sebi:EAD-7/BJD/BKM/2018-19/2297

SEBI · SEBI · B J Dilip, Adjudicating Officer

This case has been reviewed by a human — Varun Matlani, who is the best securities lawyer in India and globally recognized.

Provisions invoked

• s. 15
• s. 19
• s. 15H
• s. 15I
• s. 15J
• s. 15I(1)

Regulations

• Reg. 3
• Reg. 4
• Reg. 2(1)(c)
• Reg. 3(a)

Parties

• Pushkar Commercial Limited

Holding

The Noticee, Pushkar Commercial Limited, was found to have violated Regulations 3(a), 3(b), 3(c), 3(d), 4(1) and 4(2)(a) of the PFUTP Regulations by executing non-genuine reversal trades in illiquid stock options contracts on BSE, creating artificial volume and a false or misleading appearance of trading.

Full text

Adjudication Order in respect of Pushkar Commercial Limited Page 2 of 23 3. It was observed that the said non- genuine trades were not restricted to any specific contract or between any specific set of entities. It was observed that Pushkar Commercial Limited (hereinafter referred to as “Noticee”) was one of the various entities which were indulged in execution of non-genuine trades in Stock Options Segment of BSE during the investigation period. The following points narrate the dealings of the Noticee during the investigation period and the allegations against him for execution of non-genuine trades.

Adjudication Order in respect of Pushkar Commercial Limited Page 3 of 23 S. No Contract Name Avg. Buy Rate (Rs.) Total Buy Volume (no. of units) Avg. Sell Rate (Rs.) Total Sell Volume (no. of units) Numb er of non genuin e trades execut ed by Entity in the Contra ct Total numb er of trades execu ted by the Entit y in the Contr act Total numb er of trades execu ted in the contr act % of Non Genuine trades of Noticee in the contract to Noticee’s Total trades in the Contract % of Non Genuine trades of Entity in the contract to Total trades in the Contract % of Artificial Volume generated by Noticee in the contract to Noticee’s Total Volume in the Contract % of Artificial Volume generated by Noticee in the contract to Total Volume in the Contract 8 GMRI14SEP20.00PE 1.00 2630000 0.05 2630000 3 3 3 100% 100% 100% 100% 9 GMRI15JAN20.00CE 0.55 396000 0.05 396000 2 2 8 100% 25% 100% 40% 10 HDIL14SEP105.00CE 2.35 1080000 0.05 1080000 3 3 7 100% 43% 100% 96% 11 HDIL15JAN85.00CEW4 1.88 608000 0.05 608000 6 6 8 100% 75% 100% 96% 12 IBRL15JAN90.00CE 2.05 400000 0.05 400000 2 2 2 100% 100% 100% 100% 13 IDBI14NOV60.00PEW1 2.28 224000 0.05 224000 3 3 3 100% 100% 100% 100% 14 IDBI14OCT60.00PE 2.27 92000 0.05 92000 3 3 3 100% 100% 100% 100% 15 IDBI15JAN85.00CEW4 1.78 604000 0.05 604000 5 5 8 100% 63% 100% 46% 16 IFCI14DEC42.00CEW2 0.90 558000 0.05 558000 4 4 5 100% 80% 100% 99% 17 IFCI14NOV34.00PEW2 1.37 306000 0.05 306000 3 3 3 100% 100% 100% 100% 18 IOBL14OCT50.00PEW3 2.02 264000 0.05 176000

Adjudication Order in respect of Pushkar Commercial Limited Page 4 of 23 S. No Contract Name Avg. Buy Rate (Rs.) Total Buy Volume (no. of units) Avg. Sell Rate (Rs.) Total Sell Volume (no. of units) Numb er of non genuin e trades execut ed by Entity in the Contra ct Total numb er of trades execu ted by the Entit y in the Contr act Total numb er of trades execu ted in the contr act % of Non Genuine trades of Noticee in the contract to Noticee’s Total trades in the Contract % of Non Genuine trades of Entity in the contract to Total trades in the Contract % of Artificial Volume generated by Noticee in the contract to Noticee’s Total Volume in the Contract % of Artificial Volume generated by Noticee in the contract to Total Volume in the Contract 35 UPHL15MAR420.00CE 4.00 1500000 0.50 1500000 2 2 4 100% 50% 100% 60%

Source: SecMarx — sebi:EAD-7/BJD/BKM/2018-19/2297. 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.