sebi:RA/JP/310-319/2018
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Facts / Headnote
Noticee Nos. 1-6 and 10 held to have violated SAST and PIT disclosure provisions and held liable for penalty under Section 15A(b) of the SEBI Act, with Noticee No.5 additionally held liable under Section 15HB for code of conduct violations; no liability fastened on Noticee Nos. 6-9 for failure to supervise/implement code beyond allegation levelled.
Provisions invoked
- s. 15A
- s. 15
- s. 15H
- s. 15J
- s. 12
- s. 4A
Regulations
- Reg. 13(4)
- Reg. 13
- Reg. 12(1)
- Reg. 199
- Reg. 13(1)
- Reg. 7
- Reg. 13(3)
- Reg. 8
- Reg. 29(1)
- Reg. 29
- Reg. 13(6)
- Reg. 7(1)
- Reg. 31
- Reg. 13(5)
- Reg. 29(2)
- Reg. 29(3)
- Reg. 201
- Reg. 31(1)
- Reg. 35
- Reg. 8A
Parties
- Ms. Chetana Kothari (Noticee No.1)
- Dinesh Patadia Financial and Investment Pvt. Ltd. (Noticee No.4)
- Tricom Fruit Products Ltd. (Noticee No.6)
- P. V. Naik (Noticee No.7)
- Ms. Riddhi Sanghvi (Noticee No.8)
- Ms. Neha Sarvaiya (Noticee No.9)
- Twin Best Trading & Marketing Private Limited (Noticee No.10)
Holding
Noticee Nos. 1-6 and 10 failed to make / made belated disclosures regarding pledge creation/invocation/release and sale/purchase of shares in Tricom and are liable for penalty under Section 15A(b), and Noticee No.5 additionally violated the internal code of conduct and is liable under Section 15HB.
Full text
Page 2 of 54 P. V. Naik (the Noticee No. 7), Ms. Riddhi Sanghvi (the Noticee No. 8), Ms. Neha Sarvaiya (the Noticee No. 9) and Twin Best Trading & Marketing Private Limited (the Noticee No. 10) or all the aforesaid Noticee may be collectively referred as ('the Noticees') have failed to make disclosures regarding creation / invocation / release of certain pledge transactions, sale/purchase of shares in the Tricom / Company and failed to follow certain code of conduct internal procedure of the Company; and thereby allegedly violated regulation 29(1) & 29(2) read with 29(3), regulation 31(1), 31(2) read with 31(3) of SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 2011, regulation 8A (2) of the SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 1997 (hereinafter referred to as ‘SAST Regulations’) and regulation 13 (1), 13(3), 13(4), 13(4A) read with 13(5), regulation 13 (6) and Clause 1.2, Clause 3.3-1 & clause 4.2 of code of conduct specified under Schedule-I of Part A read with regulation 12(1) & 12(3) of the SEBI (Prohibition of Insider Trading) Regulations, 1992 (hereinafter referred to as ‘PIT Regulations’).
Page 3 of 54 the Noticees under rule 4(1) of the Adjudication Rules to show cause as to why an inquiry should not be held and penalty be not imposed upon them under sections 15 A (b) and 15 HB of the SEBI Act for the alleged violations.
Page 4 of 54 indulgence of opposite transaction and non-seeking of pre-clearance by the Noticee No. 5. 8. It was alleged that the Noticee No. 10 had failed to make disclosures / made belated disclosures regarding change of its shareholding.
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Source: SecMarx — sebi:RA/JP/310-319/2018. 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.