sebi:Order/AN/PR/2025-26/31538

SEBI · SEBI · 1993-11-18 · Amar Navlani, Adjudicating Officer

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Adjudication Order in the matter of Prabhudas Lilladher Private Limited |Page 2 of 79 3.1. Section 23D of SC(R) Act, 1956 read with Clause 1 of SEBI Circular SMD/SED/CIR/93/23321 dated November 18, 1993; and Clause 3 of Annexure of SEBI Circular SEBI/HO/MIRSD/MIRSD2/CIR/P/2016/95 dated September 26, 2016. 3.2. Clause 5.4 of SEBI Circular SEBI/HO/MIRSD/DOP/P/CIR/2021/577 dated June 16, 2021; Clause 8.1 of SEBI Circular SEBI/HO/MIRSD/MIRSD2/CIR/P/2016/95 dated September 26, 2016 and clause 12 (e) and 12 (g) of Annexure-A of SEBI Circular SEBI/MIRSD/SE/Cir- 19/2009 dated December 03, 2009 and Clause 5.1 of SEBI Circular No. SEBI/HO/MIRSD/DOP/P/CIR/2021/577 dated June 16, 2021 and Clause 4.1 of SEBI/HO/MIRSD/DOP/P/CIR/2022/101 dated July 27, 2022. 3.3. Section 23D of SC(R) Act, 1956 read with Clause 1 of the SEBI Circular SMD/SED/CIR/93/23321 dated November 18, 1993 and Clause 2.4.2. and Clause 2.5.3 of Annexure of SEBI Circular SEBI/HO/MIRSD/MIRSD2/CIR/P/2016/95 dated September 26, 2016. 3.4. Clause 5 & 6 of SEBI Circular CIR/DNPD/7/2011 dated August 10, 2011, Clause 4.1.2 of SEBI/HO/MIRSD/DOP/CIR/P/2019/139 dated November 19, 2019 & Clause 2.1 of SEBI/HO/MIRSD/DOP/CIR/P/2020/146 July 31, 2020. 3.5. Clause A(5) of Schedule II read with Regulation 9(f) of SEBI (Stock Brokers) Regulations, 1992 read with Question no. 15 in Annexure A to NSE circular NSE/INSP/45191 dated July 31, 2020 , NSE/INSP/49929 dated October 12, 2021 and NSE/INSP/53525 dated September 02, 2022. 3.6. Clause 1

Adjudication Order in the matter of Prabhudas Lilladher Private Limited |Page 3 of 79 3.7. Clause 6.1.1(j) of Annexure of SEBI Circular SEBI/HO/MIRSD/MIRSD2/CIR/P/2016/95 dated September 26, 2016. 3.8. Clause 3.2 of Annexure of SEBI Circular SEBI/HO/MIRSD/MIRSD2/CIR/P/2016/95 dated September 26, 2016, CIR/HO/MIRSD/MIRSD2/CIR/P/2017/64 dated June 22, 2017, CIR/HO/MIRSD/MIRSD2/CIR/PB/2017/107 dated September 25, 2017. 3.9. Clause 6.1.1(j) of Annexure to SEBI Circular SEBI/HO/MIRSD/MIRSD2 /CIR/P/2016/95 dated September 26, 2016. 3.10. Clause 6.1.1.e of Annexure of SEBI Circular SEBI/HO/MIRSD/MIRSD2/CIR/P/2016/95 dated September 26, 2016. 3.11. Clause 4.1 of SEBI circular CIR/HO/MIRSD/DOP/CIR/P/2019/75 dated June 20, 2019. 3.12. Clause 3 and 19 of SEBI circular CIR/MRD/DP/54/2017 dated June 13, 2017, SEBI/HO/MIRSD/DOP/CIR/P/2020/143 dated July 29, 2020. 3.13. Clause 18 of Annexure 4 of SEBI Circular ref no. CIR/MIRSD/16/2011 dated August 22, 2011 and SEBI Circular dated February 04, 1991 on Contract Notes and Brokerage. 3.14. Clause 6 (b) of SEBI circular CIR/HO/MIRSD/DOP/CIR/P/2019/75 read with Clause 1 of SEBI/HO/MIRSD/DOP/CIR/P/2019/95 dated August 29, 2019. In view thereof, SEBI initiated Adjudication Proceedings in respect of the Noticee under Section 15-I of SEBI Act, 1992 and under Section 23-I of the Securities Contract (Regulation) Act, 1956 (‘SCRA’) for the alleged violations of the provisions, as stated.

Adjudication Order in the matter of Prabhudas Lilladher Private Limited |Page 4 of 79 therefore, in exercise of the powers conferred under Section 19 of SEBI Act read with Section 15I (1) of the SEBI Act, and Rule 3 of SEBI (Procedure for Holding Inquiry and Imposing Penalties) Rules, 1995 (hereinafter also referred as ‘SEBI Adjudication Rules’), and under Section 23I of the Securities Contracts (Regulation) Act, 1956 (‘SCRA, 1956’) read with Rule 3 of the Securities Contracts (Regulation) (Procedure for Holding Inquiry and Imposing Penalties) Rules, 2005 (‘SCRA Adjudication Rules’), the Competent Authority appointed the undersigned as Adjudicating Officer vide order dated December 28, 2023 to inquire into and adjudge under Section 15HB and 15 F(c) of the SEBI Act, and Section 23D of the SCRA, 1956, for the alleged violations by the Noticee, as stated. The said proceedings of appointment were communicated to the undersigned vide Communique dated December 29, 2023.

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