sebi:Order/JS/VC/2025-26/31828

SEBI · SEBI · 2025-09-02 · Jai Sebastian, Adjudicating Officer

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Facts / Headnote

Penalty imposed on the Noticee for violations of regulation 22(1)(c) of FPI Regulations and clauses of the Master Circular; Noticee directed to pay within 45 days

Provisions invoked

Regulations

Parties

Holding

The Noticee was found to have violated regulation 22(1)(c) of the FPI Regulations read with clause 14(i) of Part A of the Master Circular by intimating the addition of new share Class III with a delay of 82 days, and clause 12(i) of Part A of the Master Circular by making additional investments worth ₹20.02 crore without prior intimation of the BO of new share Class III, and a monetary penalty was imposed under section 15HB of the SEBI Act.

Full text

Adjudication Order in the matter of Samena Special Situations Mauritius Page 2 of 25 SHOW CAUSE NOTICE, REPLY AND HEARING

Adjudication Order in the matter of Samena Special Situations Mauritius Page 3 of 25 Table-1: Summary showing the type of material changes intimated to SEBI Name of FPI Effective Date of Change Summary of Changes Date of intimation by the FPI to DDP No of earlier delays in Intimation Samena Special Situations Mauritius (INMUFP080816) December 13, 2023 Addition of one Share Class (III) March 05, 2024 1

Adjudication Order in the matter of Samena Special Situations Mauritius Page 4 of 25 (l) The DDP, inter alia, confirmed vide email dated February 19, 2025 that the trades executed by Noticee between December 13, 2023 to March 05, 2024 were through the newly added share class (participating shares – Class III).

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Source: SecMarx — sebi:Order/JS/VC/2025-26/31828. 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.