sebi:WTM/AN/IVD/ID5/31713/2025-26
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Facts / Headnote
SCN dated September 12, 2019 disposed; Noticee 1 directed to sell 1.54% excess shares and deposit entire proceeds in Investor Protection and Education Fund within 3 months; Noticees 2 to 5 debarred from accessing securities market for 3 months
Provisions invoked
- s. 11(2)
- s. 11C(3)
- s. 24
Regulations
- Reg. 7
- Reg. 6
- Reg. 44
- Reg. 199
- Reg. 10
- Reg. 10(1)
- Reg. 11(1)
- Reg. 3(4)
- Reg. 201
- Reg. 32
- Reg. 44(a)
- Reg. 44(b)
- Reg. 44(f)
- Reg. 44(c)
- Reg. 44(d)
- Reg. 44(e)
- Reg. 44(h)
Parties
- Mr. Rajiv R. Kotia (Noticee 1)
- Mrs. Shilpa Amit Kotia (Noticee 2)
- Mrs. Shweta Dhaval Kotia (Noticee 3)
- Mr. Dhaval Ramesh Kotia (Noticee 4)
- Mr. Ravi Rajiv Kotia (Noticee 5)
Holding
Mr. Rajiv Kotia shall sell shares in excess of the 15% threshold (i.e. 1.54% shares) and deposit the entire proceeds in the Investor Protection and Education Fund, while Noticees 2 to 5 are debarred from the securities market for 3 months.
Full text
Order in the matter of Sungold Capital Limited Page 2 of 17 2. Securities and Exchange Board of India (“SEBI”) passed an order dated July 07, 2020 (“WTM Order 2020”) in respect of Mr. Rajiv R. Kotia (Noticee 1), Mrs. Shilpa Amit Kotia (Noticee 2), Mrs. Shweta Dhaval Kotia (Noticee 3), Mr. Dhaval Ramesh Kotia (Noticee 4), and Mr. Ravi Rajiv Kotia (Noticee 5), as they were found to have violated regulation 10 and 11(1) of the SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 1997 (“SAST Regulations 1997”). The following directions were issued under the WTM Order 2020:
Order in the matter of Sungold Capital Limited Page 3 of 17 5. Against SAT Order 2023, Mr. Rajiv Kotia (Noticee 1) preferred an appeal before the Hon’ble SC. Hon’ble SC vide its order dated May 03, 2024 (“SC Order 2024”) restored the review application before Hon’ble SAT and held that the review filed could not have been dismissed only on the ground that the case of Sunil Krishna Khaitan (supra) was not placed before Hon’ble SAT at the relevant time. Pursuant to the SC Order 2024, the review application was placed before Hon’ble SAT, which vide its order dated April 29, 2025 (“SAT Order 2025”) held that:
Order in the matter of Sungold Capital Limited Page 4 of 17 6.1 Common submissions of Noticees 1 to 5 filed vide separate replies dated July 08, 2025:
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Source: SecMarx — sebi:WTM/AN/IVD/ID5/31713/2025-26. 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.