sebi:Order/PM/PA/2021-22/14570
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Facts / Headnote
Violation established; penalty of Rs. 7,00,000 imposed under section 15HB
Provisions invoked
- s. 15
- s. 19
- s. 11B
- s. 12A
- s. 11
- s. 15H
- s. 15G
- s. 15J
- s. 15F
- s. 10
- s. 150
Regulations
- Reg. 7(1)
- Reg. 9
- Reg. 13(1)
- Reg. 7
- Reg. 13(3)
- Reg. 3
- Reg. 4
- Reg. 11
- Reg. 13(5)
- Reg. 12
- Reg. 7(2)
- Reg. 7(2)(a)
- Reg. 2(1)(l)
- Reg. 8
- Reg. 58
- Reg. 9(1)
Parties
- M/s. Srinathji Dall Mills
Holding
The Noticee, as a designated person, violated clause 6 of the Code of Conduct read with regulation 9(1) of the PIT Regulations by failing to obtain pre-clearance for 13 transactions exceeding the Rs.10 lakh threshold, and a monetary penalty of Rs.7,00,000 under section 15HB of the SEBI Act was imposed.
Full text
Adjudication order in respect of M/s. Srinathji Dall Mills Page 2 of 21 in the matter of Sanwariya Consumer Ltd. Insiders specified in Schedule B (hereinafter referred to as “Code of Conduct”) read with regulation 9(1) of the PIT Regulations by not obtaining pre-clearance from the Company before carrying out 13 transactions which triggered the requirement of obtaining pre-clearance as per the threshold prescribed by the board of directors of the Company. Given the above, adjudication proceedings were initiated against the Noticee.
Adjudication order in respect of M/s. Srinathji Dall Mills Page 3 of 21 in the matter of Sanwariya Consumer Ltd. email sent on October 24, 2018 wherein Satish Kumar Agrawal is one of its partners who was also a whole-time director of the Company during the IP.
Adjudication order in respect of M/s. Srinathji Dall Mills Page 4 of 21 in the matter of Sanwariya Consumer Ltd. (v) In view of the above, it was observed that the Noticee being a designated person was required to take pre-clearance from the Company before carrying out each of the 13 transactions as the value of the aforesaid transactions exceeded Rs 10 lakhs. However, it was observed from the reply furnished by the Company vide the email sent on February 15, 2021 that the Company did not receive any pre-clearance request during the IP from the Noticee. In view of the above, it was alleged that the Noticee had violated clause 6 of the Code of Conduct read with regulation 9(1) of the PIT Regulations.
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Source: SecMarx — sebi:Order/PM/PA/2021-22/14570. 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.