525 RADHIDEVI B M B 5 Nilkanth Dhara, 2nd flr, 90 Feet Road, Ghatkopar East, Mumbai 1971252 80. 40082734 MEHTA H BISHIR 501 Parijat Plot No 60, 60 Feet Road, Ghatkopar East, Mumbai 1971252 81. 40081854 MEHTA HELLY B B 5 Nilkanth Dhara, 2nd flr, 90 Feet Road, Ghatkopar East, Mumbai 1971252 82.
40082846 D BHUPENDRA MEHTA 501 Parijat Plot No 60, 60 Feet Road, Ghatkopar East, Mumbai 1971252
83. 40081862 MEHTA RADHI B B 5 Nilkanth Dhara, 2nd flr, 90 Feet Road, Ghatkopar East, Mumbai 1971252 84. 40082064 HELLY BISHIR M B 5 Nilkanth Dhara, 90 Feet Road, Ghatkopar East, Mumbai 1971252 85. 40082742 MEHTA R BISHIR B 5 Nilkanth Dhara, 90 Feet Road, Ghatkopar East, Mumbai 1971252 86. 40082072 RADHI BISHIR M B 5 Nilkanth Dhara, 90 Feet Road, Ghatkopar East, Mumbai 1971252 87. 40082516 HELLYDEVI B M B 5 Nilkanth Dhara, 2nd flr, 90 Feet Road, Ghatkopar East, Mumbai 1971252 88.
40082186 BISHIRBHAI BHUPENDRABHAI B 5 Nilkanth Dhara, 90 Feet Road, Ghatkopar East, Mumbai 19712400
89. 40082097 GEETA BISHIR M B 5 Nilkanth Dhara, 90 Feet Road, Ghatkopar East, Mumbai 19712400 90.
40082314 BINDIBEN BISHIRBHAI M B 5 Nilkanth Dhara, 90 Feet Road, Ghatkopar East, Mumbai 19712400
91. 40082056
BISHIR BHUPENDRA M B 5 Nilkanth Dhara, 2nd flr, 90 Feet Road, Ghatkopar East, Mumbai 19712400
92. 40082283
GEETABEN BISHIRBHAI B 5 Nilkanth Dhara, 90 Feet Road, Ghatkopar East, Mumbai 19712400
93. 40081846 MEHTA GEETA B B 5 Nilkanth Dhara, 2nd flr, 90 Feet Road, Ghatkopar East, Mumbai 19712400 94. 40082533 BINDIDEVI B M 501 Parijat Plot No 60, 60 Feet Road, Ghatkopar East, Mumbai 19712400 95. 40082507 GEETADEVI B M B 5 Nilkanth Dhara, 2nd flr, 90 Feet Road, Ghatkopar East, Mumbai 19712400 96.
40082718 MEHTA B BHUPENDRA 501 Parijat Plot No 60, 60 Feet Road, Ghatkopar East, Mumbai 19712400
97. 40082726 MEHTA G BISHIR B 5 Nilkanth Dhara, 2nd flr, 90 Feet Road, Ghatkopar East, Mumbai 19712400 98. 40082494 BISHIRLAL B M B 5 Nilkanth Dhara, 2nd flr, 90 Feet Road, Ghatkopar East, Mumbai 19712400 99. 40082759 MEHTA BINDI BISHIR 501 Parijat Plot No 60, 60 Feet Road, Ghatkopar East, Mumbai 19712400 100.
40082935 B BHUPENDRA MEHTA 501 Parijat Plot No 60, 60 Feet Road, Ghatkopar East, Mumbai 19712400
101. 40082943 G BISHIR MEHTA B 5 Nilkanth Dhara, 2nd flr, 90 Feet Road, Ghatkopar East, Mumbai 19712400 102.
40082976 BINDIKUMARI B MEHTA
Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 19712400
103. 40081838 MEHTA BISHIR B B 5 Nilkanth Dhara, 90 Feet Road, Ghatkopar East, Mumbai 19712400 104.
40082785 ACHARYA L MITHILAKSHA 501 Parijat Plot No 60, 60 Feet Road, Ghatkopar East, Mumbai 1971239
Page 89 of 191
Sr. No.
SOURCE CLIENT ID
SOURCE CLIENT NAME ADDRESS1
BANK ACCOUNT
105. 40082144
SASHIKANT LAXMAN W
R No 4 Mahadik Niwas, Jamili Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971239
106. 40082804 WAUGH S LAXMAN 501 Parijat Plot No 60, 60 Feet Road, Ghatkopar East, Mumbai 1971239 107.
40083008 L MITHILAKSHA ACHARYA
Mahalaxmi CHS 1 R No 22, Chatrapati Shivaji Nagar, Asalpha Village Ghatkopar W, Mumbai 1971239
108. 40083024 S LAXMAN WAUGH
R No 4 Mahadik Niwas, Jamili Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971239
109. 40082195
DHARMESHBHAI BHUPENDRABHAI
Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971239
110. 40083032 SASHINATH L WAUGH
R No 4 Mahadik Niwas, Jamili Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971239
111. 40081900
ACHARYA LALITHA M
Mahalaxmi CHS 1 R No 2, Chatrapati Shivaji Nagar, Asalpha Village Ghatkopar W, Mumbai 1971239
112. 40082339
SATISHBHAI MITHILAKSHABHAI A
Mahalaxmi CHS 1 R No 22, Chatrapati Shivaji Nagar, Asalpha Village Ghatkopar W, Mumbai 1971239
113. 40082566 LALITHADEVI M A
R No 4 Mahadik Niwas, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971239
114.
40082347
LALITHABEN MITHILAKSHA BHAI A
Mahalaxmi CHS R No 22, Chatrapati Shivaji Nagar, Asalpha Village Ghatkopar W, Mumbai 1971239
115. 40082365
SASHIBHAI LAXMANBHAI W 501 Parijat Plot No 60, 60 Feet Road, Ghatkopar East, Mumbai 1971239
116. 40081967
DHARMESH BHUPENDRA M
Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971239
117. 40081934
WAUGH SHASHIKANT L
Mahadik Niwas, R No. 4Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971239
118. 40081740 MEHTA DHARMESH B
Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971239
119. 40082582 SASHILAL L W 501 Parijat Plot No 60, 60 Feet Road, Ghatkopar East, Mumbai 1971239 120.
40082373 SASHIBEN LAXMANBHAI W
R No 4 Mahadik Niwas, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971239
121. 40082128
LALITHA MITHILAKSHA A
Mahalaxmi CHS R No 22, Chatrapati Shivaji Nagar, Asalpha Village Ghatkopar W, Mumbai 1971239
9.60. From the above table, it may be seen that a few bank accounts held with BhOB,
Goregaon branch resulted in numerous dematerialized accounts with Karvy DP. It
is pertinent to note that Karvy DP had introduced these bank accounts.
9.61. Analysis of Afferent dematerialized accounts held with Karvy DP and their
Characteristics
During the course of SEBI investigations into the IPO related irregularities during
2003-2005 it was found that as many as 58,938 afferent dematerialized accounts
had been opened with various DPs by the Key Operators for cornering the IPO
shares. It was found that a substantial proportion of the afferent accounts identified
by SEBI were held with Karvy DP and the details are given below:
Page 90 of 191
Name of Depository
Total No. of Afferent Demat accounts
No. of Afferent Demat accounts with Karvy DP
% of Afferent Demat Accounts with Karvy
NSDL 37,240 29,309 79% CDSL 21,698 20,399 94% Total 58,938 49,708 84%
9.62. Further, it was noticed that many of these afferent demat accounts had been opened
on the same day with the address of the key operators shown as the address of
fictitious / benami BOs. The details are as below:
Sr. no
Date of opening account
Address CDSL NSDL
1 June 27 /30, 2003 402 403, Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad – 380006 (Roopal Panchal)
- 321
2 September 27-29, 2003
68, Samashta B Society Opp Pinakin Soc Paldi, Ahmedabad (Kelan Atul Doshi)
500
3 November 6, 2003 402 403, Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad – 380006 (Roopal Panchal)
570
4 December 16 / 17, 2003
402 403, Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad – 380006 ( Roopal Panchal)
1220
5 January 2004 C/o P P Jhaveri, 804, Abhijeet I Mithakhali Circle, Ellisbridge, Ahmedabad (Parag Jhaveri)
565
6 January 5 / 6, 2004 402 403, Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad – 380006 (Roopal Panchal)
- 3,200
7 February 16, 2004 402 403, Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad – 380006 ( Roopal Panchal)
- 1529
8 April 20, 2004 C/o. SEIPL, G-1, Devpath Complex B/h. Lal Bunglow, Ahmedabad. (Sugandh Estates)
- 1096
2,742
564
8 August 16-17, 2004 402 403, Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad – 380006 (Roopal Panchal 68, Samashta B Society Opp Pinakin Soc Paldi, Ahmedabad (Kelan Atul Doshi) C/o. SEIPL, G-1, Devpath Complex B/h. Lal Bunglow, Ahmedabad. (Sugandh Estates)
4239
9 October, 15 - 26, 2004
C/o. SEIPL, G-1, Devpath Complex B/h. Lal Bunglow, Ahmedabad. (Sugandh Estates)
- 4,512
202 10 October 23, 2004 68, Samashta B Society Opp Pinakin Soc Paldi, Ahmedabad Kelan Atul Doshi C/o. SEIPL, G-1, Devpath Complex B/h. Lal Bunglow, Ahmedabad. (Sugandh Estates)
1559
Page 91 of 191
9.63. From the above table, it may be seen that thousands of fictitious / benami
dematerialized accouts were opened with Karvy DP with common addresses and
thousands of such dematerialized accounts were opened on one single day. Karvy
DP as per the SEBI guidelines relating to opening of dematerialized accounts was
under a duty to exercise due diligence while opening the dematerialized accounts.
That it did not do so shows that the obvious was apparently overlooked. It is clearly
indicative that Karvy was aware of the existence of fictitious afferent accounts.
11 Various dates in the year 2004
OTHERS LIKE D B MEHTA, D KATAKIA
820
12 July 08, 2005 Niketan Maheshwar, 33, Peddar Road, 5B (Manoj Sekseria
489 -
13 July 15, 2005 Office No 403, Shashwat Bldg nr. Hotel Kanak Ellisbridge Ahmedabad (Roopal Panchal)
4886
14 July 16, 2005 406, Shashwat Opp Gujarat College, Ellisbridge, Ahmedabad (Roopal Panchal)
9943
15 July 19, 2005 402 403, Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad – 380006 (Roopal Panchal)
- 1,004
16 July 20, 2005 402 403, Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad – 380006 (Roopal Panchal)
- 1,532
17 July 21, 2005 402 403, Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad – 380006 (Roopal Panchal)
- 755
18 July 22, 2005 B/2 Himalaya Asalaya Ghatkopar, W, Mumbai. (Purshottam Bhudhwani) Niketan Maheshwar, 33, Peddar Road, 5B (Manoj Sekseria)
2823 1135
- -
19 July 25, 2005 Niketan Maheshwar, 33, Peddar Road, 5B (Manoj Sekseria)
572
415 20 August 17, 2005 Niketan Maheshwar, 33, Peddar Road, 5B(Manoj Sekseria) B/2 Himalaya Asalaya Ghatkopar, W, Mumbai. (Purshottam Bhudwani) 136
-
718
21 August 2-5, 2005 68, Samashta B Society Opp Pinakin Soc Paldi, Ahmedabad (Ketan Atul bhai Doshi) 23, Payal Complex, Sayajigunj, Paldi, Baroda, 3900053 (biren kantilal shah)
-
780 22 August 16 / 17 2005 C/o P P Jhaveri, 804, Abhijeet I Mithakhali Circle,
Ellisbridge, Ahmedabad (Parag Jhaveri) 881
Total 20,399 29,309
Page 92 of 191
9.64. Charecteristics of the afferent dematerialized accounts
In respect of the afferent dematerialized accounts opened with Karvy DP, various
features that should have alerted the DP while opening the dematerialized accounts
were noticed.
9.65. Afferent Accounts opened on the Same Date
A sample of 50 afferent dematerialized accounts opened with Karvy DP on the
same date i.e. July 19, 2005 is given below:
Sr No
Source Client ID
Source DP ID
Source DP Name
Name Of Source Client
Address Of Source Client
Date Of Opening
Of Demat Account
Date Of Closure Of Demat (If
Applicable) Account Status
1. 15442390 IN300394 Karvy Stock Broking Ltd
SURESH JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
2. 15442406 IN300394 Karvy Stock Broking Ltd
ABHAY JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
3. 15442414 IN300394 Karvy Stock Broking Ltd
DEVANSHI JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
4. 15442422 IN300394 Karvy Stock Broking Ltd
GULJAR JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
5. 15442439 IN300394 Karvy Stock Broking Ltd
JENNY JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
6. 15442447 IN300394 Karvy Stock Broking Ltd
LABDHA JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
7. 15442455 IN300394 Karvy Stock Broking Ltd
YASHI JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
8. 15442463 IN300394 Karvy Stock Broking Ltd
NIRU JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
9. 15442470 IN300394 Karvy Stock Broking Ltd
NITA JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
Page 93 of 191
Sr No
Source Client ID
Source DP ID
Source DP Name
Name Of Source Client
Address Of Source Client
Date Of Opening
Of Demat Account
Date Of Closure Of Demat (If
Applicable) Account Status
10. 15442489 IN300394 Karvy Stock Broking Ltd
UTPALL JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
11. 15442498 IN300394 Karvy Stock Broking Ltd
ABHIGNA JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
12. 15442502 IN300394 Karvy Stock Broking Ltd
BALWANT JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
13. 15442519 IN300394 Karvy Stock Broking Ltd
DEVARSHI JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
14. 15442527 IN300394 Karvy Stock Broking Ltd
GUMAN JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
15. 15442535 IN300394 Karvy Stock Broking Ltd
JHANKI JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
16. 15442543 IN300394 Karvy Stock Broking Ltd
LAGNI JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
17. 15442550 IN300394 Karvy Stock Broking Ltd
YASHU JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
18. 15442569 IN300394 Karvy Stock Broking Ltd
NIRUPAMA JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
19. 15442578 IN300394 Karvy Stock Broking Ltd
NITANSH JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
20. 15442586 IN300394 Karvy Stock Broking Ltd
SWATI JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
21. 15442594 IN300394 Karvy Stock Broking Ltd
ABHILAS JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
22. 15442609 IN300394 Karvy Stock Broking Ltd
BALVIR JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
23. 15442617 IN300394 Karvy Stock Broking Ltd
DEVASYA JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
24. 15442625 IN300394 Karvy Stock Broking Ltd
GUNISH JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
Page 94 of 191
Sr No
Source Client ID
Source DP ID
Source DP Name
Name Of Source Client
Address Of Source Client
Date Of Opening
Of Demat Account
Date Of Closure Of Demat (If
Applicable) Account Status
25. 15442633 IN300394 Karvy Stock Broking Ltd
JIGAR JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
26. 15442640 IN300394 Karvy Stock Broking Ltd
LAHAR JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
27. 15442659 IN300394 Karvy Stock Broking Ltd
YATNA JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
28. 15442668 IN300394 Karvy Stock Broking Ltd
NIRVI JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
29. 15442676 IN300394 Karvy Stock Broking Ltd
NITIN JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
30. 15442684 IN300394 Karvy Stock Broking Ltd
TRUSHIT JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
31. 15442692 IN300394 Karvy Stock Broking Ltd
ABHISHEK JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
32. 15442705 IN300394 Karvy Stock Broking Ltd
BANJUL JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
33. 15442713 IN300394 Karvy Stock Broking Ltd
DEVENDRA JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
34. 15442720 IN300394 Karvy Stock Broking Ltd
GUNJAK JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
35. 15442739 IN300394 Karvy Stock Broking Ltd
JIGISH JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
36. 15442748 IN300394 Karvy Stock Broking Ltd
LAJJA JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
37. 15442756 IN300394 Karvy Stock Broking Ltd
YATRI JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
38. 15442764 IN300394 Karvy Stock Broking Ltd
NISAR JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
39. 15442772 IN300394 Karvy Stock Broking Ltd
DEPARV JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
Page 95 of 191
Sr No
Source Client ID
Source DP ID
Source DP Name
Name Of Source Client
Address Of Source Client
Date Of Opening
Of Demat Account
Date Of Closure Of Demat (If
Applicable) Account Status
40. 15442789 IN300394 Karvy Stock Broking Ltd
TUKHAR JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
41. 15442797 IN300394 Karvy Stock Broking Ltd
ADIP JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
42. 15442800 IN300394 Karvy Stock Broking Ltd
BANKIM JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
43. 15442819 IN300394 Karvy Stock Broking Ltd
DEVI JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
44. 15442828 IN300394 Karvy Stock Broking Ltd
JIMESH JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
45. 15442836 IN300394 Karvy Stock Broking Ltd
LAKENDRA JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
46. 15442844 IN300394 Karvy Stock Broking Ltd
YAVAN JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
47. 15442852 IN300394 Karvy Stock Broking Ltd
MIYA JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
48. 15442869 IN300394 Karvy Stock Broking Ltd
ROHINI JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
49. 15442877 IN300394 Karvy Stock Broking Ltd
TURANG JANI
402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 11/24/2005 CLOSED
50. 15442885 IN300394 Karvy Stock Broking Ltd
ADITI JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
7/19/2005 1/3/2006 CLOSED
9.66. It is seen that all the above afferent dematerialized accounts were opened on July
19, 2005. All the account holders had the same surname viz. “Jani”. All the account
holders had the same address i.e. 402 403 SHASWAT, OPP GUJARAT
COLLEGE, ELLISBRIDGE, AHMEDABAD, 380006, which is the address of key
operator viz. the Panchal family. The names of the account holders run in the same
series from “Suresh” to “Aditi”, as contained in the 50 names added to the IOB
bank account no.12140, which has been discussed in detail in earlier paragraphs.
Page 96 of 191
9.67. Pursuant to verification of the genuineness conducted by Karvy DP during
November 2005 i.e. subsequent to the commencement of SEBI’s preliminary
enquiry into the matter, the DP had closed these dematerialized accounts.
9.68. Another sample of 50 such afferent accounts opened by Karvy DP for another key
operator viz. the Jhaveri group on January 7, 2004 is given below:
Sr No
Source Client ID
Source DP ID
Source DP Name
Name of Source Client
Address of Source Client
Date of Opening of Demat Account
Date of Closure of Demat (If
Applicable)
Account Status
1. 13120297 IN300394 Karvy Stock Broking Ltd.
AJAY B PARIKH
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
2. 13119893 IN300394 Karvy Stock Broking Ltd.
AJIT B PARIKH
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
3. 13119869 IN300394 Karvy Stock Broking Ltd.
AMI I PARIKH
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
4. 13120239 IN300394 Karvy Stock Broking Ltd.
ASHWIN J MEHTA
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
5. 13120272 IN300394 Karvy Stock Broking Ltd.
BHADRESH S PARIKH
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
6. 13120560 IN300394 Karvy Stock Broking Ltd.
BHANUPRASAD M SONI
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
7. 13119819 IN300394 Karvy Stock Broking Ltd.
BHARAT K PARIKH
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
8. 13119756 IN300394 Karvy Stock Broking Ltd.
BHARTI C DESAI
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
9. 13120256 IN300394 Karvy Stock Broking Ltd.
BHUPENDRA B MEHTA
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
10. 13120289 IN300394 Karvy Stock Broking Ltd.
BIJAL R PARIKH
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
11. 13120094 IN300394 Karvy Stock Broking Ltd.
BIJAL S DESAI
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
Page 97 of 191
12. 13119965 IN300394 Karvy Stock Broking Ltd.
BIRVA J PARIKH
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
13. 13120205 IN300394 Karvy Stock Broking Ltd.
CHANDRAKANT R DESAI
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/30/2005 CLOSED
14. 13119828 IN300394 Karvy Stock Broking Ltd.
CHETAN D PARIKH
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
15. 13120109 IN300394 Karvy Stock Broking Ltd.
DAKSHA M MEHTA
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
16. 13120213 IN300394 Karvy Stock Broking Ltd.
DAKSHA S MEHTA
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
17. 13119844 IN300394 Karvy Stock Broking Ltd.
DEPTI A DESAI
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
18. 13120133 IN300394 Karvy Stock Broking Ltd.
HARSHIDABEN B SONI
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
19. 13119932 IN300394 Karvy Stock Broking Ltd.
ILA M DESAI
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
20. 13119877 IN300394 Karvy Stock Broking Ltd.
ILESH A PARIKH
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
21. 13119772 IN300394 Karvy Stock Broking Ltd.
JANAK S DESAI
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
22. 13119924 IN300394 Karvy Stock Broking Ltd.
JASUMATI N DESAI
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
23. 13120588 IN300394 Karvy Stock Broking Ltd.
JIGNESH P DESAI
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
24. 13120336 IN300394 Karvy Stock Broking Ltd.
JITENDRA K PARIKH
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
25. 13120159 IN300394 Karvy Stock Broking Ltd.
KETKI A DESAI
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
26. 13120168 IN300394 Karvy Stock Broking Ltd.
KEYURI A DESAI
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
27. 13120125 IN300394 Karvy Stock Broking Ltd.
MADHUSUDAN M SONI
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
Page 98 of 191
28. 13120117 IN300394 Karvy Stock Broking Ltd.
MAHENDRA H MEHTA
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
29. 13120264 IN300394 Karvy Stock Broking Ltd.
MANAN B PARIKH
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
30. 13120069 IN300394 Karvy Stock Broking Ltd.
MANAN M MEHTA
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
31. 13119908 IN300394 Karvy Stock Broking Ltd.
MAULIN T MEHTA
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
32. 13119885 IN300394 Karvy Stock Broking Ltd.
MRUDULA A PARIKH
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
33. 13120086 IN300394 Karvy Stock Broking Ltd.
MRUDULABEN J PARIKH
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
34. 13120140 IN300394 Karvy Stock Broking Ltd.
MRUGAVATI A DESAI
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
35. 13119764 IN300394 Karvy Stock Broking Ltd.
NIKITA C DESAI
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
36. 13120176 IN300394 Karvy Stock Broking Ltd.
NILIMA A DESAI
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
37. 13120328 IN300394 Karvy Stock Broking Ltd.
NRUPAL M PARIKH
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
38. 13120035 IN300394 Karvy Stock Broking Ltd.
PARESH D DESAI
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
39. 13120019 IN300394 Karvy Stock Broking Ltd.
PIYUSH M SONI
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
40. 13119957 IN300394 Karvy Stock Broking Ltd.
PRASHANT M DESAI
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
41. 13119973 IN300394 Karvy Stock Broking Ltd.
PUNITA T MEHTA
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
42. 13120300 IN300394 Karvy Stock Broking Ltd.
PURVI A PARIKH
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
43. 13120248 IN300394 Karvy Stock Broking Ltd.
RASHMI B MEHTA
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
Page 99 of 191
44. 13120050 IN300394 Karvy Stock Broking Ltd.
ROOPA D DESAI
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
45. 13120192 IN300394 Karvy Stock Broking Ltd.
RUPA M PARIKH
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
46. 13119852 IN300394 Karvy Stock Broking Ltd.
RUPAL A PARIKH
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
47. 13119797 IN300394 Karvy Stock Broking Ltd.
SHOBHANA S DESAI
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
48. 13119980 IN300394 Karvy Stock Broking Ltd.
SUBHADRA H MEHTA
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
49. 13120319 IN300394 Karvy Stock Broking Ltd.
SUBHASH H MEHTA
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
50. 13120184 IN300394 Karvy Stock Broking Ltd.
SUMI R DESAI
C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006
1/7/2004 12/16/2005 CLOSED
9.69. It may be seen that all the account holders had the address of C O K P JHAVER,
803 ABHIJIT, MITHAKALI CIRCLE ELLISBRIDG, AHMEDABAD, 380006,
which is the address of a key operator viz. the Jhaveri group. Pursuant to
verification of the genuineness conducted by Karvy DP during November 2005 i.e.
subsequent to the commencement of SEBI’s preliminary enquiry into the matter,
the DP had closed these dematerialized accounts.
9.70. Afferent Accounts with the same Surname
It was found that many of the afferent dematerialized account-holders had common
surnames. A summary of some such common surnames are given below:
Sr. no.
Surname No. of afferent demat accounts
Address Date of Opening Date of Closure
1. Daksha Luhar (13015876) to Induben Luhar (13021863)
600 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
16 – 18 December 2003
November – December 2005
2. Daksha Pari 600 402 403 Shashwat, 16 – 19 November –
Page 100 of 191
Sr. no.
Surname No. of afferent demat accounts
Address Date of Opening Date of Closure
(13040728) to Induben Pari (13046715)
Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
December 2003 December 2005
3. Daksha Mistri (13139789) to Induben Mistri (13145777)
600 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
5-6 January 2004 November 16 – 17, 2005 (one account closed in January 2006)
4. Daksha Shroff (13145785) to Induben shroff (13151778)
600 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
5-6 January 2004 November – December 2005 (one account closed in January 2006)
5. Daksha Soni (14243715) to Induben Soni (14249666)
589 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
16 / 18 August 2004
November 2005 (two accounts closed in January 2006)
6. Daksha Suthar (14249674) to Induben Suthar (14255448)
578 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
16 / 18 August 2004
November 2005 (four accounts closed in January 2006)
7. Daksha Patel (14255456) to Induben Patel (14261229)
578 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
16 / 18 August 2004
November – December 2005 (four account s closed in January 2006)
8. Daksha Joshi (14349790) to Induben Joshi (14355564)
578 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
16 / 18 August 2004
November – December 2005
9. Daksha Dapki (15457926) to Induben Dapki (15463820)
591 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
20-21 July 2005 November 28, 2005
10. Daksha Panchal (12912969) to Ayushi Panchal (12915969)
301 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
6 / 24 November 2003
November – December 2005
11. Daksha Kadia (14261238) to Samik Kadia (14263753)
253 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
16 August 2004 November 23 – 24, 2005
12. Daksha Rami (15463839) to Naymesh Rami (15467905)
407 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
20-21 July 2005 November – December 2005
13. Dasharath Seth (13162815) to Badri Seth (13163300)
50 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
20-21 July 2005 November – December 2005
14. Kunal Seth (13129788) to Babita Seth (13139770) *
1000 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006
5-6 January 2004 (two accounts opened on 12.04.04)
November – December 2005
Total 7325 * - includes the set of 50 names from Suresh Seth to Aditi Seth as referred to earlier in
various contexts.
Page 101 of 191
9.71. From the above table, it may be seen that thousands of afferent dematerialized
accounts were opened on a few dates. The thousands of the afferent account holders
had a few common surnames. The address of the afferent dematerialized account-
holders was indicated as the address of the key operator viz. Roopalben Panchal.
9.72. During November – December 2005, pursuant to verification of genuineness of the
account holders in the wake of SEBI preliminary enquiry in the matter, Karvy DP
had closed these dematerialized accounts.
9.73. The contention of Karvy DP that the applications were not received on the same
date and because it follows a batch processing system, the dematerialized accounts
were opened on the same day does not absolve it of its apparent failure to exercise
due diligence while opening the dematerialized accounts. Further, even if the
applications had not been received on a single day, it is clear that they would have
been received around the same period and were processed by the DP on one or a
few days. Further, admittedly, Karvy DP follows a batch processing system
whereby many applications are verified, uploaded and activated en masse. Thus,
when the DP had processed these applications together, it should have got alerted
regarding the features of the applications as seen from the table above. In any case,
as brought out by the discussions in this order, it was not mere failure to exercise
due diligence that made Karvy to overlook these tell-tale signs. It is something
more than that.
9.74. Examination of dematerialized accounts pending activation
With regard to the dematerialized accounts that had been opened by Karvy DP and
were pending for activation, during the course of the instant proceeding, Karvy DP
was advised to submit the dematerialized account opening forms and the KYC
documents. In this regard, Karvy DP vide letter dated June 8, 2007 stated that “The
demat account opening forms pertaining to the clients of the sub broker Grace
Page 102 of 191
Consultancy, which are pending for activation, are not available with us as the same
were returned back to the sub broker for complying with the required
documentation at that point of time”. From the submission of Karvy DP it can be
deduced that when the DP entered the details in the CDSL system and generated
BO IDs, the documentation in respect of the dematerialized accounts was either
incomplete or absent. Though the DP may argue that the dematerialized accounts
were not activated, it is clear that the DP opened dematerialized accounts on the
basis of incomplete / non-existent documents. In the face of such fait accompli, the
plea that the documents were incomplete and hence returned to the ‘sub-broker’
does not cut much ice.
9.75. Further, an examination of the details of these 10,000 dematerialized accounts
shows that the account holders had 10 common surnames in sets of 1000 each.
Further all these account holders had their bank accounts with Indian Overseas
Bank. The details are as below:
Sr. No.
Starting Name Last Name No of accounts
Date of opening
IOB Bank account No
Remarks
1. KUNAL KAPUR RITU KAPUR 1000 22-Sep-05 2611-15001 to 2611- 16000
Account opening forms returned
2. KUNAL TATED RITU TATED 1000 22-Sep-05 2611-16001 to 2611 - 17000
Account opening forms returned
3. KUNAL KELA RITU KELA 1000 22-Sep-05 2611-17001 to 2611-18000
Account opening forms returned
4. KUNAL SEN RITU SEN 1000 22-Sep-05 2611-18001 to 2611-19000
Account opening forms returned
5. KUNAL ROY RITU ROY 1000 22-Sep-05 2611-19001 to 2611-20000
Account opening forms returned
6. KUNAL IRANI RITU IRANI 1000 22-Sep-05 2611-20001 to 2611-21000
Account opening forms returned
7. KUNAL JHA RITU JHA 1000 22-sep-05 2611-21001 to 2611-22000
Account opening forms returned
8. KUNAL MEHTA RITU MEHTA 1000 22-sep-05 2611-22001 to 2611-23000
Account opening forms returned
9. KUNAL DAS RITU DAS 1000 22-sep-05 2611-23001 to 2611-24000
Account opening forms returned
10. KUNAL PRASAD RITU PRASAD 1000 22-sep-05 2611-24001 to 2611-25000
Account opening forms returned
Total 10000
Page 103 of 191
9.76. The details of 50 such accounts on a sample basis is given below. It may be
mentioned that as per the demat records all the account holders mentioned in the
table below had their Savings Bank account with IOB, Stadium Road Branch.
BOID AccOp Date BOName BOAdd BOCity BOPin DPName
Ben BankMICR
BenBank AccNo
1301440000399716 22092005 KUNAL KAPUR .
Office No.402, Shashwat Bldg. Nr. Hotel Kanak Ellisbridge AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15001
1301440000399720 22092005 BAKULA KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15002
1301440000399735 22092005 GRAHI KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15003
1301440000399741 22092005 JAYSHREE KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15004
1301440000399754 22092005 KUNJ KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15005
1301440000399769 22092005 YAGNA KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15006
1301440000399773 22092005 NIRAV KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15007
1301440000399788 22092005 NISHA KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15008
1301440000399792 22092005 RAMESH KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15009
1301440000399809 22092005 AAKASH KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15010
1301440000399813 22092005 BALA KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15011
1301440000399828 22092005 DEV KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15012
1301440000399832 22092005 GRASHIT KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15013
1301440000399847 22092005 JEET KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15014
1301440000399851 22092005 KUNJAL KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING 380020011
2611-15015
Page 104 of 191
LIMITED
1301440000399866 22092005 YAJAN KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15016
1301440000399870 22092005 NIRBHAY KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15017
1301440000399885 22092005 NISHANT KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15018
1301440000399891 22092005 RANI KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15019
1301440000399906 22092005 AANSHI KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15020
1301440000399910 22092005 BALCHAND KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15021
1301440000399925 22092005 DEVAN KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15022
1301440000399931 22092005 GRISHA KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15023
1301440000399944 22092005 JEEVAN KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15024
1301440000399959 22092005 KUNTI KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15025
1301440000409461 22092005 VIRAJ KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15976
1301440000409476 22092005 BADAL KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15977
1301440000409480 22092005 DAXESH KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15978
1301440000409495 22092005 GIRISH KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15979
1301440000409501 22092005 JAVAL KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15980
1301440000409516 22092005 KOMAL KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15981
1301440000409520 22092005 UDAYA KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15982
Page 105 of 191
1301440000409535 22092005 MINA KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15983
1301440000409541 22092005 SUMIT KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15984
1301440000409554 22092005 RAKESH KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15985
1301440000409569 22092005 BADREN KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15986
1301440000409573 22092005 DAYA KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15987
1301440000409588 22092005 GIRISHA KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15988
1301440000409592 22092005 JAY KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15989
1301440000409609 22092005 KONY KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15990
1301440000409613 22092005 UDHBHAV KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15991
1301440000409628 22092005 MINAKSHI KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15992
1301440000409632 22092005 SUNIL KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15993
1301440000409647 22092005 RAKHI KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15994
1301440000409651 22092005 VIRAL KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15995
1301440000409666 22092005 BADRI KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15996
1301440000409670 22092005 DIPTI KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15997
1301440000409685 22092005 SAUNIL KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15998
1301440000409691 22092005 DIYA KAPUR . Same as above AHMEDABAD 380006
KARVY STOCK BROKING LIMITED 380020011
2611-15999
1301440000409706 22092005 RITU Same as above AHMEDABAD 380006 KARVY 380020011 2611-
Page 106 of 191
KAPUR . STOCK BROKING LIMITED
16000
9.77. From the above table, it may be seen that the above dematerialized accounts were
opened in bulk on the same date and have the same address. The account holders
had common surnames. Further, it is seen that the dematerialized account holders
have bank accounts with consecutive numbers.
9.78. Further, as narrated in a later paragraph, the characteristics of the above account
holders matches that of the clients financed by KCL through IPO finance provided
to key operators who were sub-brokers of KSBL for IPO distribution. In this regard,
I note that SEBI in the interim order dated April 27, 2006 had indicated “accounts
opened but not activated. Probably were meant to be used later”. Karvy DP in its
reply dated May 09, 2006 to the observations of the interim order had stated “This
observation itself is indicative of the bias against us by you. The observations is in
the realm of conjectures, surmises and hypothesis and is totally unjustified and
uncalled for.”
Thus, the earlier inference of SEBI that the 10,000 dematerialized accounts
indicated in the table above were meant to be used in subsequent IPOs appears to be
correct.
9.79. Examination of Demat Accounts closed by Karvy DP
Karvy-DP vide e-mail dated January 30, 2006 furnished the details of accounts
closed by Karvy-DP where 20 or more dematerialized account-holders share
common addresses. Upon perusal of the information it is seen that Karvy-DP has
closed 38,409 accounts held with CDSL and 30,221 accounts held with NSDL.
Prior to these closures Karvy-DP had 43,327 BO accounts with CDSL and 7,56,886
BO accounts with NSDL. Thus, it is seen that about 90% of the CDSL accounts
held with Karvy-DP have been closed in the course of verification of genuineness
of account-holders. Upon examining the details of the dematerialized accounts
Page 107 of 191
closed by Karvy-DP (taking address 1 as the basis for analysis), the following
observations emerge:
Sr. No.
Address No. of dematerialized account-holders sharing the address
Name of the Depository
Comments
1 C O SEIPL, 804 Abhijeet I, Mithakhali Circle, Ahmedabad – 380009
5793 NSDL This address is same as that of SEIPL
2 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad - 380006
5492 NSDL This address is same as that of the Panchals
3 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad - 380006
3180 NSDL This address is same as that of the Panchals
4 402-403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad – 380006
1710 NSDL This address is same as that of the Panchals
5 C/0 SEIPL, 804 Abhijeet I, Mithakhali Circle Ellisbridge, Ahmedabad-380006
1472 NSDL This address is same as that of SEIPL
6 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad - 380006
1415 NSDL This address is same as that of the Panchals
7 68 Samshta B Society, Opp Pinakin Society, Paldi, Ahmedabad-380007
1293 NSDL This address is same as that of Kelan Atulbhai Doshi
8 C/O SEIPL, 804 Abhijeet I, Mithakhali Circle, Ellisbridge Ahmedabad- 380006
1214 NSDL This address is same as that of SEIPL
9 803 Abhijit, Mithakhali Circle, Ellisbridge, Ahmedabad-380006
1099 NSDL This address is same as that of SEIPL
10 406, Shashwat, Opp. Gujarat College, Ellisbridge, Ahmedabad, 380006
4998 CDSL This address is same as that of the Panchals
11 307, Shashwat, Opp. Gujarat College, Ellisbridge, Ahmedabad, 380006
4975 CDSL This address is same as that of the Panchals
12 Office No.403, Shashwat Bldg., Nr. Hotel Kanak, Ellisbridge, Ahmedabad, 380006
4961 CDSL This address is same as that of the Panchals
13 Himalaya B-2, Asalfa, Ghatkopar W, Mumbai 400084
3814 CDSL This address is same as that of Budhwani
14 C/o. SEIPL, G-1, Devpath Complex, B/h. Lal Bunglow, Navrangpura, Ahmedabad, 380009
2500 CDSL This address is same as that of SEIPL
15 Niketan Maheshwar 33, Peddar Road 5B, Mumbai - 400026
1120 CDSL This address is same as that of Seksaria
16 Maheshwar Niketan 33,Pedd, Mumbai, 400026
822 CDSL This address is same as that of Seksaria
Page 108 of 191
9.80. From the above table relating to demat accounts closed by Karvy DP, it is seen that
Karvy DP had opened numerous (running into many hundreds) demat accounts with
common addresses, the common addresses being that of Karvy DP’s sub-brokers
namely Grace Consultancy, C/o Dipak Panchal, who is the husband of Devangi
Panchal and the brother-in-law of Roopalben Panchal, Arth Realty Pvt. Ltd. (related
to SEIPL), Purshottam Budhwani and Manojdev Seksaria.
9.81. Other observations regarding dematerialized accounts opened with Karvy DP
In view of the cornering of retail portion of IPO shares observed in the case of Yes
Bank IPO and the fact that almost all the afferent dematerialized accounts that were
used for the cornering were held with Karvy DP, SEBI advised the depositories to
conduct inspection of the DP and submit report to SEBI. Based on the inspection
report of CDSL, it was noticed that BhOB has issued letters, which showed that
multiple bank accounts have been opened by same person (same photograph) with
different names and possessing the same or similar address. Some of such cases are
listed below:
Multiple bank accounts opened with same photograph Sr.no. Name A/c no. with
BhOB Name A/c no. with BhOB Name A/c no. with
BhOB
1 Bhagyesh Vania 9550-12175 Abhilash Rathi 9550-2068 Abhilash Desai 9550-1068
2 Darni Verma 9550-3909 Karina Desai 9550-1576 Aarti Zala 9550-10040
3 Agat Pathak 9550-8117 Bhadresh Vala 9550-7165 ---- ----
4 Aanshi Pandya 9550-20 Aanshi Rathi 9550-2020 ---- ----
5 Bablu Pathak 9550-8958 Aakash Verma 9550-3010 ---- ----
6 Abhishek Rathi 9550-2078 Abhishek Desai 9550-1078 ---- ----
7 Agni Pathak 9550-8137 Badren Barot 9550-6986 ---- ----
8 Akshar Bhatt 9550-9222 Bablu Patil 9550-13958 ---- ----
9 Bhadresh Desai 9550-1165 Bhadresh Rathi 9550-2165 ---- --.....
10 Aditya Pandya 9550-107 Aakash Patil 9550-13010 ---- ----
11 Abhilash Verma 9550-3068 Agat Pandya 9550-117 ---- ----
12 Agat Rathi 9550-2117 Agat Desai 9550-1117 ---- ----
Page 109 of 191
Demat accounts opened with Karvy DP for the aforesaid account holders Sr. No Name BOlD Name BOlD Name BOlD 1 Bhagyesh Vania 78034 Abhilash Rathi 126968 Abhilash Desai 116966 2 Dami Verma 145379 Karina Desai 122049 Aarti Zala 56681 3 Agat Pathak 187451 Bhadresh Vala 177937 ---- ---- 4 Aanshi Pandya 106487 Aanshi Rathi 126480 ---- ---- 5 Bablu Pathak 195861 Aakash Verma 136385 ---- ---- 6 Abhishek Rathi 127066 Abhishek Desai 117064 ---- ---- 7 Agni Pathak 187656 Badren Barot 176141 ---- ---- 8 Akshar Bhatt 198501 Bablu Patil 95869 ---- ---- 9 Bhadresh Desai 117936 Bhadresh Rathi 127938 ---- ---- 10 Aditya Pandya 107351 Aakash Patil 86383 ---- ---- 11 Abhilash Venna 136961 Agat Pandya 107457 ---- ---- 12 Agat Rathi 127450 Agat Desai 117459 ---- ---- 9.82. In cases of letters of Vijaya Bank (VB) accepted by Karvy DP towards POI and
POA for opening demat accounts, it was observed that the signature column of the
branch manager consisted of just 'two ticks' and apparently such impression does
not appear to constitute a bonafide signature.
9.83. Demat Accounts opened with POI and POA
In case of accounts opened by Karvy DP on the basis of the letters issued by VB, it
was observed that in many instances the date of opening of the BO account was
much earlier than the date of issue of such letter issued by VB. Some of such
instances are mentioned as under:
BOlD Date of account opening Date of POI & POA from Vijaya Bank 390669 27/8/05 08/09/05 389826 14/7/05 08/09/05 390181 17/8/05 08/09/05 390329 17/8/05 08/09/05 390293 17/8/05 08/09/05 390071 17/8/05 08/09/05 390196 17/8/05 08/09/05 390202 17/8/05 08/09/05 390221 17/8/05 08/09/05 389923 17/8/05 08/09/05 390240 17/8/05 08/09/05 391170 27/8/05 08/09/05
Page 110 of 191
9.84. Different BOs with same signatures
It was observed that the signature of the different BOs substantially match with each
other. Some of the instances are as under :
9.85. Consolidated Payment of account charges for various demat accounts:
The inspection of Karvy DP by SEBI revealed that the DP had accepted third party
cheques for dues payable by various BOs. In case of 225 accounts, Karvy DP had
accepted a single cheque (Cheque Number 273329 issued by HDFC Bank
Navranpura, Ahmedabad) towards their dues. Similarly in case of 1276 accounts a
single cheque (Cheque Number 699328 issued by HDFC Bank, Navrangpura,
Ahmedabad) was accepted by Karvy DP. It was further observed that the DP had
issued a single receipt in case of the amount paid on behalf of various accounts.
Similarly in various accounts of Panchal Family/group a single consolidated cheque
had been deposited by a third party on behalf of these account holders to settle the
outstanding dues. Such practices are at variance with the market practices and clearly
demonstrate tha Karvy DP knew for certain that it was only dealing with Roopalben
Panchal or other key operators while purporting to deal with others on paper.
9.86. Based on information furnished to SEBI by Karvy DP vide letter dated June 8,
2007, it is seen that Karvy DP had accepted consolidated payments from key
Sr.No BOID Name BOID Name BOID Name
1 108159 Hari Pandya 188153 Hari Pathuk 158158 Hari Trivedi
2 168151 Hari Barot 178151 Hari Vala 118150 Hari Desai
3 392856 Munny B Gupta 390859 Munni B Maniar 382854 Munni B Chokshi
4 143825 Jacky Verma 73821 Jacky Rathod 93823 Jacky Patil
5 227392 Dani D Pritam 227559 Dani D P (different person) ---- ----
6 171842 Fida Barot 111841 Fida Pandya ---- ----
7 111744 Fenil Pandya 121746 Fenil Desai. ----- ----
8 61645 Fena Zala 81649 Fena Vania 181641 Fena Vala
9 202046 Karina Bhatt 152044 Karina Gandhi 172048 Karina Barot
Page 111 of 191
operators towards AMC charges and transaction charges of numerous
dematerialized accounts held with the DP. The details are given below:
CHEQUE COLLECTION AMOUNT (PANCHAL)
Total AMC Charges Transactions Charges
Slno Chq_no Date Bank Name No of Accounts
Amount No of Accounts Amount
No of Accounts
Amount
1 627986 12-May-03 HDFC 4 2743.00 4 2743.00 2 907406 12-May-03 HDFC 3 2449.00 3 2449.00 3 907407 12-May-03 HDFC 1 780.00 1 780.00 4 984761 12-May-03 HDFC 1 1589.00 1 1589.00 5 6278986 12-May-03 HDFC 1 192.00 1 192.00 6 774641 12-May-03 ICICI 1 324.00 1 324.00 7 780184 12-May-03 ICICIC 1 371.00 1 371.00 8 749833 12-May-03 VIJAYA 1 316.00 1 316.00 9 417618 22-Aug-03 HDFC BANK 1 146.00 1 146.00 10 766900 09-Sep-03 VIJAYA 1 150.00 1 150.00 11 273329 24-0ct-03 HDFC BANK 225 11250.00 225 11250.00 12 699328 24-Dec-03 HDFC BANK 1277 63850.00 1277 63850.00 13 699329 24-Dec-03 HDFC BANK 600 30000.00 600 30000.00
14 815625 24-Mar-04 BANK OF BARODA 1 119.32 1 119.32
15 144388 31-Mar-04 BOBL 1334 200000.00 1334 200000.00 16 394242 10-Jun-04 HDFC BANK 1 2600.00 1 2600.00 17 774588 24-Jul-04 ICICI 1 319.62 1 319.62 18 907683 24-Jul-04 ICICI 1 439.03 1 439.03 19 941364 24-Jul-04 ICICI 1 883.58 1 883.58 20 955211 24-Jul-04 ICICI 926 100000.00 926 100000.00 21 853131 24-Jul-04 S CB 1 966.12 1 966.12 22 853128 24-Jul-04 SCB 1 191.64 1 191.64 23 853129 24-Jul-04 SCB 1 110.43 1 110.43 24 853130 24-Jul-04 SCB 1 256.83 1 256.83 25 865238 24-Jul-04 SCB 1 198.06 1 198.06 26 984167 24-Jul-04 SCB 1 124.20 1 124.20 27 984168 24-Jul-04 SCB 1 135.34 1 135.34 28 984171 24-Jul-04 SCB 1 1162.14 1 1162.14 29 984172 24-Jul-04 SCB 1 477.36 1 477.36 30 985719 24-Jul-04 SCB 1 254.89 1 254.89 31 986122 24-Jul-04 SCB 1 526.72 1 526.72 32 984169 24-Jul-04 SCCB 1 126.24 1 126.24
33 984170 24-Jul-04 STANDARD CHARTERED 1 316.45 1 316.45
34 749844 24-Jul-04 VIJAYA 1 180.49 1 180.49 35 955249 19-Aug-04 ICICI BANK 2507 300000.00 2507 300000.00 36 152462 25-Aug-04 BOBL 566 56600.00 566 56600.00
37 151219 19-Nov-04 STANDARD CHARTERED 428 295500.00 428 295500.00
38 623168 21-Jan-05 hdfc bank 171 45000.00 171 45000.00 39 774593 25-J an-05 ICICI 1 211.58 1 211.58 40 907688 25-Jan-05 ICICI 1 380.19 1 380.19 41 936348 25-J an-05 ICICI 1 928.99 1 928.99 42 940881 25-Jan-05 ICICI 1 232.52 1 232.52
Page 112 of 191
43 941368 25-J an-05 ICICI 1 631.45 1 631.45 44 943874 25-J an-05 ICICI 4 1078.78 4 1078.78 45 962365 25-J an-05 ICICI 1 1147.18 1 1147.18 46 940692 25-J an-05 ICII 4 3389.79 4 3389.79 47 984188 25-Jan-05 SCB 1 284.32 1 284.32 48 749850 25-J an-05 VIJAYA 1 160.89 1 160.89 49 64640 28-Mar-05 SBI 1 327.00 1 327.00 50 815633 29-Mar-05 BOB 1 495.40 1 495.40
51 35625 09-Jun-05 VIJAYA BANK 1 414.00 1 414.00
52 983781 12-Jul-05 ICICI 2778 300000.00 2778 300000.00 53 426709 10-Nov-05 SBI 1 586.70 1 586.70 54 40553 29-Nov-05 CIT! BANK 1 520.00 1 520.00 55 80498 29-Nov-05 CIT! BANK 1 500.00 1 500.00
56 41747 22-Dec-05 VIJAYA BANK 1 496.00 1 496.00
Total 10869 1432433.25 10213 1061700.00 656 370733.25 CHEQUE COLLECTION AMOUNT
(JHAVERI)
Total AMC Charges Transactions Charges
Sino ChCl-no Date Bank Name No of Accounts Amount No of
Accounts Amount No of Accounts Amount
1 36442 11-Dec-03 SIDDHI CO-OP BANK 3 300.00 3 300.00
2 497953 11-Dec-03 VIJ AY A BANK 49 4900.00 49 4900.00
3 500376 08-J an-04 VIJAYA BANK 150 15000.00 150 15000.00
4 604590 08-J an-04 VIJAYA BANK 149 14900.00 149 14900.00
5 604855 08-J an-04 VIJAYA BANK 149 14900.00 149 14900.00
6 605500 08-J an-04 VIJAYA BANK 150 15000.00 150 15000.00
7 272992 10-J an-04 HDFC BANK 75 7500.00 75 7500.00
8 976373 24-Jul-04 VIJ A Y A 1 20244.60 1 20244.60
9 906815 25-Aug-04 VIJAYA BANK 1000 100000.00 1000 100000.00
10 185223 08-Nov-04 BHARA T OVERSEAS 225 22500.00 225 22500.00
11 909880 08-Nov-04 VIJAYA BANK 2500 250000.00 2500 250000.00
12 909888 18-Nov-04 VIJ AY A BANK 800 80000.00 800 80000.00
13 269230 25-Jan-05 HDFC 179 16800.00 179 16800.00
14 269231 25-Jan-05 HDFC 466 41751.64 466 41751.64
15 287528 25-Jan-05 HDFC 564 33600.00 564 33600.00
16 287529 25-Jan-05 HDFC 714 33660.00 714 33660.00
17 287530 25-J an-05 HDFC 2570 128996.25 2570 128996.25
18 255190 31-Mar-05 HDFC 174 11124.69 174 11124.69
19 255393 31-Mar-05 HDFC 204 12777.69 204 12777.69
Page 113 of 191
20 255789 31-Mar-05 HDFC 148 14182.74 148 14182.74
21 390999 31-Mar-05 HDFC 506 11157.75 506 11157.75
22 891948 31-Mar-05 VIJAYA 4150 122322.00 4150 122322.00
23 906878 31-Mar-05 VIJAYA 2436 78517.50 2436 78517.50
24 266069 25-May-05 VIJAYA BANK 1 1114.76 1 1114.76
25 906895 25-May-05 VIJAYA BANK 1 28381.69 1 28381.69
26 417645 17 -Nov-05 HDFC 3787 275500.00 3787 275500.00
27 417646 17 -Nov-05 HDFC 6771 206625.00 6771 206625.00
28 127526 02-Dec-05 BOB 1 86.16 1 86.16
Total 27923 1561842.47 5250 525000.00 22673 1036842.47
9.87. Summary of observations on the demat account holders of Karvy DP
Keeping in view of the discussions regarding the dematerialized accounts opened
by Karvy DP, the following conclusions emerge:
9.88. Thousands of dematerialized accounts were opened with Karvy DP on the same
date. Many of these afferent accounts had common surnames. The addresses of the
thousands of dematerialized account-holders were indicated as the addresses of the
key operators. In many instances, bank letters were accepted towards POI and POA.
Karvy itself had introduced the bank accounts of the dematerialized account-
holders. In certain instances, dematerialized accounts had been opened without
obtaining POI and POA. In certain instances, same photographs were used by
various BOs. In other instances, many BOs had the same signatures. Karvy DP had
accepted consolidated payments from the key operators towards numerous
dematerialized accounts maintained with the DP. As discussed elsewhere in this
order, Karvy DP had executed synchronized off-market transfers from the afferent
dematerialized accounts to the dematerialized accounts of the key operators using
pre-printed DIS and in certain cases even without the DIS. Pursuant to the
verification conducted in the wake of SEBI preliminary enquiry in the matter of
IPO irregularities, Karvy had closed these dematerialized accounts. Thus, it
emerges that these dematerialized account-holders whose accounts were held with
Karvy DP were fictitious / benami in nature and that Karvy was aware of it.
Page 114 of 191
9.89. From the above, it is seen that Karvy DP has admitted that it did not do any KYC
related verification while opening demat accounts and relied on the sub-brokers for
the same. In the criminal complaint, Karvy has admitted that these sub-brokers / key
operators had opened demat accounts in fictitious names.
9.90. The IPO financing provided by the Karvy to the afferent dematerialized account-
holders was released to the key operators and no money was released to the
ficititious / benami entities. The funds for IPO applicantions in the names of the
afferent demat account holders came from the bank accounts of the key operators /
sub-brokers of Karvy and not from the afferent dematerialized account-holders /
IPO applicants. Similarly the refund money also went to the bank accounts of the
key operators only.
9.91. From the above, it is logical to conclude that the thousands of dematerialized
account-holders whose demat accounts had been opened with Karvy DP were
fictitious / benami in nature and that Karvy was aware of the same.
9.92. Reliance on ‘sub-brokers’ for KYC verification
In terms of SEBI circulars dated August 4, 2000 and August 24, 2004, the KYC
verifications for the purpose of opening dematerialized accounts are required to the
carried out by the DP. The SEBI circular ref: MRD/DoP/Dep/Cir-29/2004 dated
August 24, 2004 specifically states that “While opening a BO Account, the DPs are
required to exercise due diligence while establishing the identity of the person to
ensure the safety and integrity of the depository system.”
9.93. With regard to the KYC verification done by it while verifying the identity of the
person, Karvy DP has claimed that it relied on sub-brokers appointed by it for
carrying out the verification process. This is in contravention of the SEBI circular
which places the onus on the DP to exercise due diligence while establishing
Page 115 of 191
identity of the person opening the demant account. Also, I do not find merit in the
contention of Karvy DP for the following reasons:
9.94. In terms of Regulation 52 of SEBI (Depositories and Participants) Regulations,
1996, “No Participant shall assign or delegate its functions as participant to any
other person, without the prior approval of the depository.” In the instant case, there
is nothing on record to suggest that Karvy DP had obtained the permission of
depositories to assign or delegate its function of carrying out KYC verifications
while opening demat accounts to its purported sub-brokers. Further, it may be noted
that in terms of SEBI (DP) Regulations, there is no concept of sub-broker.
9.95. Process flow adopted by Karvy DP for opening Demat Accounts
The process flow adopted while opening dematerialized accounts by Karvy DP for
KYC compliance in respect of applications procured through sub-brokers, as per
submissions of Karvy vide letter dated January 19, 2007 before the Enquiry Officer
is given below:
Page 116 of 191
Format 1 Format 2 Contains details including Contains details including Account no. Name Name Address Address 9 digit MICR Code 9 digit MICR Code Bank account no. Bank account no. Date of activation Status of account
PROCESS FOR ACTIVATION OF ACCOUNTS FROM SUB BROKERS
Shortcoming in KYC Documents
Seek fresh / additional documents
Scrutinize application form for completeness and KYC
Receive Data (Format – 1) and Application form from sub broker
Not collected – reject application and return to customer
Collected additional documents
Upload data to NSDL / CDSL & verify
KYC Documents complete
Scan the signature
Activate DP account
Send response file to sub broker (Format 2)
Page 117 of 191
9.96. From the above, it may be seen that as per the process flow detailed by Karvy –DP,
it needs to verify the KYC documents procured through the sub-brokers, while
opening dematerialized accounts.
9.97. In another proceeding in the matter of IPO irregularities, Karvy has produced a
letter dated June 8, 1999 issued to a key operator namely Shri Purshottam
Budhwani to substantiate their claim that the key operator was a sub-broker who
procured demat clients for Karvy DP. Upon perusal of the letter, it is observed that
the letter has been issued by Karvy Securities Ltd. intimating the allotment of sub-
broker code no.42338 to Shri Purshottam G Budhwani. The letter mentions that
“We will inform you the rate of sub broker payable to you for each issue
separately.” (emphasis supplied). Thus, a prima facie reading of the letter issued by
Karvy Securities Ltd. suggests that Shri Budhwani was expected to operate as a
sub-broker of Karvy Securities Ltd. for the purpose of procuring applicants in
public issues. Though Karvy might argue now that the word ‘issue’ should be
construed in its broader sense, I am of the view that the word ‘issue’ needs to be
given an interpretation in the context in which it appears i.e. in the context of Karvy
Securities Ltd. being an IPO broker. Therefore, it follows that Karvy Securities
Ltd., as an IPO broker, had appointed Shri Budhwani as a sub-broker and assigned
him a sub-broker code. It does not lie in the mouth of Karvy to claim now that it
had appointed Shri Budhwani as a sub-broker for its DP operations. In any case, as
noted earlier, there is no concept of sub-broker with regard to the activities of DP.
9.98. Further, in terms of the process flow for opening dematerialized accounts as per
Karvy DP’s own submissions also shows that the DP was required to conduct KYC
verification in respect of the demat clients procured through the sub-brokers.
9.99. Considering the above, Karvy DP’s claim of having relied on purported sub-
brokers that are neither registered with SEBI nor recognized in law for carrying out
the obligations relating to KYC verifications imposed upon Karvy DP as a SEBI
registered Depository Participant, rings hollow and the same deserves to be
Page 118 of 191
dismissed in toto. In any event the DP cannot palm off its duties under the
regulations to anyone else.
9.100. Role of KCL – IPO Financier
The next step in the IPO process after the opening of bank accounts and dematerialized
accounts is arrangement of IPO finance. It was found that for the purpose of arranging
IPO finance for its demat clients, Karvy DP had tied up with BhOB during June 2003.
The details of IPO financing done by BhOB in various IPOs pursuant to the tie-up with
Karvy is given below:
IPOs financed by BHOB
Name of IPO No. of applications relating to suspect entities
Amount Financed (Rs. In Lakhs)
Maruti Udyog 725 552.91 UCO Bank 1020 321.34 Vijaya Bank 878 318.19 Indraprastha Gas Ltd. 4631 1707.69 TV Today 8503 2446.92 Patni Computers 10386 2415.23 Bank of Maharashtra 347 83.17 Biocon 1487 236.49 TCS 7605 2040.16 NTPC 10473 3120.31 Jet Airways 3084 718.01 Jay Prakash Hydro 1950 468 Yes Bank 12778 3038.19 SPL 2594 635.53 ILFS 11030 2412.81 Sasken 16123 3977.12 Prthvi Comm. 12 5.67 Pyramid 16 6.37 IDFC 6898 1693.46 Suzlon 12 2.94
9.101. From the above table, it is seen that pursuant to the arrangement with Karvy,
BHoB provided IPo finance to 725 IPO applicants in the Maruti IPO that came
during June 2003. Thereafter, the number of applications and the amount financed
by BHoB increased as seen in the IPOs of Indraprastha Gas Ltd. (December 2003)
wherein 4631 IPO applicants were financed by BHoB and Patni Computer Systems
Ltd. (February 2004) wherein 10386 applicants were financed by BHoB. In this
Page 119 of 191
context, it may be recalled that pursuant to the arrangement with BHoB, Karvy had
introduced the account holders to BHoB, based on which, they were able to obtain
IPO finance from the Bank.
9.102. Thereafter, during October 2004 and March 2005, Karvy had introduced the key
operators to Indian Overseas Bank, Ahmedabad and had also introduced fictitious
joint account holders whose names were added to the IOB Bank accounts of the key
operators. Based on the same, the key operators were able to obtain IPO finance
from IOB also as in the case of BHoB.
9.103. Apparently, after having introduced the key operators and the afferent account
holders to the banks during 2003, 2004 and the first quarter of 2005 as mentioned
above, during July 2005, a Karvy group entity (Karvy Consultants Ltd., an NBFC)
had provided IPO finance to the afferent account holders by extending IPO finance
to the Key Operators.
9.104. Based on Annexure A of Karvy Consultants Ltd’s reply dated May 9, 2006 to the
SEBI interim order dated April 27, 2006, it is seen that KCL, an NBFC, had
provided IPO finance to the following key operators in the IPOs listed below:
ROOPAL PANCHAL – KCL FUNDING DETAILS IN VARIOUS ISSUES Issue
Chq No.
Margin Chq No.
disbursement
Loan Chq No.
Repayment
Chq No.
Interest
IDFC 484887 61880000 RTGS 247520000 185640000 777196 185640000 484887 3640000 SASKEN
0 891062 20000000 260000000 269105 112500000 623077 2030140
891063 20000000 269106 57500000 891064 20000000 TFR TO
AMAR 90000000
891065 20000000 891066 20000000 891067 20000000 891068 20000000 891069 20000000 891070 20000000 891071 20000000 891072 20000000 891073 20000000 891074 20000000
Page 120 of 191
AMAR
RTGS 208900000 298900000 RTGS 298900000 623077 2333877
TFR FM SASKEN
90000000
MANOJ SEKSARIA – KCL FUNDING DETAILS IN VARIOUS ISSUES Issue
Chq No.
Margin Chq No.
disbursement
Loan Chq No.
Repayment
Chq No.
Interest
Int. TDS
ILFS 723248 2161250 530271 20000000 19451250 763602 19451250 723249 117798 34082 530272 1612500 IDFC 763603 9800000 891127 20000000 80920000 624990 19040000 763608 490056 141785 763604 4400000 891128 20000000 628989 19040000 763617 10955 3169 763605 80000 891129 17120000 763606 38318000 891130 19040000 763607 4522000 891131 19040000 SASKEN
763616 9100000 891143 20000000 172900000 800783 9000000
891144 20000000 800780 20000000 891145 20000000 800776 20000000 891146 20000000 763624 20000000 891147 20000000 763623 20000000 891148 20000000 800778 20000000 891149 20000000 800779 20000000 891150 20000000 763625 20000000 891172 20000000 800777 20000000 891173 2000000 763642 3900000 SUZLON
800799 4993920 891214 20000000 44945280 800752 37500000 723195 272154 78752
891215 20000000 723194 5439200 891216 9939200 800762 2000000 Recon 6080 PURUSHOTTAM BUDHWANI – KCL FUNDING DETAILS IN VARIOUS ISSUES Issue
Chq No.
Margin Chq No.
disbursement
Loan Chq No.
Repayment
Chq No.
Interest
Int. TDS
IDFC 276018 11280000 891152 20000000 80920000 276024 39032000 276027 490056 141785 276019 3000000 891153 20000000 768077 19040000 276032 9224 2669 891154 17120000 738076 19040000 891155 19040000 276025 3808000 891156 19040000
SASKEN
276031 9100000 891175 20000000 172900000 242163 4300000 242174 1047092
302949
891176 20000000 242153 20000000 891177 20000000 242154 20000000 891178 20000000 242155 20000000 891179 20000000 242156 20000000 891180 20000000 242173 80000000 891181 20000000 242166 8600000 891182 20000000 891183 20000000 891174 2000000
SUZ 800799 4993920 891214 20000000 44945280 800752 37500000 723195 272154 78752
Page 121 of 191
LON 891215 20000000 723194 5439200 891216 9939200 800762 2000000 6080
PARAG JHAVERI – KCL FUNDING DETAILS IN VARIOUS ISSUES Issue Chq
No. Margin Chq
No. disbursement
Loan Chq No.
Repayment
Chq No.
Interest
IDFC 287559 11900000 RTGS 101150000 75862500 982650 75862500 287561 1487500 287560 700000 287562 87500 287566 12600000 SASKEN
6500000 891076 45500000 39000000 266141 39000000 600000
9.105. Observations on IPO Financing by Karvy:
From the above table, it may be seen that as per Karvy’s submissions, it had
provided IPO finance to Roopalben Panchal in the IPOs of IDFC, Sasken and Amar
Remedies. For instance, in the case of IDFC, Karvy had provided IPO finance of
Rs. 18,56,40,000 i.e.Rs. 18.56 crores to Roopalben Panchal. Based on the IPO loan
agreement dated July 21, 2005 entered into between Karvy Consultants Ltd. and
Roopalben Panchal, it is seen that Karvy had provided IPO finance to Roopalben
Panchal to apply for 7280000 shares in IDFC IPO. Shri Mayur Modi and Shri
Aditya Gupta, employees of Karvy had acted as references for Roopal Panchal.
9.106. It is seen that the disbursement of the loan was made by Karvy through RTGS
transfer to the IDFC escrow account. Vide its letter dated May 19, 2007, KSBL had
submitted that an amount of Rs. 51,90,78,000 i.e. Rs. 51.90 crores was transferred
to the escrow account of ICICI who were bankers to the issue of IDFC. The amount
was in respect of 10,900 applications which were being financed by KCL as an
NBFC. The amount of Rs. 51,90,78,000 was inclusive of Rs. 12,97,69,500 i.e.
12.97 crores, being the amount collected from various loan applicants as margin
money.
9.107. It is seen that in the case of Sasken IPO, Karvy did not take any margin from
Roopalben Panchal. Karvy had provided 100% IPO finance of Rs. 26 crores to
Page 122 of 191
Roopalben Panchal. Further, Karvy had transferred Rs. 9 crores out of the refund
money of Sasken IPO for making application in the IPO of Amar Remedies on
behalf of Roopalben Panchal. In addition, Karvy had made RTGS transfer of Rs.
20.89 crores in the IPO of Amar Remedies towards IPO loan given to Roopalben
Panchal. In this regard Karvy DP in its reply dated May 19, 2007 has stated that “it
may however, be noted that the margin amount was not transferred to KCL, but
only the loan amount was disbursed to the loanee, who inturn has deposited the total
amount inclusive of the margin amount to the escrow account of the issuer.” In the
normal course of IPO finance the financier collects the margin amount from the
borrower and issues cheque / DD favourig the escrow account for the application
money. This practice is adopted to ensure that the loan money is utilized only for
the purpose of making IPO application. That KCL, instead of adopting the normal
practice as above, released the loan amount directly to the key operator (Roopal
Panchal) shows that Karvy had full control over the manner of application of funds.
In this regard, I note that RBI has issued guidelines to NBFCs regarding Customer
identification procedures and KYC norms to be followed by them.
9.108. Similarly, it is seen that Karvy had provided IPO finance to various other Key
Operators, namely, Manoj Seksaria, Purushottam Budhwani a nd Parag Jhaveri in
respect of various IPOs namely, ILFS, IDFC, Sasken and Suzlon. As regards the
financing by KCL to Purshottam Budhwani, it was found that KCL had disbursed
the loan amount many days after the closure of the IDFC IPO. In this regard KSBL
in its reply dated May 19, 2006 has stated that “we had received the margin
subsequently. It is submitted that the margin was received by KCL on the date of
closure of the issue. It is reiterated that KCL had not disbursed the loan amount to
Purshottam Budhwani, since KCL had not received the margin.” In this regard it is
noted that KSBL, the stock broker, had bid the IDFC IPO application forms
pertaining to Purshottam Budhwani on the last day of the issue i.e. July 22, 2005.
Apparently the cheques attached to the application forms were encashed a week
later i.e. after the disbursal of the loan money by KCL.
Page 123 of 191
9.109. Based on the data furnished by Karvy Consultants Ltd. (KCL) in its letter dated
May 9, 2006, it was seen that KCL had granted IPO financing to 5200 individual
applicants on the strength of loan applications purportedly received from them in
regard to the IPO of IDFC. When KSBL was asked to furnish copies of all 5200
loan applications in the course of personal hearing, it pointed out that all the
original loan applications were seized by CBI in the course of search and seizure
operation and were lying in the custody of CBI. SEBI has obtained sample copies of
some of the request letters for sanction of IPO funding from CBI. A perusal of these
request letters reveals that each such document consists of two pages and comprises
Request Letter for Sanction of Loan, Receipt of Loan, and Letter to the Bank to
debit the account of the account holder / loan applicant and Promissory Note in
favour of KCL. As per these documents, the salient features of IPO funding to these
5200 loan applicants are as under:
? The cheque for the loan amount was issued in favour of each individual
applicant.
? KCL was authorized to credit the bank account of each applicant towards refund
for the said IPO directly and debit each bank account subsequent to receipt of
refunds towards principal amount as well as interest etc.
? The loan amount was advanced for a period of 15 days from July 22, 2005 which
was the last day of currency of IDFC IPO.
9.110. However, it is a matter of record that no separate cheques were issued by KCL
towards the loan amount in favour of individual applicants presumably because
KCL was very well aware that the SB Account Nos. mentioned in the said 5200
loan applications did not exist at all. It was for this reason again that individual
refund orders for crediting the respective bank accounts of the said 5200 loan
applicants were not issued by Karvy RTI pursuant to allotment in the IPO of IDFC
and in lieu thereof, consolidated refund orders were issued.
A scrutiny of the said Request Letters and other loan documents brings out that:
Page 124 of 191
? The SB Account Nos. of the applicants were shown as 9550-1, 9550-2, 9550-3,
9550-4 and so on with the BhOB, Ellisbridge, Ahmedabad.
? The cheque number for the loan amount granted by KCL was not mentioned on
any of the Receipts.
? There was no individual loan sanction letter issued by KCL to each applicant.
? There was no mention of rate of interest on any of the Promissory Notes executed
by each applicant. No interest has actually been paid to KCL by any of 5200
individual loan applicants.
? There was no mention of receipt of any margin from any of the individual
applicants. The application amount for each application was Rs.47,600/- whereas
the loan amount was Rs.35,700/- per application. In other words, the differential
amount of Rs.11,900/- represented the margin amount (25%) to be contributed by
each applicant. There is no evidence to suggest that KCL received margin
moneys from any of the 5200 individual loan applicants.
9.111. KCL is also stated to have entered into another loan agreement with Roopal N
Panchal on July 21, 2005 in the IPO of IDFC. The following points need to be
considered in this regard:-
i) The loan applicant, Roopal N Panchal based at Ahmedabad made an application for
loan to KCL, Hyderabad on July 21, 2005. KCL, Hyderabad sanctioned the said
loan to her on the same day subject to her executing Agreement of Pledge, POA,
Demand Promissory Note, Post Dated Cheques etc. which was also done on the
same day.
ii) There is nothing in the loan agreement with Roopal N Panchal to show that she had
underwritten the loan for 5200 applicants.
iii) The application was made by Roopal N Panchal for loan of Rs.18,56,40,000/- for
applying in the IPO of IDFC wherein KCL “may be the second applicant”. The
amount of loan was required by Roopal N Panchal for the purpose of applying for
7280000 shares in the IPO of IDFC.
Page 125 of 191
iv) A perusal of the loan sanction letter shows that the column of rate of interest is left
blank.
v) No disbursement of funds was made by KCL to any of 5200 individual loan
applicants.
vi) Subsequent to allotment, the refund money was given to Roopalben Panchal
through a few consolidated refund orders.
vii) Roopal N Panchal paid interest of Rs.36,40,000/- on loan of Rs. 18,56,40,000/- for
a period of 15 days from the date of closure of issue i.e. 22.07.2005 although
money was disbursed by KCL on 30.07.2005 till the date of allotment/ refund, i.e.
06.08.2005. This gives an interest rate of over 47% p.a. for a period of 15 days. No
reasonable or prudent person would pay such exorbitant rate of interest, especially
when he can avail of IPO finance from Bank/ NBFCs @ 14-15% p.a. Karvy has
not been able to offer any explanation in this regard. KCL has admittedly charged
18% -19% p.a. from the Key Operators namely Purushottam Budhvani and Manoj
Dev Seksaria.
viii) Apparently, there were no efforts on the part of Karvy for ascertaining the identity
of borrowers by way of photographs, identification documents etc.
ix) Apparently, KCL did not take any steps to ascertain the credit worthiness of the
borrowers.
x) Also, Karvy made no attempt to obtain the correct address - permanent address of
the loan applicants.
9.112. In effect, what emerges is that KCL funded Roopalben Panchal for making 5200
IPO applications in the IPO of IDFC. The so-called loan applications with 5200
individual loan applicants were nothing but just a make-believe.
9.113. Even if it is assumed for the sake of argument that the 5200 borrowers were real
persons, it is hard to believe that the said 5200 loan applicants having the same
address as Roopalben Panchal at Ahmedabad would approach KCL, Hyderabad for
obtaining IPO finance @ 47%p.a. whereas they could have availed such finance
locally on more reasonable terms.
Page 126 of 191
9.114. A perusal of the Income–Tax returns of Roopalben Panchal shows that she had
shown total income of Rs.76,760 and Rs.1,08,420 in her I.T. return for A.Y.s 2003-
04 and 2004-05 respectively. With such meager income/ resources, it is hard to
believe that any financier would have provided IPO finance to the tune of
Rs.18,56,40,000/- to her. All these circumstances put a big question mark on the
genuineness of the loan documentation as well as the loan transaction. A perusal of
loan applications indicates that this was meant to be a single application for
allotment of 26,78,500 shares to Roopal N Panchal presumably under the HNI
category.
9.115. Based on documents submitted by Karvy, it is seen that Karvy Consultants Ltd.
had provided loan of Rs. 4,85,52,000/- at 19% p.a. for a period of 15 days to a key
operator namely Shri Purshottam Budhwani for making application in the IPO of
IDFC Ltd. Karvy had specified a margin of Rs.85,68,000/- for the loan.
9.116. In the normal course of a financier providing IPO loan, the financier enters into an
agreement with the borrower, collects the margin money from the borrower and
issues a cheque / DD favouring the IPO escrow account for the full application
money. The release of loan by way of cheque / DD favouring the escrow account
ensures that the loan money is used only for the intended purpose of applying in the
IPO and is not diverted / misused by the borrower for any other purpose. Further, a
lien is noted on the demat account of the borrower to ensure IPO shares that get
allotted are available as security for the loan and a lien is noted on the bank account
to ensure refund money is available for adjustment against the loan.
9.117. In the case of purported IPO finance provided by Karvy Consultants Ltd. to the
key operator, the loan money was apparently released directly to the key operator,
who in turn divided the same for making numerous small value applications so as to
be eligible for allotment in the retail category. The above leads to the possible
inference that Karvy Consultants released the IPO finance to the key operator rather
Page 127 of 191
than issue a cheque favouring the escrow account, as is the normal practice, to
enable the key operator to execute their gameplan of dividing the IPO finance into
numerous IPO applications in the retail category. If Karvy Consultants was
providing IPO finance in the normal course, it would necessarily issue a cheque
favouring the escrow account to ensure that the borrower uses the money only for
the purpose of IPO finance. In the instant case, Karvy Consultants, in order to
enable the key operator to make multiple applications in fictitious / benami names,
provided IPO finance directly to the key operator rather than to the escrow account.
From this, it may be inferred that Karvy Consultants was aware of the intentions of
the key operator and did its part to ensure that the key operator’s gameplan got
executed without a hitch.
Page 128 of 191
Manoj Seksaria through 1998 applicants
Parag Jhaveri / SEIPL through 2125 applicants
Dharmesh Mehta through 498 applicants
Dhaval Katakia through 519 applicants
Biren Kantilal Shah through 1210 applicants
Refund Rs. 46652760
Refund Rs. 20010564
Refund Rs. 77034888
Roopal Panchal through 5200 applicants
PurshottamBudhwani through 2000 applicants
Key Operators
Refund Rs. 200491200
Karvy Consultants Limited
Refund Rs. 77112000
Refund Rs. 19200888
Refund Rs. 81931500
Applied for 1400 shares each for Rs. 47,600/- on July 22, 2005
1694000 shares for Rs. 7596000
2800000 shares for Rs. 5200000
697200 shares for Rs. 23704800
7280000 shares for Rs. 247520000
726600 shares for Rs. 24704400
2975000 shares for Rs. 101150000
2797200 shares for Rs. 95104800
Received allotment of 266 shares @ Rs.34/- each on August 04, 2005
321860 shares for Rs. 10943240
532000 shares for Rs. 18088000
132468 shares for Rs. 45039120
1383200shares for Rs. 47028800
138054 shares for Rs. 46938360
565250 shares for Rs. 19218500
531468 shares for Rs. 18069912
Received refund of Rs.38,556/- per application
Page 129 of 191
9.118. DETAILS OF THE AFFERENT ACCOUNTS/ BANK ACCOUNTS OF KEY OPERATORS USED IN THE IPO OF IDFC FOR AVAILING FINANCE FROM BHOB / IOB / KCL
Name of the Key Operator (Bank Account No.)
No of afferent entities that were financed
Address of the afferent account holder as per demat account
Name of the Bank as per the demat records of the afferent accounts (significant for purpose of Refund)
Finance availed from with BhOB/ IOB / KCL
Roopal Panchal (55045) - BHOB (50795) - BHOB (54119) - BHOB
IOB (15,107) KCL (5,200)
402-403, Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad – 380006
BHOB IOB / KCL
Parag Jhaveri / SEIPL
BHOB (3125) KCL (2125)
C/o. SEIPL, G-1, Devpath Complex B/h. Lal Bunglow, Ahmedabad.
Vijaya Bank BHOB / KCL
Kelan Atul Doshi (2527) - IOB (8993) - BHOB
IOB ( 1994) BHOB ( 495)
68, Samashta B Society Opp Pinakin Soc Paldi, Ahmedabad
BHOB /IOB BHOB / IOB
Biren Kantilal Shah KCL (1210)
23, Payal Complex, Sayajigunj, Paldi, Baroda, 3900053
Tamilnadu Mercantile Bank (TMB)
KCL
Purshottam Bhudwani
KCL (2000) B/2 Himalaya Asalaya Ghatkopar, W, Mumbai.
HDFC BANK KCL
Manoj Sekseria KCL (2000) Niketan Maheshwar, 33, Peddar Road, 5B
HDFC BANK KCL
D B Mehta KCL ( 498) BHOB (1032)
6 Vinay Bhuvan, 90 Foot Road, Ghatkopar (E) Mumbai
BHOB BHOB / KCL
Dhaval Katakia KCL (519) BHOB (722)
Kailash Plaza, Bldg no 126, Near Kar Ke RAs Hotel, Above ICICI Bank, Ghatkopar (e), Mumbai.
BHOB BHOB / KCL
Total 36,027 9.119. It is seen from the above table that 36,051 afferent demat accounts (out of 49, 708
afferent accounts held with Karvy DP) were used in the IPO of IDFC where finance
was availed from BhOB / IOB / KCL. It is relevant to note that majority of the
afferent account holders had their bank accounts with BhOB which were introduced
by Karvy (viz. SB Account Nos. 50795 and 54119). Karvy admittedly certified the
signatures of the afferent account holders to IOB and also introduced the bank
accounts of the Key Operator like Roopal Panchal who availed financed from IOB
and thereafter KCL itself started financing these key operators. Thus, Karvy had
initially introduced afferent account holders with BhOB (as per the Idea Paper in
the IPO of Maruti Udyog Ltd.) in the month of June, 2003 and then in the month of
December, 2003 and thereafter encouraged Key Operators to open bank accounts
Page 130 of 191
with same modus operandi and opened demat accounts with one bank accounts with
series of names attached with each account. Thereafter, Karvy had introduced
saving bank accounts of Key Operators like Roopal Panchal, Kelan Atul Doshi with
IOB in the month of March, 2005 and thereafter also certified list of names attached
with each account and enabled them to get finance from IOB. Further, Karvy itself
in the month of July, 2005 extended finance to the key operators whom it had
introduced with BhOB and IOB and in the month of September, 2005 Karvy made
an attempt to open 10,000 demat accounts of Roopal Panchal with the bank
accounts of IOB. Karvy submitted that it had returned the demat account opening
forms to the applicants for want of adequate compliance of KYC norms. However,
it is relevant to note that Karvy had already extended finance to demat accounts
with the same modus operandi and with the same name with different surnames as
explained elsewhere in the report.
9.120. The analysis of the afferent demat accounts of Roopalben Panchal used in the IPO
of IDFC is mentioned in the table below:
No of afferent demat accounts
Name of the Bank as per demat records
Name of the account holder
Date of opening of bank account
Date of opening of demat account on NSDL / CDSL
297 BHOB 50795 – Devangi Dipak Panchal (introduced by Karvy Securities and Karvy investors Services Ltd)
17.06 03 (Closed on 27.10.03)
27.06.03
3200 BHOB 54119 (– Devangi Dipak Panchal - Group a/c) (introduced by Karvy Securities Ltd)
4.12.03 (Closed on 24.04.04)
12.12.03
6810 BHOB 55045 Arajav N Panchal (Introduced by Dipak Jasvantlal Panchal)
5.02.04 6.02.04 (1045) 16.08.04 (2996) 20.10.04 (200) 17-19.07.05 (2569)
10,000 BHOB 9550 Arjav Naresh Panchal (introduced by Devangi Dipak Panchal)
December – 2004
16.07.05 (10,000) – CDSL accounts
20307 Total
9.121. It is noted that the afferent demat account holders financed by IOB had indicated
BhOB as their banker in their respective demat records. It is seen that Karvy Stock
Page 131 of 191
broking Pvt. Ltd had introduced the 19 bank accounts of Roopal Panchal with IOB
Thaltej Branch with list of 50 names and signatures certified by Karvy Stock
Broking. Based on such certification, the afferent accounts of Roopal Panchal were
able to avail IPO finance in the IPO of IDFC for 15,131 afferent applicants. The
analysis of the said demat accounts suggests that first bank accounts were
introduced by Karvy and thereafter Key Operators have adopted same modus
operandi as could be observed from the fact that all the key operators had same
modus operandi of having one main account with series of sub-numbers. The
following Key Operators who hold bank account with BhOB had used the same
modus operandi. The details of such bank accounts and the number of
dematerialized accounts that indicated these bank accounts in their demat records is
given below:
Name of the Key Operator
BhOB Bank account no
Number of demat accounts
Remarks
Roopal Panchal 9550
15000 The bank accounts number had bank account number starting from 9550 / 1 to 9550 / 15000
Kelan Atul Doshi 151008993 700 The bank accounts number had bank account number starting from 151008993/ 1 to 151008993 / 700
Biren Kantilal Shah 2527 700 The bank accounts number had bank account number starting from 2527 / 1300 to 2527 / 2000
9.122. It is observed that Karvy stock broking had introduced the bank account no.
12004 of Kelan Atul Doshi with IOB, Stadium Branch, Ahmedabad.
9.123. Role of KSBL as Broker (Observations on bidding of IPO forms):
The process flow relating to bidding of application forms as indicated by Karvy
during the enquiry proceedings is given below:
Page 132 of 191
IPO PROCESS – APPLICATION BY INVESTORS TO BIDDING (Through Institutions)
Investor ‘n’ Investor 2 Investor 1
Received by Institutions through sub brokers / brokers
Receipt of intent for applying with respect to the applications under POA
Receipt of application along with loan documents for applications under IPO finance
Receipt of necessary documents like loan document / Power of Attorney
Preparation of completed application forms (including application money for funded cases and printing and signing of applications for POA cases) for bidding
Providing the applications and data to the syndicate member for bidding
Bidding by the Syndicate / Sub Syndicate Member
Sending the data to the Registrar on the applications funded / managed under POA
Page 133 of 191
9.124. KSBL in its reply dated May 09, 2006 to the SEBI interim dated April 27, 2006
had stated as below at para 4.25.11:
“It is submitted that the changes in the process followed by BHOB as part of the internal procedure and process towards IPO funding had never been suggested in the Idea Paper. Maintaining of “manual control sub ledger account” confirms that the bank was aware of individual customers and had accounts for them, though not in the system. Further the applications have been handed over to us for the purpose of bidding along with individual pay orders, signifying loans being provided to that many applicants. It is necessary for each such application to be bidded in the NSE / BSE system before depositing the applications along with the payment instrument, with the bank, designated as the collecting Bank for the IPO. Biding can be done only by syndicate / sub-syndicate members to the issue and we being a syndicate / sub syndicate have provided the service of upload to NSE / BSE for these loan cases.”
9.125. Further, KSBL, in its reply dated May 19, 2007 to the post enquiry show cause
notice dated May 04, 2007 of SEBI stated at para 17.6 as below:
“ On the last day of the issue, there are huge volumes of applications submitted by various investors. These applications along with the payment instruments are submitted to the escrow bankers to the issue on the following da subsequent to the closure of the issue.”
9.126. From the reply, it is clear that at the time of bidding of the IPO application form,
it is necessary for the syndicate member to obtain the duly filled in application form
along with the payment instrument (cheque/DD). Further, in terms of Guideline
11.3.1 clause xvii (a) of SEBI (DIP) Guidelines, 2000, “The broker may collect an
amount to the extent of 100% of the application money as marging money from the
clients / investors before he places an order on their behalf… ”. Thus in terms of the
guidelines prescribed by SEBI before placing the order of the IPO applicant on the
Exchange System ( i.e. bidding), the broker is required to collect 100% of the
application money as margin from the clients/investors.
9.127. Also, based on information collected by SEBI from Market Participants which act
as brokers/syndicate members, it is gathered that while bidding the IPO application,
the broker/syndicate member verifies the application form and ascertains that the
Page 134 of 191
application money is duly filled in with the cheque/DD attached to the application
form.
9.128. Therefore, in terms of regulatory guidelines, market practices and Karvy’s own
submissions, it is essentital for the IPO application forms to be accompainied by
payment instruments. After bidding, the syndicate member forwards the application
form along with the payment instrument to the banker to the issue (also known as
Escrow Collection Bank). The banker to the issue detaches the instrument and sends
the same for collection while simultaneously forwarding the application form to the
Registrar to the issue.
9.129. As mentioned earlier, in the case of IDFC IPO, wherein Karvy Consultant Ltd.
had acted as IPO financier, it had done RTGS transfer of Rs.51,90,78,000 to the
IDFC escrow account on July 30, 2005. The IDFC IPO opened on July 15, 2005
and closed on July 22, 2005. Therefore it is seen that the RTGS transfer made by
Karvy Consultants Ltd. to IDFC Escrow account was after the date of closure of the
IPO. In view of the fact that RTGS took place in respect of 10900 applicants after
the closure of the IPO, it appeared that these IPO applications were not
accompanied by payment instruments at the time of bidding of the applications.
9.130. Further, in the case of Suzlon IPO, the public issue closed on September 29, 2005
and it was found that KCL had made RTGS transfer of Rs.20.51 crores to the
escrow account of Suzlon IPO on October 5, 2005 i.e. many days after the date of
close of the IPO. In this regard, KSBL has submitted that the amount to be
transferred towards margin and the loan funded by KCL for various afferent
applicants in the Suzlon IPO was ascertained only by the evening of September 29,
2005. Since September 30, 2005, October 1 and October 2, 2005 were Bank
holidays KCL made RTGS transfer to the Suzlon IPO Escrow account on October
5, 2005 in respect of the applicants financed by it. Thus it may be seen that at the
time when KSBL, a stock broker and also a sub-syndicate member had bid the
Page 135 of 191
application forms on September 29, 2005, the application forms were not
accompanied by cheques / DDs for the application money.
9.131. Bidding of IDFC IPO Applications by KSBL (Stock Broker)
In view of the above, the bidding of the IPO applications was examined:
Based on the examination of the bid book data obtained from Karvy as well as the
Stock Exchange, it is seen that the application was bid by the broker having the
code “07701”. Based on information obtained from NSE, it is seen that the broker
code “07701” belongs to Karvy Stock Broking Ltd. Thus it is seen that KSBL in its
capacity as a broker of NSE and also a sub-syndicate member has bid the
application forms in respect of the applicants financed by KCL through IPO finance
to the Key Operators. It is clear that the individual application forms of these
applicants did not contain the payment for the IPO application. This is evidenced by
the fact that if there had been a cheque/DD attached to the application form, the
same would have been collected by the banker to the issue and there would have
been no occasion for KCL to make RTGS transfer directly to the escrow account
may days after the closure of the public issue.
9.132. It was seen that the 5200 IDFC IPO applicants financed by Karvy through Roopal
Panchal had only eight surnames i.e. Pandya, Rathi, Desai, Verma, Gandhi, Trivedi,
Vala and Pathak. The details are as below:
Last Name No. of Applicants PANDYA 1000 RATHI 500 DESAI 680 VERMA 1000 GANDHI 1000 TRIVEDI 200 VALA 100 PATHAK 720 Total 5,200
Page 136 of 191
9.133. An extract of the salient fields of the bid book is given below in respect of 100
bids made in the name of applicants having the last name as “Pandya”:
BROKER LOCATION USER
ID NAME OF USER
DATE OF ENTRY
IHNO APPL_NO NAME ADD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:07 PM
2975001 32990828 KUNAL PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:10 PM
2975002 32990829 BAKULA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:13 PM
2975003 32990830 GRAMI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:16 PM
2975004 32990831 JAKSHREE PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:18 PM
2975005 32068477 KUNJ PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:22 PM
2975006 32068478 VAGNA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:25 PM
2975007 32068479 NIRAN PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:27 PM
2975008 32068480 NISHA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:30 PM
2975009 32068481 RAMESH PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:33 PM
2975010 32068482 AAKASH PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:35 PM
2975011 32068483 BALA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:39 PM
2975012 32068484 DEV PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:41 PM
2975013 32068485 GRASHIT PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:44 PM
2975014 32068486 JEET PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
Page 137 of 191
BROKER LOCATION USER ID
NAME OF USER
DATE OF ENTRY
IHNO APPL_NO NAME ADD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:46 PM
2975015 32068487 KUNALPANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:49 PM
2975016 32068488 PAJAN PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:52 PM
2975017 32068489 NIRBHAY PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:55 PM
2975018 32068490 NISHANT PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:58 PM
2975019 32068491 RANI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:00 PM
2975020 32068492 AANSHI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:02 PM
2975021 32068493 BALCHAND PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:05 PM
2975022 32068494 DEVAN PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:07 PM
2975023 32068495 GRISHA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:10 PM
2975024 32068496 JEEVAN PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:13 PM
2975025 32068497 KUNIT PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:15 PM
2975026 32068498 VAMYA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:18 PM
2975027 32068499 NIRDESH PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:21 PM
2975028 32068500 NISHIT PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:23 PM
2975029 32068501 RANJIT PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:26 PM
2975030 32068502 USHMA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE
Page 138 of 191
BROKER LOCATION USER ID
NAME OF USER
DATE OF ENTRY
IHNO APPL_NO NAME ADD
ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:28 PM
2975031 32068503 BALI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:30 PM
2975032 32068504 DEVANG PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:32 PM
2975033 32068505 GUDDY PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:34 PM
2975034 32068506 JENITH PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:37 PM
2975035 32068507 KUSH PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:40 PM
2975036 32068508 YASH PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:43 PM
2975037 32985551 NIRJA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:46 PM
2975038 32985550 NISHU PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:48 PM
2975039 32985549 SUNITA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:51 PM
2975040 32985957 AARTI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:53 PM
2975041 32985775 BALRAM PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:56 PM
2975042 32985774 DEVANSH PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:59 PM
2975043 32985836 GULAB PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:01 PM
2975044 32985835 TRIKAL PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:03 PM
2975045 32985834 KUSUM PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE,
Page 139 of 191
BROKER LOCATION USER ID
NAME OF USER
DATE OF ENTRY
IHNO APPL_NO NAME ADD
AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:06 PM
2975046 32985833 YASHANG PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:09 PM
2975047 32985832 NIRMAM PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:12 PM
2975048 32985831 SURESH PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:15 PM
2975049 32985830 ABHAY PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:18 PM
2975050 32985829 DEVANSHI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:20 PM
2975051 32985828 GULJAR PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:23 PM
2975052 32985827 JENNY PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:26 PM
2975053 32985826 LABOHA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:28 PM
2975054 32985825 YASHI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:31 PM
2975055 32985824 NIRU PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:33 PM
2975056 32985823 NITA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:36 PM
2975057 32985822 UTAPLL PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:39 PM
2975058 32985821 ABHIGNA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:41 PM
2975059 32985820 BALWANT PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:44 PM
2975060 32985819 DEVARSHI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
Page 140 of 191
BROKER LOCATION USER ID
NAME OF USER
DATE OF ENTRY
IHNO APPL_NO NAME ADD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:46 PM
2975061 32985818 GUMAN PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:48 PM
2975062 32985817 JHANKI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:50 PM
2975063 32985816 LAGNI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:53 PM
2975064 32985815 KASHU PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:56 PM
2975065 32985554 NIRUPAMA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:58 PM
2975066 32985553 NITANSH PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:01 PM
2975067 32985552 SWATI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:03 PM
2975068 32985776 ABHILASH PANDY
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:06 PM
2975069 32985771 BALWIR PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:08 PM
2975070 32985770 DEVASPA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:11 PM
2975071 32985769 GUNISH PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:14 PM
2975072 32985768 JIGAR PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:17 PM
2975073 33016532 LAHAR PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:19 PM
2975074 32985766 YATNA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:22 PM
2975075 32985765 NIRVI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:25 PM
2975076 32985764 NITIN PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE
Page 141 of 191
BROKER LOCATION USER ID
NAME OF USER
DATE OF ENTRY
IHNO APPL_NO NAME ADD
ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:28 PM
2975077 32985763 TRUSHIT PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:31 PM
2975078 32985813 ABHISHEK PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:34 PM
2975079 32985812 BANJUL PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:36 PM
2975080 32985811 DEVENDRA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:39 PM
2975081 32985810 GUNJAK PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:43 PM
2975082 32985809 JIGISH PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:45 PM
2975083 32985808 LAJJA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:48 PM
2975084 32985789 YATRI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:50 PM
2975085 32985788 NISAR PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:53 PM
2975086 32985787 DEPARV PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:55 PM
2975087 32985807 TUKHAR PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:57 PM
2975088 32985805 ADIP PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:27:00 PM
2975089 32985804 BANKIM PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:27:03 PM
2975090 32985803 DEVI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:27:05 PM
2975091 32985802 JIMISH PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE,
Page 142 of 191
BROKER LOCATION USER ID
NAME OF USER
DATE OF ENTRY
IHNO APPL_NO NAME ADD
AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:27:10 PM
2975092 32985801 LAKENDRA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:27:13 PM
2975093 32985800 YAVAN PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:27:17 PM
2975094 32985799 MIYA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:27:21 PM
2975095 32985798 ROHINI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:27:23 PM
2975096 32985797 TURANG PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:27:25 PM
2975097 32985796 ADITI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:27:29 PM
2975098 32985795 BANSI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:27:34 PM
2975099 32985794 DHAIVAT PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:27:37 PM
2975100 32985793 GUNJAL PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
9.134. From the above table, it may be seen that the bids were entered by one Shri
Shrishailam L, an employee of KSBL. The above 100 applications have been
entered in a time span of 1 minute and 16 seconds ranging from 3:23:07 pm to
3:27:37 pm. It is seen that the bids have been entered within a time difference of 2-3
seconds. The address of all the applicants is the same. In many of the instances, the
application numbers are continuous e.g. 32068477, 32068478, 32068479,
32068480, 32068481, 32068482, 32068483, 32068484, 32068485, 32068486,
32068487, 32068488, 32068489, 32068490, 32068491, 32068492, 32068493,
32068494, 32068495, 32068496, 32068497, 32068498, 32068499 and 32068500.
Page 143 of 191
9.135. Further, the examination of the bid data revealed that KSBL had similarly bid the
application forms in respect of thousands of applicants belonging to various Key
Opertor Groups. The details are given below:
Name of Key Operator
No. of Application forms
Application Amount (Rs.)
Allotment Amount (Rs.)
Refund Amount (Rs.)
Refund Order Number
Biren Kantilal Shah 1210 57596000 10943240 46652760 690001, 690003, 690005, 690008 and 770001 Purushottam Budhwani 2000 95200000 18088000 77112000 183144 to 184143 (1000 numbers) D.B. Mehta 498 23704800 4503912 19200888 690001 Roopalben Panchal 5200 247520000 47028800 200491200 173217 to 174033 (817 numbers), 173193 to
173197 (5 numbers) and 690001 Dhaval Katakia 519 24704400 4693836 20010564 690001 Parag Jhaveri/SEIPL 2125 101150000 19218500 81931500 690009 Manoj Dev Seksaria 1998 95104800 18069912 770034888 181146 to 182145 (1000 numbers)
9.136. It may be noted that in respect of the above applicants, Karvy provided
consolidated refund order and also requested BhOB to adjust the refund against the
loan provided by them.
9.137. Bidding in Suzlon IPO
Further, it is noted that in Suzlon IPO, KSBL had bid the applications of the
afferent entities pertaining to the key operators at Hyderabad. Since KCL had
provided finance to the applicants and since the application was provided by KCL
through direct RTGS transfer to the escrow account of Suzlon IPO, it follows that at
the time of bidding these applications no payment instrument i.e. cheque / DD was
available with the applications. Therefore, it follows that KSBL, acting as a broker
and sub-syndicate member had bid the applications without receiving the 100%
margin.
9.138. Issuance of Consolidated Refund:
It is seen that Karvy-RTI has issued consolidated refund orders in the IDFC IPO
favouring banks / financial institutions in respect of the applications that were
financed by the banks / financial institutions. Based on data furnished by Karvy, the
details of consolidated refunds given by Karvy-RTI in respect of large number of
applicants is given below:
Page 144 of 191
Consolidated Refunds issued by KCPL in IDFC IPO Refund Order No. No. of applicants Amount of Refund (Rs.)
690001 6488 25,01,51,328 690003 19 7,32,564 690005 93 35,85,708 690008 989 3,81,31,884 690009 2125 8,19,31,500 770001 364 1,42,27,334
9.139. The details of the consolidated refund orders issued by KCPL in the IPOs of ILFS
and Sasken Communication are given below. It may be seen that the consolidated
refunds were given in respect of the key operators Roopalben Panchal, Parag
Jhaveri and Dharmesh Mehta. In these instances where consolidated refunds were
issued by KCPL it is observed that the IPO applications were financed by KCL or
BHOB and KCPL was also the RTI in these IPOs.
Name of the IPO
Name of Key Operators
Consolidated Refund Order no
No of applicants
Amount Financed by
ILFS Roopal Panchal 600002 10,497 43,13,75,000 BHOB Sasken Communication
Roopal Panchal 500002 9,041 40,37,34,500 BHOB
Dharmesh B Mehta 500002 1,079 5,40,73,500 BHOB Dharmesh B Mehta 534002 1,447 1,99,94,000 KCL Parag Jhaveri 534005 999 4,46,03,000 KCL Parag Jhaveri 500002 8,067 13,95,68,000 BHOB 9.140. The details of the Refund Orders pertaining to the IPO applications wherein KCL
had made direct RTGS transfer of Rs.2089 crores to the Suzlon Energy escrow
account are not available and hence no comments can be made on the Refund
Orders in the IPO of Suzlon Energy. It is also seen that in respect of the applicants,
IPO applications have been bidded by Karvy Stock Broking in its terminal.
9.141. It is understood that issue of a consolidated refund cheque in respect of numerous
IPO applicants is not a market practice, as claimed by Karvy. It is understood that
RTIs have a practice of issuing consolidated refund cheques only for applications
made through internet i.e. web trades. In case of physical applications, the RTIs do
not give a consolidated refund for multiple applicants. Thus, the issue of
Page 145 of 191
consolidated refund cheque was a practice peculiar to Karvy, which facilitated
quick and easy encashment of refund money by the key operators. The refund
money was used immediately thereafter by the key operators for making
applications in the subsequent IPOs.
Name of the KO
IPOs financed
Date of Closure of IPO
Date of disbursement
Amount disbursed
Date of RO Date of repayment
Repayment amount
Roopal Panchal IDFC 22-07-05 30-07-05 (RTGS)
24,75,20,000 (5,200 appl)
05-08-05 (consol RO)
08-08-05 18,56,40,000
SASKEN 17-08-05 17-08-05 26,00,00,000 (no margin received)
31-08-05 31-08-05 17,09,00,000
AMAR REMED
31-08-05 05-09-05 (RTGS)
29,89,00,000
NA. NA. 29,89,00,000
Parag Jhaveri IDFC 22-07-05 30-07-05 (RTGS
10,11,50,000 (appl money for 2,125 appl)
05-08-05 (consol RO)
10-08-05 7,58,62,500
SASKEN 17-08-05 17-08-05 4,55,00,000 (1000 appl)
31-08-05 02-09-05 3,90,00,000
Bhudwani IDFC 22-07-05 28-07-05 9,52,00,000 (2000 appl)
05-08-05
11-08-05 8,09,20,000
SASKEN 17-08-05 22-08-05 18,20,00,000 (4000 appl)
31-08-05 02-09-05 17,29,00,000
Suzlon 29-09-05 03-10-05 4,99,39,200 (1020 appl)
14-10-05 17-10-05 4,49,39,200
Manoj Sekseria IDFC 22-07-05 28-07-05 9,52,00,000 (2000 appl)
05-08-05
11-08-05 8,09,20,000
SASKEN 17-08-05 22-08-05 18,20,00,000 (4000 appl)
31-08-05 02-09-05 17,29,00,000
Suzlon 29-09-05 03-10-05 4,99,39,200 (1020 appl)
14-10-05 17-10-05 4,49,39,200
ILFS 08-07-05 NA 2,16,12,500 (494 appl)
21-07-05 30-07-05 1,94,51.250
OTHER ILFS 08-07-05 NA 1,77,00,000 NA NA NA IDFC 22-07-05 NA 17,58,00,000 NA NA NA SASKEN 17-08-05 NA 14.85,00,000 na NA NA Suzlon 29-09-05 NA 31,35,00,000 NA NA NA
9.142. From the above table, it may be seen that in the IDFC IPO, KCL had made direct
RTGS transfer to the escrow account on July 30, 2005 whereas the IPO had closed
on July 22, 2005. The RTGS transfer of Rs. 51.91 crores was made by KCL in
respect of the 10,900 applicants financed by it. Further, KCPL, the RTI, had issued
consolidated refund orders in respect of these applications vide refund order dated
August 5, 2005, which is a Friday. It is seen that the refund orders pertaining to the
key operators were dispatched in the first lot of refund orders issued by the RTI In
this context it may be recalled that KCL vide letter dated August 8, 2005 had
requested BHOB to adjust the IPO finance provided by it against the refund
amount. Thus, it may be seen that KCL had provided IPO finance to the key
Page 146 of 191
operators for a period of 15 days and had charged interest at 19% p.a. reckoning the
15 day finance period. However, by adopting the above modus operandi which was
facilitated by the presence of the Karvy group entities at various stages of the IPO
process, Karvy ensured that its money was actually used only for a period of 8-10
days thereby improving the returns on the money loaned by it.
9.143. Issuance of Refund in cases where no bank accounts were mentioned in
demat records
In terms of SEBI guidelines, in public issues, at the time of making allotment and
issuing refunds the RTIs should use the demographic and bank details of the IPO
applicants as contained in the depository system. It was found that in respect of
4000 dematerialized accounts held with Karvy DP pertaining to the key operators
Purshottam Budhwani and Manojdev Seksaria, the data in the depository system did
not indicate the bank account details of the dematerialized account-holders.
Therefore, in the case of IDFC IPO, Karvy RTI could not have issued refund orders
in respect of these 4000 dematerialized accounts pertaining to the key operators.
However, it was found that Karvy RTI had indeed issued refund orders in respect of
these 4000 dematerialized account-holders. When queried by the Enquiry Officer in
this regard, KSBL in its reply dated January 19, 2007 stated that the bank details of
the demat account holders was mentioned in the respective application forms and
the same had been captured in the back office of the DP and upload to the DPM
(Depository Participant Module of the CDSL depository system). KSBL further
stated that
“b. ..… ..On verification of the back office records, we find that the bank account
details are available… … ..
c. The absence of these details with CDSL may be due to system related issues in
the software of CDSL, at the time of bulk upload.”
Page 147 of 191
9.144. Thus, it is clear that the depository system did not contain the bank account
details of the 4000 afferent dematerialized account holders pertaining to the key
operators Purshottam Budhwani and Manojdev Seksaria.
9.145. It follows that the refund was issued by Karvy RTI in respect of these 4000
applicants by accessing the back office records of Karvy DP, which shows that
various entities belonging to the Karvy group were acting in a collusive manner
with the key operators.
9.146. Directions of Karvy regarding Appropriation of Refunds
BhoB Ahmedabad branch confirmed that they had not funded the IDFC IPO.
However, it was seen that Roopal Panchal (through her bank account no.
15.100.9000 maintained with the branch) transferred an amount of around Rs. 14.28
crores on July 26, 2005 for the said issue. The refund for the same was received
from Karvy Consultants Ltd.(KCL) through BhoB, Hyderabad branch. KCL., vide
letter dated August 8, 2005 addressed to the Bhob, Hyderabad branch, enclosed a
Bankers Cheque no 103594 dated 5/8/2005 drawn on ICICI Bank Ltd. for Rs.28.17
crores towards the refund of excess application money of IDFC issue and provided
the list of account holders to whom credit of this amount was to be done. As per the
said letter, KCL had funded these applications and had received a mandate letter
from the customers for collecting the refunds as well as adjusting the same against
the loan. KCL requested BhOB, Hyderabad Branch to debit Rs.26.08 crores to the
customers’ account and pay the same in favor of Karvy Consultants Ltd. As per the
list attached by KCL, refund amount for account no. 9550 in the name of Devangi
Panchal was Rs.20.04 crores out of which Rs.18.56 crores was to be paid to KCL.
9.147. Upon perusal of a letter bearing the subject “IPO of IDFCL issue” dated August
8. 2005 from BhOB Hyderabad branch addressed to BhOB Ahmedabad it is
observed that it is mentioned in the letter that “We have been advised by M/s Karvy
Page 148 of 191
Consultants Ltd. that they have funded the IPO application of the enclosed list of
parties who are your branch customers.
9.148. A consolidated refund order has been received at our end for the crediting the
refund amount to the parties account. We understand (that) the customers have
given an authority to debit their account with your branch and credit KCL for the
loan granted for the purpose of the subject IPO funding. To avoid delay we have
refunded the amount payable to KCL from our end out of the consolidated refund
received.”
Refund money
Payment to KCL
Payment to investor
No of applications
Panchal 200491200 185640000 14851200 5200 D B Mehta 19200888 17778600 1422288 498 Dhaval Katakia 10024560 9282000 742560 260 Dharmesh Katakia 9986004 8925000 714000 259 Alpesh Lakhani 9639000 8925000 714000 250 Mukesh G Popat 9639000 8925000 714000 250 Hemal Lakhani 9639000 8925000 714000 250 Hemal Lakhani 9639000 8925000 714000 250 Purshottam Bhudwani 2000 manoj Sekseria 2000 Parag Jhaveri 2125 Biren Kantilal Shah 1210 others 348
Total KO applications financed by KCL 14900 9.149. The above goes to show that Karvy was controlling the banking leg of the IPO
activities through BhOB. While the securities market related transactions in the
IPOs were handled by Karvy group entities, the funds part was managed by Karvy
group through BhOB. This gave complete control to Karvy group over the entire
process of IPO while using fictitious / benami names to corner IPO shares through
the key operators.
Page 149 of 191
9.150. Execution of off-market transfers
During the course of enquiry proceedings, Karvy had submitted the process of DIS execution adopted by it. The same is reproduced below:
Format 1 Format 2 Contains details including Contains details including Slip No. Slip No. BO ID BO ID Scrip Scrip Quantity Quantity Date of entry Date of entry Target account BO ID Target account BO ID Market / off market flag Market / off market flag Execution Date Execution Date Debit instruction no. Credit instruction no.
START
Receipt of DIS from the customer / sub broker
Data capture of the DIS in the off-line module (FORMAT 1)
Verification of signature
Signature tallies
Signature different
Upload data to NSDL / CDSL
Transaction executed
Transaction rejected
Download transaction file for updation of back office (FORMAT 2)
Reject DIS
Write the reference numbers on DIS
Store records
Page 150 of 191
9.151. It was found during the SEBI inspection of Karvy DP that the issuance of
welcome Kit which contains the DIS was decentralized and the Regional Managers
were the authorized signatories for issuing the Welcome Kit to the investors. It was
noticed that the welcome kit for IPO clients who were referred through the IPO sub-
brokers of Karvy contained only single leaf DIS booklets along with the DIS
booklet requisition slip. The correspondence addresses in respect of the accounts
referred through IPO sub-brokers were those of the IPO sub-brokers. The Welcome
Kit was sent to the correspondence address of demat clients and hence went to the
IPO sub-brokers.
9.152. It was found during the course of inspection that the DIS issued to various BOs,
who had opened the accounts introduced by the sub-brokers under the IPO scheme,
were in continuous serial numbers.
9.153. It was seen that these DIS were pre-printed and contained all the material details
such as ISIN number, company name, name of the BO, quantity, execution date etc.
The verification of DIS revealed that the one person had signed on behalf of the
BOs.
9.154. Based on a sample of physical DIS, prima-facie, it is observed that these DIS are
computer generated with columns like Bo account number, First holder, ISIN,
security name, Qty, Target client number being pre-printed. The details are as
below:
Sr. no.
DIS Sr. No.
Instruction No.
Source Client ID
Source Client name
Source DP
Target Client ID
Target DP
Name of Security
Quantity
Date of Execution
1. 200190918 1956033 14544833 Gandhi Roshan M
KCL 14405199 KCL IDFC 266 08.08.05
2. 200190917 1956032 14544825 Gandhi Trishul M
KCL 14405199 KCL IDFC 266 08.08.05
3. 200190916 1956031 14544817 Gandhi Payal M
KCL 14405199 KCL IDFC 266 08.08.05
4. 200190915 1956030 14544809 Sheth KCL 14405199 KCL IDFC 266 08.08.05
Page 151 of 191
Hitendra H
5. 200190914 1956029 14544794 Sheth Mauli H
KCL 14405199 KCL IDFC 266 08.08.05
6. 200190913 1956028 14544786 Sheth Vasu H
KCL 14405199 KCL IDFC 266 08.08.05
7. 200190912 1956027 14544778 Sheth Vasu H
KCL 14405199 KCL IDFC 266 08.08.05
8. 200190911 1956026 14544769 Doshi Vatsal G
KCL 14405199 KCL IDFC 266 08.08.05
9. 200190910 1956025 14544750 Doshi Kajri G
KCL 14405199 KCL IDFC 266 08.08.05
10. 200190909 1956024 14544743 Mistry Bokshi P
KCL 14405199 KCL IDFC 266 08.08.05
11. 200190908 1956023 14544735 Mistry Kalpen P
KCL 14405199 KCL IDFC 266 08.08.05
12. 200190907 1956022 14544727 Mistry Vibhut P
KCL 14405199 KCL IDFC 266 08.08.05
13. 200190919 1956034 14544840 Mistry Mohan R
KCL 14405199 KCL IDFC 266 08.08.05
14. 200190901 1956016 14544663 Sheth Chirag S
KCL 14405199 KCL IDFC 266 08.08.05
15. 200190902 1956017 14544670 Sheth Samrat S
KCL 14405199 KCL IDFC 266 08.08.05
16. 200190903 1956018 14544689 Sheth Kanjari S
KCL 14405199 KCL IDFC 266 08.08.05
17. 200190904 1956019 14544698 Gandhi Chetak R
KCL 14405199 KCL IDFC 266 08.08.05
18. 200190905 1956020 14544702 Gandhi Akshar R
KCL 14405199 KCL IDFC 266 08.08.05
19. 200190906 1956021 14544719 Gandhi Anali R
KCL 14405199 KCL IDFC 266 08.08.05
Note: The target BO ID of 14405199 belongs to SEIPL. 9.155. The above table shows that details contained in the DIS used for making off-
market transfers from the afferent dematerialized accounts to the dematerialized
account of key operator viz. SEIPL. It may be noted that the DIS are in continuous
serial number.
9.156. Further, in the above DIS all the material particulars including Bo account
number, First holder, ISIN, security name, Qty, Target client number and
Transaction Number being printed. It may be mentioned that the transaction number
is generated after execution of DIS and the number is hand written by the DP staff
after execution. In the normal course, the DP executes the transaction by punching
in the depository system the details contained in the DIS. Upon execution, the
depository system generates a transaction number which is hand written by the DP
Page 152 of 191
for the purpose of reference and the DIS is kept in the records of the DP. The
printing of Transction number in the DIS as detailed in the table above, is possible
only when the DIS has been printed after the execution of the transction i.e. no DIS
existed at the time of execution of off-market transactions and the DIS was printed
after execution. In terms of Regulation 42(2) and 42(3) of SEBI DP Regulations
1996
“(2) A participant shall register the transfer of securities to or from a beneficial owner’s account only on receipt of instructions from the beneficial owner and thereafter confirm the same to the beneficial owner in a manner as specified by the depository in its bye-laws. (3) Every entry in the beneficial owner’s account shall be supported by electronic instructions or any other mode of instruction received from the beneficial owner in accordance with the agreement with the beneficial owner.”
9.157. It may be seen from the above that the DIS serial numbers issued to clients of
various groups are in continuous serial numbers. This is possible only if loose DIS
of one booklet is issued to various clients. Even in such a scenario it is highly
unlikely that the DIS executed by various persons making off-market transfers to
one entity will have continuous serial number. This is possible only if DIS slips had
been issued by the DP to one or few persons controlling the alleged group.
9.158. The details contained in the sample CDSL DIS executed by Karvy DP is
summarized below:
Sr. no.
DIS Sr. No.
Instruction No.
Source Client id
Source Client name
Source DP
Target Client ID
Target DP
Name of Security
Quantity
Date of Execution
1. 78965 18420 1301440000147251
Aditi Gandhi KCL 1301440000307503
KCL IDFC 266 11.08.05
2. 78964 18419 1301440000147245
Turang Gandhi
KCL 1301440000307503
KCL IDFC 266 11.08.05
3. 78963 18418 1301440000147230
Rohini Gandhi
KCL 1301440000307503
KCL IDFC 266 11.08.05
4. 78962 18417 1301440000147226
Miya Gandhi KCL 1301440000307503
KCL IDFC 266 11.08.05
5. 78961 18416 1301440000147211
Yavan Gandhi
KCL 1301440000307503
KCL IDFC 266 11.08.05
6. 78960 18415 1301440000147207
Lakendra Gandhi
KCL 1301440000307503
KCL IDFC 266 11.08.05
7. 78959 18414 1301440000147190
Jimish Gandhi
KCL 1301440000307503
KCL IDFC 266 11.08.05
Page 153 of 191
8. 78958 18413 1301440000147186
Devi Gandhi KCL 1301440000307503
KCL IDFC 266 11.08.05
9. 78957 18412 1301440000147171
Bankim Gandhi
KCL 1301440000307503
KCL IDFC 266 11.08.05
10. 78956 18411 1301440000147167
Adip Gandhi KCL 1301440000307503
KCL IDFC 266 11.08.05
11. 78955 18410 1301440000147152
Tukhar Gandhi
KCL 1301440000307503
KCL IDFC 266 11.08.05
12. 78954 18409 1301440000147148
Deparv Gandhi
KCL 1301440000307503
KCL IDFC 266 11.08.05
13. 78953 18408 1301440000147133
Nisar Gandhi KCL 1301440000307503
KCL IDFC 266 11.08.05
14. 78952 18407 1301440000147129
Yatri Gandhi KCL 1301440000307503
KCL IDFC 266 11.08.05
15. 78951 18406 1301440000147114
Lajja Gandhi KCL 1301440000307503
KCL IDFC 266 11.08.05
16. 78990 18405 1301440000147509
Lakshana Gandhi
KCL 1301440000307503
KCL IDFC 266 11.08.05
17. 78989 18404 1301440000147492
Jinal Gandhi KCL 1301440000307503
KCL IDFC 266 11.08.05
18. 78988 18403 1301440000147488
Hanil Gandhi KCL 1301440000307503
KCL IDFC 266 11.08.05
19. 78987 18402 1301440000147473
Dhara Gandhi KCL 1301440000307503
KCL IDFC 266 11.08.05
20. 78986 18401 1301440000147469
Barun Gandhi KCL 1301440000307503
KCL IDFC 266 11.08.05
Note: The target BO ID of 1301440000307503 belongs to Roopalben Panchal
9.159. In respect of the above CDSL DIS, it was observed that all the relevant columns
including the target DP and target BO ID were pre-printed. The transaction number
was not mentioned in the DIS as is the normal practice. The pre-printing of all the
relevant columns including target DP and target BO ID shows that the DP was
assisting the key operators in executing their game plan.
9.160. Based on information obtained from CDSL, it is seen that hundreds of the DIS
submitted by each of the following groups are in continuous serial numbers thereby
showing that Karvy DP had issued the DIS slips pertaining to hundreds of benami /
fictitious dematerialized account-holders to a few purporting to represent the group
and the details are as below:
9.161. CDSL DIS bearing continuous serial numbers used by various key operators
in IDFC IPO
Sr. No
Name of the Group DIS Serial no. From and To.
No of DIS.
1 Manoj Sakseria 40,001 – 42,000 1,999
Page 154 of 191
Sr. No
Name of the Group DIS Serial no. From and To.
No of DIS.
2 Pushottam Bhudwani 32,001-32,130 32,141-32,300 32,311-32,845 61,001-61,100 61,201-62,600 65,401-66,200
129 159 534 100 1,399 799
3 Roopal Panchal 70,001-84,807 14,806
4 Dhaval A Mehta 19,679 – 20,018 339
5 Dharmesh B Mehta 20,405 – 21,106 701
6 Dhaval A Katakia 21,107-21,027 21,172-22,283
80 1,111
7 Dharmesh K Katakia 21,586-21,711 125
8 Dhaval A Mehta
19679-20,018 22541-22,612
339 71
Total 22,691
9.162. CDSL DIS bearing continuous serial numbers in respect of various IPOs
Based on the information submitted by KSBL vide letter dated June 18, 2007, it is
observed that the DP had issued loose DIS slips bearing continuous serial
numbers to key operators in respect of various afferent accounts pertaining to
these key operators. The details of DIS used by the key operators for making off-
market transfers of IPO shares in respect of ILFS, Sasken and Suzlon IPOs are
given below:
9.163. Issue of loose slips to Key Operators in the IPO of ILFS as submitted by
Karvy
Name of the Key operators DIS Serial No from DIS serial No To No of DIS
Manoj Sekseria 42853 43064 211 Roopal Panchal 200142961 200148122 5161
Total 5372 9.164. In the IPO of Sasken Communications.
Name of the Key operators
DIS Serial No from DIS serial No To No of DIS
Page 155 of 191
Jhaveri group 200211506 200212027 521 Roopal Panchal 84146
200209281 86237 200210877
2091 1596
Dharmesh B Mehta 69652 69993 341 Total 4549
9.165. IPO OF SUZLON ENERGY
Name of the Key operators DIS Serial No from DIS serial No To No of DIS
Manoj Sekseria 214330 215347 1017 Bhudwani 213312 214329 1017 Total 2034
9.166. KSBL has contended that requests for issuance of DIS slips were received from
sub-brokers and hence their numbers are continuous. They further contended that
signature on DIS tallied with specimen signature available with them and there was
no irregularity. In view of the numerous facts which corroborate one another and
the fact that issuance of loose DIS slips is a violation of SEBI Circulars, I find this
explanation to be prima facie unacceptable.
9.167. In respect of the off-market transfers from the afferent accounts to the demat
accounts of the key operators, it was observed that the delivery instructions slips
(DIS), which were necessary to be filled in and signed by the beneficial owner to
transfer the shares in his demat account, were pre-printed by KSBL including the
details of the scrip name, ISIN, quantity of shares and the target ID. This was done
to facilitate the transfer of shares from thousands of afferent accounts to the demat
accounts of the key operators, as otherwise, it would have been impossible to
manually fill in the particulars in thousands of DIS slips in respect of each of those
accounts.
9.168. KSBL submitted that they had pre-printed only the serial number, name of the
client and client ID and that the other pre-printed details in DIS like the ISIN,
number of shares, target DP ID etc. were filled in probably by sub-broker. In my
view, this contention too is prima facie unacceptable as pre-printing of all details
Page 156 of 191
including serial numbers and the above details appears to have been done at one go,
as seen from the copies of relevant DIS.
9.169. It is seen that transaction number mentioned on the DIS is the credit transaction
number and is not the debit transaction number, as is the normal case. It is
significant to note that credit transaction number is not available with the DP at the
time of entering the DIS in the system as the details are only available in the target
client account. Incidentally in this case target client account was also with the same
DP ie. KSBL and therefore it was possible for the DP to have the details of the
credit transaction number.
9.170. It was further noted that in respect of the subject off-market transactions many
demat accounts were debited and a single demat account was credited. Since it is
easier to obtain credit transaction number from the demat account statement of
Roopalben Panchal, it appears that the DP has conveniently used the credit
transaction number on the DIS used for debiting various demat accounts and this
indicates that the DP had no debit instruction from the afferent account holders and
DIS had been generated post-facto to make up the records by conveniently using the
CIN available from one account thereby dispensing with the rigmarole of wading
through thousands of afferent account statements which is cumbersome and
laborious.
9.171. With respect to the credit instruction number (CIN) mentioned in the DIS instead
of debit transaction number, Karvy DP has claimed that the CINs were filled in at
the instance of CDSL during the inspection of the DP by the depository. In this
regard, I note that in an earlier proceeding before me i.e. the post-decisional hearing
granted to the DP pursuant to the interim order dated April 27, 2006, KSBL
contended that the mentioning of CIN in the DIS was a clerical error. The excuse of
clerical error then proferred by Karvy DP did not pass muster in the earlier
proceeding and therefore, it appears that Karvy DP has thought up a new excuse
Page 157 of 191
stating that the CIN was entered at the instance of the depository. Therefore, I find
this explanation to be prima facie untenable.
9.172. Observations on Fabrication of records
The account opening forms of many of the afferent dematerialized accounts opened in
bulk, as above, were found to contain letters from scheduled commercial banks
certifying the identity and address of the account holders. Karvy DP accepted these
bank letters towards POI and POA for opening demat accounts. On further
verification, it was found that these bank letters relied upon by Karvy DP for opening
dematerialized accounts were forged. An inference of fabrication of KYC documents
(bank introduction letters) by KSBL for showing compliance with KYC norms was
drawn. The reasons broadly for such inference were the following:
(a) The respective banks had denied issuing the same and stated that the stationery
was materially different from their bank stationery (in case of BHOB), that there was
no official by name of purported signatory (in case of two branches of BHOB).
Further, the photographs appearing in the introduction letter and in the corresponding
bank records did not match.
(b) The clients representing various groups have denied having submitted such bank
introduction letters with their demat account opening forms.
(c) The client details in the relevant bank introduction letters have exact
correspondence with that in the depository system including minutiae like capital
letter, space, comma, full stop etc. The inference was that the client details were
downloaded from the depository system, after the demat account was opened.
(d) There was perfect matching of bank details, including minutiae between that in
the depository system (which are associated with a bank branch’s MICR number) and
that contained in the forged bank letter. In this context, it was observed that
practically the MICR details such as bank name, branch name, address and PIN code
were already available in the depository system and could not have been uploaded by
anybody else. The inference therefore was that these details might have been
Page 158 of 191
downloaded from the depository system together with other details as in (c) above for
use in forging bank introduction letters by someone who had access to the depository
system, i.e. most likely the DP, KSBL.
9.173. Karvy DP contended that the fabrication might have been done by other parties
involved i.e. key operators and banks. The perfect matching of the details contained
in the fabricated bank letters including minutiae with the data available in the
depository system shows that the fabrication could have been done by an entity
having access to the depository system. In this regard, I note that the key operators
were not DPs and do not have access to the depository software. As for banks, I
find no reason for them fabricate their own letterheads when they might as well
have used the original letterheads available with them.
9.174. As regards the finding that the bank introduction letters contained the client
details corresponding exactly even to the last spelling and punctuation mark to that
in the depository system, KSBL contended that such data in soft form was taken
from sub-brokers and used for upload in the system and therefore was also available
with the sub-brokers. While it is possible that such data was also available with sub-
brokers, the further matching of the details in the bank introduction letters also with
the MICR details like bank address, city and PIN code as decoded in the depository
system could reasonably lead to the inference that KSBL might have used the data
in fabricating the letters.
9.175. The uploading of data in soft copy cannot explain the perfect matching of the
bank details in the fabricated bank letter with the MICR details contained in the
depository system. The perfect matching of the bank details in the fabricated bank
letters accepted by Karvy DP towards KYC verification for opening demat accounts
with the MICR details in the depository system can only lead to the inference that
the MICR data in the depository system has been downloaded to fabricate the bank
letters. Since only the DP has the facility to download the data from the depository
Page 159 of 191
system, the attempt of Karvy DP to deflect the needle of suspicion does not pass
muster.
9.176. Karvy DP claimed that taking information from agents is a market practice
adopted by DPs. In this regard, I understand that DPs do not accept information in
soft copy from agents. In cases where large number of DP application details need
to be entered into the depository system, the DPs engage data entry operators who
come to the premise of the DP and make the entries in the depository software
available at the DP’s premise. An independent verification of the data is done by a
staff of DP before uploading the same in the depository system. Thus, Karvy’s
claim of having accepted the details of demat clients in soft copies from the sub-
brokers is at variance to the market practice and the claim is an after-thought to shift
the blame to the key operators for the acts of commissions and omissions of Karvy
DP.
9.177. Further, in order to accept the soft copy in the format that can be directly
uploaded in the depository system, the DP would have to provide its agent the
software relating to the depository system. If Karvy DP had indeed adopted such
practice, the same is at variance to the market practice, as DPs do not provide
access to the depository software to third parties outside the premise of the DP.
9.178. As noted earlier, it is not a practice of the DPs to provide the depository software
outside their premise. If Karvy DP had provided the depository software to its sub-
brokers for use outside the premises the same is at variance to the market practice.
Alternatively, if it did not provide the depository software outside its premises, then
the fabrication of the bank letters could have happened only in the premises of
Karvy DP. Either way Karvy DP is guilty of allowing the depository software that
is available to it as a registered DP, for being used to fabricate bank letters which in
turn were used for opening dematerialized accounts in fictitious / benami names
with the DP. That apart, the very creation of about 50,000 fictitious afferent
accounts is nothing but fabrication.
Page 160 of 191
10.0. CONSIDERATION OF KCPL RTI MATTER
I have considered the Enquiry Report, the Show Cause Notice, the Reply submitted
by KCPL and the oral submissions made on behalf of KCPL. Admittedly, KCPL,
KCL, KSBL etc. are the group companies of Karvy and the connection between the
various Karvy Group entities including that of KCPL is established in the
discussion mentioned earlier in this order. The contention of KCPL that there was a
clear division of operations between it and other Karvy entities is not acceptable in
the facts and circumstances of the case which amply demonstrate how such a
division gave way to a common cause by abusing their respective positions in the
business chain which was evident in some of the IPO’s.
10.1. I note that KCPL in its reply dated January 8, 2007 stated that it is a joint venture
with equal shareholding between KCL (admittedly a Karvy group entity) and
Computershare Ltd., Australia. In the reply of KSBL (in its capacity as a DP and a
stock broker) it has been specifically mentioned that the Karvy group companies
inter alia comprised of KCPL. Further, the communication of Shri Vincent Paul (an
employee of KSBL) on behalf of KCPL would establish that there were certain
managerial links between KCPL and KSBL and which also indicate that KCPL
failed to maintain arms length distance with its associates as mentioned above.
Further, Shri V. Mahesh (employee of KSBL was also the signatory of KCPL in the
inspection conducted by SEBI.
10.2. As discussed earlier in this order the key operators opened multiple and fictitious
applications in various IPOs and the act on the part of KCPL sending common
refund order in respect of the applications made by the key operators would
establish that the KCPL was supplementing the activities of its associates in various
irregularities in the process of IPOs.
Page 161 of 191
10.3. In the facts and circumstances, in view of the established direct connection between
KCPL and other Karvy group entities the role of KCPL cannot be viewed in
isolation but has to be seen in the overall context of the activities of other Karvy
group intermediaries as discussed earlier.
10.4. I also note that KCPL had issued single consolidated refund orders in respect of the
benami/ fictitious applications of Key Operators like Roopalben Panchal,
Purushottam Budhwani, Manoj Seksaria and Sugandh Estates. In the Yes Bank
IPO, KCPL issued a single refund order no: 400002 favouring Bharat Overseas
Bank( BhOB) for 53.89 crores in respect of 12676 applicants. In the IPO of IDFC,
single refund order no:610003 for Rs.27.35 crores was issued favouring BhOB in
respect of 6878 IPO applicants.
10.5. It is pertinent to note that issuing of single consolidated cheque/refund orders have
not been disputed by KCPL and it is evident that the consolidated cheques were
forwarded to the financier. The fact that there were common directors at the helm of
KCL and KCPL necessarily indicates that the said entities were aware of each
others actions more so when one entity (KCL) was financing the IPO applicants and
the other (KCPL) was issuing common refund orders in such cases. In this context,
I note that KCL who acted as a financier in many such issues, obtained its dues in
respect of repayments from IPO applicants whom it financed, directly from the
bank out of the consolidated refunds credited to the bank by KCPL. Hence the act
of issuing singe refund orders facilitated the entities who extended finance and the
key operators who had applied in the IPO’s to continue with the scheme/
arrangement till the same was detected by SEBI. Therefore, the action of KCPL
cannot be viewed as facilitating the 'settlement process' and administrative in
nature as contended by them. Though KCPL submitted that it had received requests
from the financier institutions for issuing a consolidated refund order, the act of
KCL adjusting the amount due to it as a financier out of the consolidated refund
order issued by KCPL clearly indicates that KCPL was privy to the activities KCL.
Page 162 of 191
10.6. Therefore, the alleged violations made by KCPL have to be viewed in the overall
factual context. I note that KCL had arranged large amount of finance for many key
operators mainly to Shri Purshottam Bhudiani, Shri Manoj Seskaria and Smt
Roopalben Panchal. I also note that large number of afferent accounts were opened
by the said key operators with the Karvy DP. Admittedly the issue of single
consolidated cheques/ refund orders have not been disputed by KCPL and that the
consolidated cheques were forwarded to the financier. The submission of KCPL
was that if KCL was aware of the fictitious nature to the application the same could
not be attributed to KCL. In the present case, I note that there were common
directors in KCL and KCPL and that indicates that the entities were aware of the
actions of each other, more so when one entity (KCL) was financing the IPO
applicants and the other (KCPL) was issuing common refund orders in such cases. I
also note that KCL who was the financier in many IPOs, obtained its dues in respect
of repayments from IPO applicants whom it financed, directly from the bank out of
the consolidated refunds credited to the bank by KCPL. Therefore, the action of
KCPL could not be viewed as facilitating the settlement process and administrative
in nature as contended by them. Further I also note that KCPL was aware of the
actions of its related entities which was discussed in detail in the enquiry report.
10.7. Issuance of Refund in cases where no bank accounts were mentioned in demat
records
10.8. In terms of SEBI guidelines, in public issues, at the time of making allotment and
issuing refunds the RTIs should use the demographic and bank details of the IPO
applicants as contained in the depository system. It was found that in respect of
4000 dematerialized accounts held with Karvy DP pertaining to the key operators
Purshottam Budhwani and Manojdev Seksaria, the data in the depository system did
not indicate the bank account details of the dematerialized account-holders.
Therefore, in the case of IDFC IPO, Karvy RTI could not have issued refund orders
in respect of these 4000 dematerialized accounts pertaining to the key operators.
However, it was found that Karvy RTI had indeed issued refund orders in respect of
Page 163 of 191
these 4000 dematerialized account-holders. When queried by the Enquiry Officer in
this regard, KSBL in its reply dated January 19, 2007 stated that the bank details of
the demat account holders was mentioned in the respective application forms and
the same had been captured in the back office of the DP and upload to the DPM
(Depository Participant Module of the CDSL depository system). KSBL further
stated that
“b. ..… ..On verification of the back office records, we find that the bank account
details are available… … ..
c. The absence of these details with CDSL may be due to system related issues in
the software of CDSL, at the time of bulk upload.”
10.9. Thus, it is clear that the depository system did not contain the bank account details
of the 4000 afferent dematerialized account holders pertaining to the key operators
Purshottam Budhwani and Manojdev Seksaria.
10.10. It follows that the refund was issued by Karvy RTI in respect of these 4000
applicants by accessing the back office records of Karvy DP, which shows that
various entities belonging to the Karvy group were acting in a collusive manner
with the key operators.
10.11. All the activities of RTI need to be appraised in the context of the big picture. The
same reveals that the afferent accounts were fictitious, crafted by playing on names
in several permutations and combinations in a repetitive sequence. It was just a play
on the names without the players. In effect the Karvy group was dealing only with
key operators. In that view of the matter consolidated refund, albeit administratively
convienent, assumes ominous significance. It turned out to be a collusive activity
under the guise of administrative expediency. In appraising the role of Karvy
Group, the basic feature of the case should not be lost sight of i.e one has to look
beyond the elaborate edifice of make believe. Further, the closure of such afferent
Page 164 of 191
accounts by Karvy later in December 2005 confirms the nature of accounts the
group was dealing, during their existence.
10.12. I note that the inspection conducted by SEBI found that KCPL had not exercised
due diligence in weeding out multiple, invalid applications thereby allowing such
applications to be allotted shares in the public issue of Yes Bank and IDFC Ltd. The
details of such discrepancies as revealed during the said inspection were explained
in detail in the enquiry report. Further, the discussion relating to DP contains
copious references to interconnected activities among the group members besides
highlighting their complementary role in abusing the IPO process. In view of the
above, I do not find any reason to disagree with the findings of the Enquiry Officer.
11.0. CONSIDERATION OF KSBL BROKER MATTER
I note that the Enquiry Officer in his report dated March 15, 2007 observed that the
findings of the enquiry against KSBL as the depository participant might by
considered as the same and was reflecting on the various activities of KSBL as the
stock broker. He also observed that the various irregularities in the opening of
accounts, irregularities in off market transactions by way of pre printed DIS etc.
have to be taken into account as the same would also highlight the activities of
KSBL as a stock broker in facilitating the key operators in furtherance of their
objectives.
11.1. I note that KSBL had assisted and introduced the key operators in opening of bank
accounts with BhOB, Worli, Goregaon and Ahmedabad branch. The said accounts
have been introduced by the employees of KSBL. The submission of KSBL is that
simply because its employees had introduced the accounts and put the address or
stamp of the company on the forms, it could not be concluded that the Broker was
aware of the activities of the employees. It further added that its employees
introduced certain bank accounts after fulfilling the KYC requirements. In this
context I note that in respect of the bank account number 12149 of Roopal
Page 165 of 191
maintained with BhOB 50 additional names were attached. As discussed above,
KSBL in his appeal memo (SAT) admitted that it had given such certificate.
Similarly 37 accounts were opened in the said branch with additional 50 names
attached with the bank account opening forms certified by KSBL.
11.2. In view of the fact that the employees of KSBL were actively introducing the
accounts to the bank indicate that it was facilitating opening of many bank accounts
which in turn facilitated the opening of large number of demat accounts which were
used for applying the IPO shares. In this context, I also note that the Karvy DP had
opened as many as 37105 and 17795 demat accounts in CDSL and NSDL in a short
time. The contention that the alleged afferent accounts have been opened by IPO
sub brokers cannot be accepted in the facts and circumstances wherein the
participation of the Karvy Group in its various roles as a broker and DP was
manifest from their active involvement in the entire gamut of events. Further, I note
that KCPL (another Karvy group entity) was the registrar to the issue in the public
issue of Sasken Technologies and Suzlon Energy and the same facilitated the
activities of the key operators and their subsequent sale of shares through KSBL. In
the facts and circumstances, it is established that KSBL was involved in the entire
manipulation by its active presence in various roles such as DP, broker, RTI (group
company).
11.3. Based on the examination of the bid book data obtained from Karvy as well as the
Stock Exchange, it is seen that the application was bid by the broker having the
code “07701”. Based on information obtained from NSE, it is seen that the broker
code “07701” belongs to Karvy Stock Broking Ltd. Thus it is seen that KSBL in its
capacity as a broker of NSE and also a sub-syndicate member has bid the
application forms in respect of the applicants financed by KCL through IPO finance
to the Key Operators. It is clear that the individual application forms of these
applicants did not contain the payment for the IPO application. This is evidenced by
the fact that if there had been a cheque/DD attached to the application form, the
Page 166 of 191
same would have been collected by the banker to the issue and there would have
been no occasion for KCL to make RTGS transfer directly to the escrow account
may days after the closure of the public issue.
11.4. It was seen that the 5200 IDFC IPO applicants financed by Karvy through Roopal
Panchal had only eight surnames i.e. Pandya, Rathi, Desai, Verma, Gandhi, Trivedi,
Vala and Pathak. The details are as below:
Last Name No. of Applicants PANDYA 1000 RATHI 500 DESAI 680 VERMA 1000 GANDHI 1000 TRIVEDI 200 VALA 100 PATHAK 720 Total 5,200
11.5. An extract of the salient fields of the bid book is given below in respect of 100 bids
made in the name of applicants having the last name as “Pandya”:
BROKER LOCATION USER
ID NAME OF USER
DATE OF ENTRY
IHNO APPL_NO NAME ADD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:07 PM
2975001 32990828 KUNAL PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:10 PM
2975002 32990829 BAKULA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:13 PM
2975003 32990830 GRAMI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:16 PM
2975004 32990831 JAKSHREE PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:18 PM
2975005 32068477 KUNJ PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:22 PM
2975006 32068478 VAGNA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:25 PM
2975007 32068479 NIRAN PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE
Page 167 of 191
BROKER LOCATION USER ID
NAME OF USER
DATE OF ENTRY
IHNO APPL_NO NAME ADD
ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:27 PM
2975008 32068480 NISHA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:30 PM
2975009 32068481 RAMESH PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:33 PM
2975010 32068482 AAKASH PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:35 PM
2975011 32068483 BALA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:39 PM
2975012 32068484 DEV PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:41 PM
2975013 32068485 GRASHIT PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:44 PM
2975014 32068486 JEET PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:46 PM
2975015 32068487 KUNALPANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:49 PM
2975016 32068488 PAJAN PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:52 PM
2975017 32068489 NIRBHAY PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:55 PM
2975018 32068490 NISHANT PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:23:58 PM
2975019 32068491 RANI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:00 PM
2975020 32068492 AANSHI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:02 PM
2975021 32068493 BALCHAND PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:05 PM
2975022 32068494 DEVAN PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE,
Page 168 of 191
BROKER LOCATION USER ID
NAME OF USER
DATE OF ENTRY
IHNO APPL_NO NAME ADD
AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:07 PM
2975023 32068495 GRISHA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:10 PM
2975024 32068496 JEEVAN PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:13 PM
2975025 32068497 KUNIT PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:15 PM
2975026 32068498 VAMYA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:18 PM
2975027 32068499 NIRDESH PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:21 PM
2975028 32068500 NISHIT PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:23 PM
2975029 32068501 RANJIT PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:26 PM
2975030 32068502 USHMA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:28 PM
2975031 32068503 BALI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:30 PM
2975032 32068504 DEVANG PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:32 PM
2975033 32068505 GUDDY PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:34 PM
2975034 32068506 JENITH PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:37 PM
2975035 32068507 KUSH PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:40 PM
2975036 32068508 YASH PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:43 PM
2975037 32985551 NIRJA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
Page 169 of 191
BROKER LOCATION USER ID
NAME OF USER
DATE OF ENTRY
IHNO APPL_NO NAME ADD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:46 PM
2975038 32985550 NISHU PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:48 PM
2975039 32985549 SUNITA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:51 PM
2975040 32985957 AARTI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:53 PM
2975041 32985775 BALRAM PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:56 PM
2975042 32985774 DEVANSH PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:24:59 PM
2975043 32985836 GULAB PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:01 PM
2975044 32985835 TRIKAL PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:03 PM
2975045 32985834 KUSUM PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:06 PM
2975046 32985833 YASHANG PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:09 PM
2975047 32985832 NIRMAM PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:12 PM
2975048 32985831 SURESH PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:15 PM
2975049 32985830 ABHAY PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:18 PM
2975050 32985829 DEVANSHI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:20 PM
2975051 32985828 GULJAR PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:23 PM
2975052 32985827 JENNY PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:26 PM
2975053 32985826 LABOHA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE
Page 170 of 191
BROKER LOCATION USER ID
NAME OF USER
DATE OF ENTRY
IHNO APPL_NO NAME ADD
ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:28 PM
2975054 32985825 YASHI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:31 PM
2975055 32985824 NIRU PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:33 PM
2975056 32985823 NITA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:36 PM
2975057 32985822 UTAPLL PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:39 PM
2975058 32985821 ABHIGNA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:41 PM
2975059 32985820 BALWANT PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:44 PM
2975060 32985819 DEVARSHI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:46 PM
2975061 32985818 GUMAN PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:48 PM
2975062 32985817 JHANKI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:50 PM
2975063 32985816 LAGNI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:53 PM
2975064 32985815 KASHU PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:56 PM
2975065 32985554 NIRUPAMA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:25:58 PM
2975066 32985553 NITANSH PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:01 PM
2975067 32985552 SWATI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:03 PM
2975068 32985776 ABHILASH PANDY
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE,
Page 171 of 191
BROKER LOCATION USER ID
NAME OF USER
DATE OF ENTRY
IHNO APPL_NO NAME ADD
AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:06 PM
2975069 32985771 BALWIR PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:08 PM
2975070 32985770 DEVASPA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:11 PM
2975071 32985769 GUNISH PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:14 PM
2975072 32985768 JIGAR PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:17 PM
2975073 33016532 LAHAR PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:19 PM
2975074 32985766 YATNA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:22 PM
2975075 32985765 NIRVI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:25 PM
2975076 32985764 NITIN PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:28 PM
2975077 32985763 TRUSHIT PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:31 PM
2975078 32985813 ABHISHEK PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:34 PM
2975079 32985812 BANJUL PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:36 PM
2975080 32985811 DEVENDRA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:39 PM
2975081 32985810 GUNJAK PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:43 PM
2975082 32985809 JIGISH PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:45 PM
2975083 32985808 LAJJA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
Page 172 of 191
BROKER LOCATION USER ID
NAME OF USER
DATE OF ENTRY
IHNO APPL_NO NAME ADD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:48 PM
2975084 32985789 YATRI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:50 PM
2975085 32985788 NISAR PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:53 PM
2975086 32985787 DEPARV PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:55 PM
2975087 32985807 TUKHAR PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:26:57 PM
2975088 32985805 ADIP PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:27:00 PM
2975089 32985804 BANKIM PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:27:03 PM
2975090 32985803 DEVI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:27:05 PM
2975091 32985802 JIMISH PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:27:10 PM
2975092 32985801 LAKENDRA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:27:13 PM
2975093 32985800 YAVAN PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:27:17 PM
2975094 32985799 MIYA PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:27:21 PM
2975095 32985798 ROHINI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:27:23 PM
2975096 32985797 TURANG PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:27:25 PM
2975097 32985796 ADITI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:27:29 PM
2975098 32985795 BANSI PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:27:34 PM
2975099 32985794 DHAIVAT PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE
Page 173 of 191
BROKER LOCATION USER ID
NAME OF USER
DATE OF ENTRY
IHNO APPL_NO NAME ADD
ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
07701 HYDERABAD 10753 SHRISHAILAM L
7/22/2005 3:27:37 PM
2975100 32985793 GUNJAL PANDYA
406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD
11.6. From the above table, it may be seen that the bids were entered by one Shri
Shrishailam L, an employee of KSBL. The above 100 applications have been
entered in a time span of 1 minute and 16 seconds ranging from 3:23:07 pm to
3:27:37 pm. It is seen that the bids have been entered within a time difference of 2-3
seconds. The address of all the applicants is the same. In many of the instances, the
application numbers are continuous e.g. 32068477, 32068478, 32068479,
32068480, 32068481, 32068482, 32068483, 32068484, 32068485, 32068486,
32068487, 32068488, 32068489, 32068490, 32068491, 32068492, 32068493,
32068494, 32068495, 32068496, 32068497, 32068498, 32068499 and 32068500.
11.7. Further, the examination of the bid data revealed that KSBL had similarly bid the
application forms in respect of thousands of applicants belonging to various Key
Opertor Groups. The details are given below:
Name of Key Operator
No. of Application forms
Application Amount (Rs.)
Allotment Amount (Rs.)
Refund Amount (Rs.)
Refund Order Number
Biren Kantilal Shah 1210 57596000 10943240 46652760 690001, 690003, 690005, 690008 and 770001 Purushottam Budhwani 2000 95200000 18088000 77112000 183144 to 184143 (1000 numbers) D.B. Mehta 498 23704800 4503912 19200888 690001 Roopalben Panchal 5200 247520000 47028800 200491200 173217 to 174033 (817 numbers), 173193 to
173197 (5 numbers) and 690001 Dhaval Katakia 519 24704400 4693836 20010564 690001 Parag Jhaveri/SEIPL 2125 101150000 19218500 81931500 690009 Manoj Dev Seksaria 1998 95104800 18069912 770034888 181146 to 182145 (1000 numbers) 11.8. It may be noted that in respect of the above applicants, Karvy provided consolidated
refund order and also requested BhOB to adjust the refund against the loan provided
by them.
11.9. Bidding in Suzlon IPO
Further, it is noted that KSBL had bid the applications of the afferent entities
pertaining to the key operators. Since KCL had provided finance to the applicants and
Page 174 of 191
since the application was provided by KCL through direct RTGS transfer to the
escrow account of Suzlon IPO, it follows that at the time of bidding these applications
no payment instrument i.e. cheque / DD was available with the applications.
Therefore, it follows that KSBL, acting as a broker and sub-syndicate member had
bid the applications without receiving the 100% margin.
11.10. In addition, it needs to be recognized that the fictitious nature of affrenet accounts
is not disputed. In that view of the matter, the introduction of bank accounts relating
to such afferent accounts by KSBL is a just a make –believe. Also the group was
only dealing with the key operators. That being so, the entire exercise of
introduction of accounts, the bidding process and the sale of shares peters out to be
a screaming farce, which they now well. The bed-rock of material evidences as
discussed in relation to DP while covering the IPO process bears eloquent
testimony to the same.
11.11. The role of the DP and the Broker has been discussed in the preceeding
paragraphs of this order. The said discussion is to be taken into account while
deciding the role of the broker in the present proceedings. In view of the above, it is
fairly established that the various irregularities in opening of accounts, assisting and
facilitating the key operators in cornering of shares, irregularities in off market
transaction by way of pre printed DIS etc. have to be taken into account as the same
would also highlight the activities of KSBL as a stock broker in facilitating the key
operators in their manipulative designs.
11.12. In the facts and circumstances it is fairly established that the Broker violated the
provisions of section 12 A (a), (b) and (c) of the SEBI Act and also regulation 3 & 4
(1) of the FUTP Regulations, 2003. Further by actively facilitating many key
operators. It is established that the broker had failed to maintain high standards of
integrity and further indulged in manipulation and malpractices and thereby
violated the code of conduct specified in clause A (1), A (3)and A (4) of Shedule II
of the code of conduct specified in the Broker Regulations.
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11.13. A mere denial on self serving assertion cannot displace the presumption of fact
arising from inferences drawn from a mass of factual details which are
incontrovertible. The circumstances are telltale and the presumption based upon
them should prevail, more so where intentions are shrouded in secrecy or within the
special or peculiar knowledge of persons concerned. Several circumstances of a
determinative character coupled with the inference arising from the conduct of the
parties in a major market manipulation could not simply be the handiwork of the
key operators alone (as alleged by the DP) and could reasonably lead to a
conclusion that the others were also responsible as brought out by wealth of
material evidences. The cumulative evaluation of what has transpired at every stage
of the transaction in a large number of IPOs clearly shows that the actions and
inactions, and omissions and commissions on the part of the DP cannot be
neglected as “at the highest a failure of KYC”. On the other hand the activities of
the Karvy group ex-facie exhibits a scheme to deny the genuine retail investors their
quota of allotment.
11.14. Further the entire transactions starting from the introduction of bank accounts of
key operators, opening of demat accounts of key operators, IPO funding to key
operators and the sale of shares of key operators, through the Karvy group
consisting KSBL (as a DP and a stock broker) and KCPL (RTI) would prove the
active participation of the above intermediaries in the entire manipulation. The
contention of the Karvy that it was not aware about the manipulation cannot be
accepted. The contention of the Karvy that afferent accounts were opened by the
key operators, some of them admittedly their IPO sub brokers, would show that
Karvy had directly dealt with the said key operators and the entire transactions
(from cornering the shares and subsequent sale of the said shares) were held
between the karvy and the key operators under the guise of various demat accounts
which were nothing but fictioius accounts created by the key operators with the
assistance of Karvy. In this context, the observation of the SAT “… … .. It is an
undisputed fact that thousands of fictitious/ benami demat accounts were opened
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with the appellant with common addresses and more than 10000 accounts were
opened on one single day. The appellant was under a duty to check and comply with
the various norms. The obvious appears to have been overlooked. Is the action of
the appellant innocent is the question. The appellant is clearly under a cloud and
the truth can be known only after a detailed inquiry. The findings of the inquiry will
either remove the appellant or the cloud.”
11.15. Admittedly, the fictitious demat accounts were opened by Karvy DP on the basis
of bank accounts some of which were admittedly introduced by the employees of
the Karvy Group and the same can be inferred from the reply of KSBL ( Broker)
dated May 19, 2007 ““simply because its employees had introduced the accounts
and perhaps put the address or stamp of the company on the forms, it cannot be
concluded that the company was aware of the activities of the employees.” Coupled
with the statement of Karvy in the appeal memo that the Respondent has not
provided any proof for the introduction as stated in the impugned Order at para
6.35. The Appellant will be in a position to explain only on receipt of the
documents relied upon by the Respondent to arrive at the said observation. It is
stated tat the Appellant had not introduced the said 50 clients to IOB Thaltej. The
Appellant had only certified, pursuant to the request of IPO sub broker, that the said
50 clients had demat account with the Appellant. It is submitted that all the said 50
clients had, as per Appellant’s records, bank accounts with BhOB. Therefore the
certification given by the Appellant was for existence of demat account as sought to
be suggested” it is fairly established that Karvy was very much involved in the
game plan. In the facts and circumstances, it is inconceivable that such large
number of activities such as opening of demats accounts, bank accounts, IPO
finance etc. could have been possible without active collusion of the Karvy group.
Karvy can not escape by pleading ignorance and the only inference that can be
drawn is that there was active participation on the part of Karvy group in the entire
gamut of events which took place from the introduction of the bank accounts,
opening of fictitious demat accounts, IPO finance to key operators etc. The DP is
only feigning innocence which in the facts and circumstances can not be accepted.
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11.16. Even otherwise, the evidence, direct or circumstantial, should be sufficient to
raise a presumption in its favour with regard to the existence of a fact sought to be
proved. As pointed out by Best in “Law of Evidence”, the presumption of
innocence is no doubt presumptio juris; but everyday practice shows that it may be
successfully encountered by the presumption of guilt arising from circumstances,
though it may be a presumption of fact. Since it is exceedingly difficult to prove
facts which are especially within the knowledge of parties concerned, the legal
proof in such circumstances partakes the character of a prudent man’s estimate as to
the probabilities of the case. However, in the present case, it is fairly established
that the Karvy Group was actively involved in each and every part of the
manipulation committed by the key operators by introducing the bank accounts of
the key operators, opening the afferent accounts for the key operators, financing to
key operators and further culminating in the sale of the IPO cornered shares on
behalf of the key operators.
11.17. The series of transactions in the form of opening of bank accounts and demat
accounts by the key operators with the assistance of Karvy and the subsequent
funding to key operators and the sale of shares cornered by the key operators
through the Karvy group would only lead to the finding that the said transactions
were done with a manipulative intent. The said concerted level of activity and that
too on a large scale in opening about 50,000 fictitious afferent accounts with the
participation of all the necessary functionaries in the securities market viz. registrar
to the issue, depository participant, financier and the stock broker is only
compatible with the scheme of manipulating the IPO process with the other
members of the group. The same entails violation of the provisions of Section 12A
of Securities and Exchange Board of India Act, 1992, Regulation 3 and 4 of
Securities and Exchange Board of India (Prohibition of Fraudulent and Unfair
Trade Practices Relating to Securities Market) Regulations, 2003, Regulations 19,
20A, 42, 43, 46 and 52 of Securities and Exchange Board of India (Depositories and
Participants) Regulations 1996, Securities and Exchange Board of India
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(Disclosure and Investor Protection) Guidelines, 2000, 6 and 13 of Securities and
Exchange Board of India (Registrars to an Issue and Share Transfer Agents)
Regulations, 1993, Regulation 5, 7 and 15(1)(b) of Securities and Exchange Board
of India (Stock Brokers and Sub – Brokers) Regulations, 1992.
11.18. Though the Enquiry Officer had observed that it can not be conclusively
established that Karvy fabricated the bank introduction letters, I note that by
introducing fictitious bank accounts, by opening fictitious demat accounts Karvy in
a mannert of speaking, had fabricated such accounts which are otherwise non
existent.
11.19. The elaborate discussion in this order on the various activities clearly demonstrate
that Karvy group (RTI, Broker and the DP) were involved in the manipulation of
IPO process. In the course of their reply, it has been canvassed that as group
companies they were coordinating with each other in the group activities by
rendering the necessary assistance respective to their business operations. In my
view, it would take extreme naiveté to believe in such a version, because the
putative co-ordination under the guise of group activity in the vicissitudes of the
instant case virtually amounted to making a common cause in the abuse of the IPO
process. A group activity normally implies sharing of synergies for a combined
business operation, where the group members have to contribute in their respective
spheres. In the instant case, the summum bonum of the group activity was one of
abusing the IPO process to facilitate cornering of the shares by key operators
through fictitious afferent accounts. The same cannot partake the character of a
group activity as understood in normal commercial parlance. Further , the case
history as brought out is replete with profusion of instances where KSBL, KCPL(
RTI) and KCL joined hands making use of their commercial engagements in the
IPO process chain and such a concerted activity in unison with unity of control and
purpose made it easy for the Group to steer the intended course of action without
any hiccups.
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11.20. It is not a case of any defect in the system, but a classic example of hoodwinking
the system in seeming compliance with all the beguilements.
12.0. Conclusion
The findings of the investigations on the role of Karvy group entities in the IPO
irregularities, the findings of the enquiry proceedings and the findings emerging
from the consideration of submissions of Karvy and the various related
documents forming part of record from interim orders through the course of
appeal till the present proceedings are briefly as under:
12.1. At the outset, the present order seeks to capture the developments in the present
case from 2003 – 2005 in terms of the escalating scale of operations of Karvy group
in diversified roles.
12.2. It is found that Karvy group entities were ubiquitously present in the entire gamut
of the IPO process running from introducing bank accounts, opening of
dematerialized accounts, arranging IPO finance, bidding of applications, making
allotment, issuing refund, making off-market transfers (DIS) and sale of IPO shares
on the stock exchanges. The role of Karvy group entities at each stage of the
process has been examined for uncovering Karvy’s role at every stage and to
ascertain overall control beginning from opening of bank and dematerialized
accounts till making refund and off-market transfer of IPO shares.
12.3. The examination covered the following activities of Karvy:
? Introducing the BhOB and IOB bank accounts of key operators and certifying
addition of fictitious / benami names to the bank accounts of the key operators.
This was done for the key operators to avail retail IPO finance from the banks in
the names of the fictitious / benami entities.
? Using the bank accounts introduced by them for opening dematerialized accounts
in the names of key operators and afferent entities. The afferent dematerialized
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accounts were opened in bulk on few dates around the dates of major IPOs. For
the purpose of opening dematerialized accounts, the names / surnames of the
afferent entities were used in various permutations and combinations and the
address of the key operators were indicated as the address of afferent
dematerialized account-holders.
? Providing of IPO finance to the fictitious / benami entities through the medium of
key operators. KCL released the IPO finance (in non-RTGS cases) directly to the
key operators. In effect, no funds were received from the bank accounts of the
afferent entities and no refund was given to the bank accounts of the afferent
entities. Karvy knew that the entities to which they purportedly provided IPO
finance were fictitious / benami and in effect, Karvy was dealing only with the
key operators. KCL an NBFC provided IPO finance to the key operator at an
interest rate of 19% p.a. The interest was computed on the basis of IPO finance
for a period 15 days. However, due direct RTGS transfer to the escrow account
many days after the close of issue and due to prompt encashment of the
consolidated refund, the period of financing was compressed to about one week,
thereby significantly improving the returns on the loan provided by KCL.
? Bidding of the application forms of fictitious / benami entities without the
corresponding payment (100% IPO margin). KSBL acting as a stock broker and
sub-syndicate member bid the application forms of the fictitious / benami
applicants pertaining to various key operators even though application money was
not received from the applicants at the time of bidding.
? Issuing of consolidated refund orders. KCPL, acting as RTI issued consolidated
refund orders in respect of thousands of fictitious / benami applicants. This
enabled quick and easy encashment of the refund money by the key operators and
the refund money was recycled for the subsequent IPOs. This also facilitated
quick return of the IPO finance where KCL had funded the key operators for
making applications in fictitious / benami names. Further, since in many cases the
bank accounts of the fictitious / benami applicants did not exist, if the RTI had
issued individual refund orders mentioning the bank account numbers as available
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in the depository system, the encashment of the refund orders would have been
impossible.
? Issuing directions for appropriation of refund money. KCL, acting as an NBFC
had requested BhOB to adjust the refund pertaining to thousands of fictitious /
benami applicants towards the IPO finance provided by it to the key operators.
? Executing off-market transfers including irregularities relating to issuing and
processing of DIS. KSBL (erstwhile KCL), acting as DP, had executed thousands
of off-market transfers from the afferent dematerialized accounts to the
dematerialized accounts of the key operators within a span of one day. In ordinary
course, the key operators could not have got the same done without the
involvement of the DP. It was found that the off-market transfers had been
executed by the DP in some instances without there being any Delivery
Instruction Slips and in certain other instances, featuring pre-printed columns in
respect of all relevant fields including target client details which can never be in
the knowledge of the DP before execution, enabling the key operators to execute
thousands of off-market transfers in a single day.
12.4. The manner of opening bank accounts and dematerialized accounts clearly
demonstrates Karvy’s control and their knowledge of the fictitious / benami nature
of these accounts. In effect, Karvy was dealing only with the key operators and not
with anyone else. The IPO process, IPO financing, RTGS transfer to the escrow
account, issuance of consolidated refund order and issues relating to DIS, further
strengthen the above finding with tell tale strands of Karvy’s control at each and
every stage of IPO process. The examination of Karvy’s role, as above, inter alia,
revealed the following salient findings:
12.5. The evolution of Karvy’s role in the IPO irregularities began during the year 2003
when Karvy had presented to BhOB an idea paper and a process flow. As per the
process flow, the IPO applications would be filled in by the investor and a
cheque/DD in favour of the Bank towards the margin amount shall be deposited.
The investor would need to open the Demat account with Karvy who would place a
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lien on the shares deposited into the investor's account until the investor clears the
loan with the Bank. A perusal of the process flow envisaged for IPO funding as
spelt out by Karvy shows that there was a specific assuring clause to the effect that
there were no chances for cases such as benami applications, multiple applications,
fraudulent investors etc. thereby providing comfort to the bank.
12.6. Pursuant to the arrangement, Karvy had introduced numerous bank account
holders to BhOB, Ahmedabad branch. The first such bank account introduced by
Karvy to BhOB Ahmedabad appears to be a set of account numbers starting with
‘50795’. The system of internal numbers (e.g. 50795/1, 50795/5, 50795/14 etc.)
was used for opening many bank accounts starting with the same account number.
The said account no. 50795 was held in the name of Devangi Dipak Panchal as first
holder. It was found that in some of these bank accounts names had been added on
introduction of Karvy Investor Services Ltd.
12.7. Thereafter during June 27 – 30, 2003 Karvy had opened 297 demat accounts on
NSDL indicating the bank account details of the BOs as BHOB, Ahmedabad
branch, Bank account number 50795. While the said bank account no. 50795 was
closed on October 27, 2003 the corresponding demat account continued till
November 2005 when the demat accounts were closed pursuant to verification by
Karvy DP in the wake of SEBI examination of the matter of IPO irregularities.
12.8. Subsequently during December 2003 Karvy Securities Ltd. had introduced a
savings bank account number 54119 in the name and style of “Devangi Dipakbhai
Panchal – GROUP ACCOUNT”. Therefore it is clear that the arrangement between
Karvy and BHOB continued even after the Maruti IPO which closed on June 19,
2003. Further based on analysis of afferent demat accounts held with Karvy DP it
was found that 3450 afferent demat account holders pertaining to the key operator
Roopalben Panchal had indicated their bank account as BHOB bank account
number 54119. These 3450 afferent demat account holders had five common
surnames viz. Luhar (600 nos.), Pari (600), Mistry (600), Shroff (600) and Seth
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(1050). Though the bank account number 54119 was closed on April 24, 2004 the
corresponding 3450 afferent demat accounts continued to be held with Karvy DP
and were closed during November 2005 only.
12.9. Thereafter, during October 2004 – March 2005, KCL / KSBL had introduced 38
bank accounts of the key operators (Roopal Panchal and Kelan Atul Doshi) to IOB,
Thaltej branch. Furhter, KCL / KSBL had certified the list of 50 names that were
attached to each of the above bank accounts. Out of the above 38 bank accounts
one bank account having number 12140 pertaining to Roopalben Panchal was
examined in detail. It ws observed that the said bank account number 12140 was
introduced to IOB Thaltej branch by KSBL. A list of 50 names and specimen
signatures is found attached to the bank account opening form and the list is
certified by KSBL and their rubber stamp is affixed. In this context it may be
mentioned that Karvy in its appeal memorandum (Appeal No. 92 of 2006) inter alia
stated that “… … … .. the Appellant had not introduced the said 50 clients to IOB
Thaltej. The appellant has only certified pursuant to IPO sub- broker, that the said
50 demat accounts with the Appellant. It is submitted that all the said 50 clients had,
as per appellant’s record, bank accounts with BHOB. Therefore, the certification
given by the Appellant was for existence of demat account as sought to be
suggested”.
12.10. The list of 50 names attached to the bank account number 12140 held with
IOB,Thaltej branch begins with the name of SURESH SETH and ends with ADITI
SETH. It is found that Karvy DP had opened the demat accounts in these 50
names on January 5, 2004 and had thereafter introduced the names to IOB on
March 9, 2005. The signatures of the 50 persons certified by Karvy appear similar
and appear to have been made by one person only. Therefore it follows that Karvy
were aware that the names and signatures certified by them were fictitious in nature.
12.11. It was found that on CDSL Karvy DP had opened as many as 1250 demat
accounts using the series of 50 proper names beginning with SURESH and ending
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with ADITI. This had been done by adding different surnames to the series of first
names beginning with SURESH and ending with ADITI. The surnames that were
added included Zala, Rathod, Vania, Patil, Ranka, Pandya, Desai, Rathi, Verma,
Trivedi, Gandhi, Barot, Vala, Pathak, Bhatt, Kapoor, Tated, Kela, Sen, Roy, Irani,
Jha, Mehta, Das and Prasad. Out of these 1250 CDSL demat accounts, 750 demat
accounts have been opened on July 15 – 16 2005 and 500 accounts were opened on
September 22, 2005. On September 22, 2005, Karvy DP had opened 10,000 demat
accounts but had not activated them due to certain alleged deficiencies in the
account opening documents. The 10,000 demat accounts include the 500
dematerialized accounts mentioned above.
12.12. Upon comparing the demat account opening documents of eight entities namely
Guljar Seth, Abhilash Seth, Gunish Seth, Yatna Seth, Nirvi Seth, Ahishok Seth,
Devandra Seth, and Deparv Seth, with the bank loan documents of IOB, it was
observed that IOB had extended IPO finance to these eight names. However, the
photographs affixed on the demat account opening forms and that on the loan
document of IOB were completely different. Instances like this can be multiplied.
12.13. It was found that KCL had provided IPO finance to the various combinations of
50 names starting from SURESH and ending with ADITI. Furhter it was found that
in the IPO of IDFC, KCL had made RTGS transfers to the Escrow account in
respect of the IPO finance provided to these fictitious / benami applicants. Also
KCPL, the RTI, had issued consolidated refund orders in respect of these fictitious /
benami applicants.
12.14. It was found that KCL had provided IPO finance in IDFC IPO to seven key
operators namely Biren Kantilal Shah, Purshottam Budhwani, Dharmesh Mehta,
Roopal Panchal, Dhaval Katakia, Parag Jhaveri and Manoj Seksaria. Based on
information submitted by Karvy it is seen that KCL had executed a loan agreement
with Roopalben Panchal pursuant to which KCL had provided IPO finance of Rs.
18.56 crores to Roopalben Panchal. It was found that Shri Mayur Modi and Shri
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Aditya Gupta, employees of Karvy had acted as references for Roopalben Panchal.
The application money in respect of 10,900 applications pertaining to Roopal
Panchal and other key operators amounting to Rs.51.90 crores was transferred
directly by KCL to the IDFC escrow account on July 30, 2005. It may be noted that
the IDFC IPO closed on July 22, 2005. The amount transferred through RTGS for
Roopalben Panchal was purportedly towards the application money for 5200
applicants. Thus it was found that the 5200 application forms pertaining to
Roopalben Panchal were not accompanied by cheque / DD when the applications
were bid on the exchange system on July 22, 2005. Karvy RTI, pursuant to
allotment of IPO shares, issued consolidated refund orders in respect of these
applicants pertaining to the key operator namely Roopalben Panchal. KCL
requested BHOB to adjust the refund money against the loan provided by it and the
same was complied by BHOB. The same is true in the case of the IPO financing
provided by KCL to the other key operators also. Thus it was found that the margin
money towards loan did not come from the bank accounts of the respective
applicants and the refund money also did not go to the respective applicants. In
essence Karvy was dealing only with the key operators while purporting to deal
with thousands of persons who were nothing but a figment of imagination.
12.15. Further, with regard to the IPO finance provided to the key operators, it was found
that KCL had provided IPO finance to the key operators for a period of 15 days and
had charged interest at 19% p.a. reckoning the 15 day finance period. However, it
was found that in respect of the IPO finance provided by KCL to the key operators,
it had made RTGS transfers to the IPO escrow account many days after the closure
of the issue. KSBL the stock broker and sub-syndicte member had bid these
applications without receiving the application money. KCPL the RTI had issued
consolidated refund orders in respect of the applicants financed by KCL and KCL
requested the bank (BHOB) to adjust the refund against the loan provided by it.
This ensured that the money towards IPO finance was given by KCL many days
after the closure of issue and the refund was received immediately upon completion
of allotment. Thus the money of KCL was used for IPO finance only for a period
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of 8-10 days while it charged interest for 15 days to the key operators. By adopting
the above modus operandi which was facilitated by the presence of the Karvy group
entities at various stages of the IPO process, Karvy ensured that its money was
actually used only for a period of 8-10 days while charging interest for 15 days
thereby improving the returns on the money loaned by it. It is seen that interest rate
charged by KCL works out to about 47% p.a.
12.16. In terms of provisions of SEBI (DIP) guidelines, market practices and Karvy’s
own submissions it is essential for the IPO application forms in the retail category
to be accompanied by payments towards the application money. As mentioned
earlier KCL had made direct RTGS transfer of Rs.51.90 crores to the IDFC Escrow
account on July 30, 2005 in respect of the 10,900 applications pertaining to various
key operators. The last day for bidding in IDFC IPO was July 22, 2005. Therefore,
it follows that at the time of bidding these 10,900 applications were not
accompanied by the application money in the form of cheque / DD. In this regard, I
note that KSBL has claimed that in respect of the 10,900 IDFC IPO applicants
financed by it a cheque issued by KCL bearing number 336429 dated July 21, 2005
drawn on HDFC Bank was sent by it to the collecting bank at Hyderabad.
However, alledgedly the cheque was misplaced and therefore KCL made the RTGS
transfer of Rs51.91 crores to the IDFC Escrow account on July 30, 2005. The
alleged consolidated cheque number 336429 issued by KCL and the RTGS transfer
made by KCL needs to be viewed in the context of the 10,900 applicants pertaining
to various key operators financed by KCL were fictitious / benami in nature.
12.17. It is seen that in the case of Sasken IPO, Karvy did not take any margin from
Roopalben Panchal. Karvy had provided 100% IPO finance of Rs. 26 crores to
Roopalben Panchal. Further, Karvy had transferred Rs. 9 crores out of the refund
money of Sasken IPO for making application in the IPO of Amar Remedies on
behalf of Roopalben Panchal. In addition, Karvy had made RTGS transfer of Rs.
20.89 crores in the IPO of Amar Remedies towards IPO loan given to Roopalben
Panchal. In this regard Karvy DP in its reply dated May 19, 2007 has stated that “it
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may however, be noted that the margin amount was not transferred to KCL, but
only the loan amount was disbursed to the loanee, who inturn has deposited the total
amount inclusive of the margin amount to the escrow account of the issuer.” In the
normal course of IPO finance the financier collects the margin amount from the
borrower and issues cheque / DD favourig the escrow account for the application
money. This practice is adopted to ensure that the loan money is utilized only for
the purpose of making IPO application. That KCL, instead of adopting the normal
practice as above, released the loan amount directly to the key operator (Roopal
Panchal) shows that Karvy had full control over the manner of application of funds.
12.18. Similarly, it is seen that Karvy had provided IPO finance to various other Key
Operators, namely, Manoj Seksaria, Purushottam Budhwani a nd Parag Jhaveri in
respect of various IPOs namely, ILFS, IDFC, Sasken and Suzlon. As regards the
financing by KCL to Purshottam Budhwani, it was found that KCL had disbursed
the loan amount many days after the closure of the IDFC IPO. In this regard KSBL
in its reply dated May 19, 2006 has stated that “we had received the margin
subsequently. It is submitted that the margin was received by KCL on the date of
closure of the issue. It is reiterated that KCL had not disbursed the loan amount to
Purshottam Budhwani, since KCL had not received the margin.” In this regard it is
noted that KSBL, the stock broker, had bid the IDFC IPO application forms
pertaining to Purshottam Budhwani on the last day of the issue i.e. July 22, 2005.
Apparently the cheques attached to the application forms were encashed a week
later i.e. after the disbursal of the loan money by KCL.
12.19. Further, in the case of Suzlon IPO, the public issue closed on September 29, 2005
and it was found that KCL had made RTGS transfer of Rs.20.51 crores to the
escrow account of Suzlon IPO on October 5, 2005 i.e. many days after the date of
close of the IPO. In this regard, KSBL has submitted that the amount to be
transferred towards margin and the loan funded by KCL for various afferent
applicants in the Suzlon IPO was ascertained only by the evening of September 29,
2005. Since September 30, 2005, October 1 and October 2, 2005 were Bank
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holidays KCL made RTGS transfer to the Suzlon IPO Escrow account on October
5, 2005 in respect of the applicants financed by it.
12.20. In view of the above SEBI examined the bid book of IDFC IPO in respect of the
applications financed by KCL. Examination of the bid book revealed that KSBL in
its capacity as a broker of NSE and also as a sub-syndicate member had bid the
10,900 application forms pertaining to the key operators financed by KCL. Further,
a sampling of the data revealed that many of the applications had been entered by
one or few employees of Karvy. The time gap between entry of successive
applications was only 2-3 seconds. Many of the applicants shared a few common
surnames. The applicants pertaining to a key operator had the same address i.e. the
address of the key operator. Thus KSBL, the stock broker, knew at the time of
bidding the applications that these 10,900 applicants were fictitious / benami in
nature.
12.21. It was found that subsequent to the allotment, KCPL the RTI had issued
consolidated refund orders in respect of these applicants. The refund amount was
adjusted against the loan provided by KCL.
12.22. After the allotment of IDFC IPO shares on August 6, 2005 Karvy DP transferred
these shares from the afferent demat accounts to the demat account of Roopalben
Panchal (client ID 11920868) on August 8, 2005. For the purpose of these off-
market transfers Karvy DP had used DIS bearing continuous serial numbers.
Further in certain of the off-market transactions executed by Karvy DP on NSDL,
the transaction number which is generated by the depository system after the
execution of the transaction was found to be printed on the DIS. In the ordinary
course, a DP executes the depository transactions based on DIS signed by the BO
and after execution the depository system generates a transaction number which is
written on the DIS by the DP and the DIS is kept by the DP for records. The fact
that the transaction number was printed on the DIS used by Karvy DP for making
off-market transfers leads to the inference that the DIS did not exist at the time of
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execution of transactions and was printed by the DP subsequently. This view is
strengthened by the fact that the DIS have holes on the left end and right end of the
slip indicting that the slip has been printed on a continuous computer stationary.
12.23. In respect of off-market transactions executed by Karvy DP on CDSL it was
observed that all the material particulars including the target BO ID and target BO
name to be printed on the DIS. In the ordinary course the DP pre-prints onlyl the
source BO (its client) details on the DIS and the target details are not known to the
DP till the time the BO submits the DIS for execution. The pre-printing of the
target details shows that in the instant case Karvy DP was aware of the modus
operandi adopted by the key operators for cornering of IPO shares and facilitated
the same.
12.24. Thus it may be seen that various entities belonging to the Karvy group were
involved in the entire chain of IPO process and Karvy group utilized the same to
introduce bank accounts of key operators and fictitious / benami entities, open
demat accounts in fictitious / benami names, provide IPO finance to key operators
for making applications in fictitious / benami names, enter the bids without
receiving application money, make consolidated refunds, make allotment, execute
off-market transfers with improper / non-existant DIS and finally sell the IPO
shares on the stock exchanges.
12.25. Even assuming for the sake fo argument that Karvy was not aware of the plans
and modus operandi of the key operators, the manner in which certain sets of names
have been used with change in surnames with systematic regularity for opening
either bank account for financing or for opening fresh demat accounts for cornering
the shares, which was fully in the knowledge of Karvy, should have definitely
alerted them that there was somethihg amiss or untoward about them. But the fact
that such operations were carried out with unquestioning ease clearly demonstrates
Karvy’s complicity in the whole matter.
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12.26. It is fairly established that Karvy DP and the group was very much in the thick of
the entire process of abuse of IPO process
12.27. On a conspectus of the concatenation of events spanning nearly three years which
saw the evolution of the game plan into a full fledged operation of cornering IPO
shares till the final denoument in December 2005 / January 2006 resulting in the
closure of very same afferent accounts which were opened to get around the public
policy in retail quota to the detriment of retail investors, it is fairly established that
Karvy Group was very much in the thick of the entire process of IPO abuse and the
same warrants a penalty as specified in the Enquiry Regulations.
12.28. The penalty is imposed on the basis of the available materials on record. It is
understood that various other investigating agencies are looking into the matter of
IPO irregularities. On receipt of the findings of the said agencies, SEBI is at liberty
to take appropriate actions against Karvy in accordance with law.
12.29. In the facts and circumstances, inter alia taking into account the prohibition
imposed by SEBI vide interim orders dated January 12, 2006 and April 27, 2006 I
hereby pass the following order.
13.0. Order
In view of the foregoing, I, in exercise of the powers conferred upon me in terms of
Section 19 of the Securities and Exchange Board of India Act, 1992 read with
regulation 13(4) of Securities and Exchange Board of India (Procedure for Holding
Enquiry by Enquiry Officer and Imposing Penalty) Regulations, 2002, hereby pass
the following order:
a. Karvy Stock Broking Ltd., Depository Participant (Registartion nos. IN-DP-
NSDL-247-2005 and IN-DP-CDSL-305-2005) is prohibited from opening fresh
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demat accounts till December 31, 2007. This direction will come into force with
immediate effect.
b. The certificate of registration of Karvy Stock Broking Ltd., Member, National
Stock Exchange of India Ltd (Reg. no. INB 230770138), Bombay Stock
Exchange Ltd. (Reg. no. INB 010770130) and the Hyderabad Stock Exchange
Limited (Reg. no. INB 060770139) is suspended for a period of three months. The
said order against the said stock broker shall come into force immediately on the
expiry of 21 days from the date of this order.
c. Karvy Computershare Pvt. Ltd., the Registrar to the Issue (Reg. No INR
000000221) is prohibited from acting as Registrar to an Issue for a period of nine
months. As Karvy Computershare Pvt. Ltd. had already undergone the prohibition
for that period vide Securities and Exchange Board of India order dated April 27,
2006, there will be no further directions against Karvy Computershare P Ltd.
G ANANTHARAMAN
WHOLE TIME MEMBER
SECURITIES AND EXCHANGE BOARD OFINDIA
Place: Mumbai
Date: 22.06.07