sebi:Order/PB/AE/2022-23/16332-16344

SEBI · SEBI · 2021-08-18 · Parag Basu, Adjudicating Officer

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Facts / Headnote

Violations of Regulations 3(a),(b),(c),(d), 4(1), 4(2)(a) and (e) of PFUTP Regulations held established against the Noticees; monetary penalty under Section 15HA imposed, with no penalty imposed on Noticee 7 and Noticee 12.

Provisions invoked

• s. 11B
• s. 15
• s. 19
• s. 11(1)
• s. 12A
• s. 11
• s. 15H
• s. 15J
• s. 28A

Regulations

• Reg. 4
• Reg. 3
• Reg. 200
• Reg. 3(a)
• Reg. 3a

Holding

The Adjudicating Officer held that the connected Noticees violated Regulations 3(a)-(d), 4(1), 4(2)(a) and (e) of the PFUTP Regulations by repeatedly placing buy orders subsequent to sell orders at prices higher than available sell prices for lower quantities to inflate the price of Shantanu Sheorey Aquakult Limited, and imposed monetary penalty under Section 15HA, except for Noticee 7 and Noticee 12 on whom no penalty was imposed.

Full text

Adjudication Order in the matter of Shantanu Sheorey Aquakult Limited Page 2 of 69 the trading activity in the scrip of SSAL. On the basis of investigation conducted by SEBI, it was inter-alia alleged that 21 entities, which comprised the 13 Noticees and 8 other entities viz. ASBN Commodities & Fineserve Pvt. Ltd., Abjayoni Trading Pvt. Ltd., Black Horse Media and Entertainment Pvt. Ltd., Haritima Infrastructure Pvt. Ltd., Jeshna Muiltitrade Pvt. Ltd., Meritorious Realty Pvt. Ltd., Vihar Infrastructure Pvt. Ltd. and Whitetext Infrastructure Pvt. Ltd., have violated the provisions of regulations 3(a), (b), (c), (d) and 4(1), 4(2)(a) and (e) of SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003 (hereinafter referred to as “PFUTP Regulations”).

Adjudication Order in the matter of Shantanu Sheorey Aquakult Limited Page 3 of 69 Regulations by the Noticees. Pursuant to the transfer of Shri K Saravanan, the undersigned was appointed as the AO in the matter vide Communiqué dated July 14, 2021.

Adjudication Order in the matter of Shantanu Sheorey Aquakult Limited Page 4 of 69 iv. During the investigation period, share price of SSAL opened at Rs. 4.95 (March 03, 2014), touched a high of Rs. 261 (May 26, 2016) and closed at Rs. 260.5 (May 31, 2016). It has been observed that the scrip price increased continuously during the investigation period. Further, 79,55,079 shares were traded through 8274 trades. v. Following inter-se relationship is alleged among the 21 entities – Table - 2 Sr. No Connected Entities name Directors Name Connection Details 1 Orange Mist Productions Pvt. Ltd. Kumar Raichand Madan, Athistamani Velu, Sadashiv Pawar Entities at Sr. No. 1, 2, 3, 4, 5 are connected to each other through common director i.e. Kumar Raichand Madan. Connection through Fund transfers: Fund transaction between Orange Mist (Corporation bank, acc no: 146901601000344) and Tushar P Jadhav (acc no: 146900101002398, Corporation Bank). Fund transaction between Adamina Traders (Axis Bank acc. No. : 914020029287819) and Matulya Traders (Acc no: 146901601000200, Corporation Bank), Tushar P Jadhav (acc no: 146900101002398, Corporation Bank). 2 Magan Mercantile Pvt. Ltd. Prakash R Naik, Ranjankumar R Rajbhar, Kumar Raichand Madan, Sumit V Salvi 3 Roho Real Estate Private Limited Kumar Raichand Madan, Paresh B Gharat, Prashant S Indlkar 0 50000 100000 150000 200000 250000 300000 350000 400000 0 50 100 150 200 250 300 No.of Shares Close Price

Source: SecMarx — sebi:Order/PB/AE/2022-23/16332-16344. 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.