sebi:Order/JS/VC/2025-26/32227

SEBI · SEBI · 2025-04-03 · Jai Sebastian, Adjudicating Officer

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Facts / Headnote

Violation of PFUTP Regulations held established against Noticee for non-genuine reversal trades

Provisions invoked

• s. 11B
• s. 11
• s. 15
• s. 15H
• s. 15J
• s. 28A

Regulations

• Reg. 4
• Reg. 3
• Reg. 2(1)(c)
• Reg. 4(1)
• Reg. 3(a)
• Reg. 26

Parties

• Anju Agarwal

Holding

The Noticee violated regulations 3(a), (b), (c), (d), 4(1) and 4(2)(a) of the PFUTP Regulations by executing non-genuine reversal trades in illiquid stock options on BSE that created false appearance of trading through artificial volume.

Full text

Adjudication Order in respect of Anju Agarwal in the matter of dealings in Illiquid Stock Options on BSE Page 2 of 21 3. During the IP, 14,720 entities were found to have executed non-genuine trades in BSE’s stock options segment. It was observed that Anju Agarwal (hereinafter referred to as the “Noticee”) was one of the entities who indulged in execution of reversal trades in stock options segment of BSE during the IP. Her trades were alleged to be non-genuine in nature which created false or misleading appearance of trading in terms of artificial volumes in stock options. Therefore, her trades were alleged to be manipulative and deceptive in nature. In view of the same, SEBI initiated adjudication proceedings against the Noticee for alleged violation of the provisions of regulations 3(a), (b), (c), (d), 4(1) and 4(2)(a) of SEBI (Prohibition of Fraudulent and Unfair Trade Practices) Regulations, 2003 (hereinafter referred to as “PFUTP Regulations”).

Adjudication Order in respect of Anju Agarwal in the matter of dealings in Illiquid Stock Options on BSE Page 3 of 21 options contract, in which she allegedly executed reversal trade during the IP, is as follows: Table No. 1

Adjudication Order in respect of Anju Agarwal in the matter of dealings in Illiquid Stock Options on BSE Page 4 of 21 (a) SEBI conducted the purported investigation in the stock options segment on BSE for the investigation period, i.e., from April 1, 2014 to September 30, 2015 and the SCN was issued on November 8, 2021, i.e., after more than 6 years from the date of the impugned transaction of the Noticee, which took place on March 30, 2015. (b) Rules does not provide any period of limitation within which the proceedings should be initiated. In the absence of any period of limitation prescribed in the Rules, Article 137 of the Schedule to the Limitation Act, 1963 is applicable which provides for the general period of limitation of three years. For the purpose of issuing a SCN under the aforesaid rule 4, the Article 137 applies and therefore, the Adjudicating Officer must issue SCN within a period of three years from the date of relevant transaction. (c) In the present case, the alleged transaction was undertaken on March 30, 2015 whereas the SCN was issued on November 8, 2021, i.e., after a lapse of a period of 6 years. Thus, the impugned SCN was issued beyond the statutory period of limitation of three years as prescribed in the Limitation Act, 1963. Therefore, the impugned SCN is bad in law and is void ab initio. (d) SEBI purportedly issued the impugned SCN in the present case without any direct evidence against the Noticee without allowing any cross-examination of trading

Source: SecMarx — sebi:Order/JS/VC/2025-26/32227. 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.