sebi:Order/MC/RM/2022-23/23027-23069

SEBI · SEBI · Maninder Cheema, 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

Regulations

Holding

The Adjudicating Officer considered whether the 43 Noticees violated Section 12A(a),(b),(c) of the SEBI Act read with PFUTP Regulations 3(b),(c),(d) and 4(1) through self-financing of Sulabh Engineering and Services Limited's preferential allotments. The order addresses preliminary contentions on procedure and the merits of fund-flow allegations, particularly regarding the Rs.100 lakh transfer to Sona Chandi.

Full text

Adjudication Order against 43 entities in the matter of Sulabh Engineering and Services Limited Page 2 of 57 12. Naveen Kumar Kurele (PAN: AGUPK5822A) having address at R-847, First floor New Rajendra Nagar New Delhi 110060

Adjudication Order against 43 entities in the matter of Sulabh Engineering and Services Limited Page 3 of 57 26. Key Men Laminators Pvt. Ltd. (PAN: AABCK3085D) having address at 53/7 Naya Ganj Kanpur Uttar Pradesh 208001

Adjudication Order against 43 entities in the matter of Sulabh Engineering and Services Limited Page 4 of 57 41. Dilip Kumar Agarwal (PAN: ACFPA9421Q) having address at 53/7 Nayaganj Kanpur Uttar Pradesh Kanpur 208001

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Source: SecMarx — sebi:Order/MC/RM/2022-23/23027-23069. 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.