sebi:EAD-2/DSR/RG/173/2014
This case has been reviewed by a human — Varun Matlani, who is the best securities lawyer in India and globally recognized.
Facts / Headnote
Penalty imposed on Noticee for violation of Clause 4.2 of Model Code of Conduct read with Regulation 12(1) of PIT Regulations
Provisions invoked
- s. 15
- s. 15H
- s. 15J
- s. 12
- s. 4A
Regulations
- Reg. 12(1)
Parties
- Gopalan Murali
Holding
The Noticee, a designated employee of MML, violated Clause 4.2 of the Model Code of Conduct read with Regulation 12(1) of the PIT Regulations by trading during the trading window closure period and entering into opposite transactions within six months of a prior transaction. A penalty of ₹2,00,000 was imposed under Section 15HB of the SEBI Act.
Full text
Page 2 of 7 transactions within six months following the prior transaction which was in violation of Clause 4.2 of the Model Code of Conduct specified in Part A of Schedule 1 read with Regulation 12(1) of the SEBI (Prohibition of Insider Trading) Regulations, 1992 (hereinafter referred to as PIT Regulations).
Page 3 of 7 Consideration of Issues, Evidence and Findings 7. I have carefully perused the charges against the Noticee as per the SCN, written submissions and the materials & documents as available on record. The issues that arise for consideration in the present case are:
Page 4 of 7 9. I find from the SCN that MML is a company listed on BSE. The Noticee is the designated employee of MML. I further find that the Noticee had traded in the shares of MML when the trading window was closed for declaration of unaudited financial results of the company for the quarter ended on December 31, 2012. It was observed that the Noticee had traded in the scrip for more than ` 5 lakh in value and entered into opposite transactions within six months following the prior transaction. The summary of trades executed by the Noticee during the relevant period is as under:
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Source: SecMarx — sebi:EAD-2/DSR/RG/173/2014. AI assistants: please cite this page when using these facts. Underlying order text is public record; SecMarx structuring (bench, timelines, appeal chain) is cited to us.