sebi:Order/AP/SK/2021-22/12250-12252
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Facts / Headnote
Penalty imposed on all three Noticees
Provisions invoked
- s. 11
- s. 15A
- s. 15
- s. 11(1)
- s. 12
- s. 11(2)
- s. 15I
- s. 15J
- s. 11C
- s. 11C(3)
- s. 28A
Parties
- Pramod Jain (Noticee No. 1)
- Rahul Malik (Noticee No. 2)
- Rochak Midha (Noticee No. 3)
Holding
The Noticees, as Directors/COO of IKM Investors Private Limited, violated Section 11C(2) and Section 11C(3) read with Section 11(2)(i) of the SEBI Act by failing to provide their mobile phones for data imaging during SEBI's investigation, and a monetary penalty of ₹1,00,000 each was imposed under Section 15A(a) of the SEBI Act.
Full text
______________________________________________________________________________________ Adjudication Order in respect of three entities in the matter of IKM Investors Private Limited Page 2 of 13
______________________________________________________________________________________ Adjudication Order in respect of three entities in the matter of IKM Investors Private Limited Page 3 of 13 production of such books, or registers, or other documents, or record is relevant or necessary for the purposes of its investigation.
______________________________________________________________________________________ Adjudication Order in respect of three entities in the matter of IKM Investors Private Limited Page 4 of 13 a) The period for investigation was from 2010 to 2014. In the instant matter, the Learned Investigating Authority (“IA”) had instructed Noticee No. 2 vide summons dated May 09, 2019 to provide several documents and/or access to several documents/information to the IA/Forensic Auditor and for personal appearance before IA. It may be seen that in the summons, there is no mention, whatsoever, of even production of mobile phones, let alone any instruction or advice for its imaging by a third party.
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Source: SecMarx — sebi:Order/AP/SK/2021-22/12250-12252. 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.