sebi:WTM/AS/IVD-3/ID14/31131/2024-25
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Facts / Headnote
Prima facie finding of front-running; impoundment of Rs. 4,82,63,670 jointly and severally, direction to deposit in interest-bearing escrow with lien in favour of SEBI, freeze on debits in bank/demat accounts, restraint from disposing assets, direction to file asset inventory, cease and desist order, and show-cause notice requiring reply within 21 days with opportunity of personal hearing.
Provisions invoked
- s. 19
- s. 12A
- s. 15H
Regulations
- Reg. 4
- Reg. 3
- Reg. 2(1)(c)
- Reg. 8(2)
- Reg. 3(a)
Parties
- Mr. Ashish Kirti Kothari
- Mr. Amit Kirti Kothari
- Ms. Neha Ashish Kothari
- Ms. Hetal Amit Kothari
- Ashish Kirti Kothari HUF
- Mr. Krishna Tukaram Kadam
- Mr. Nirav Mahendra Sapani
- Ms. Jugmi Nirav Sapani
Holding
SEBI prima facie held Noticees 1-5 front-ran trades of Gagandeep Consultancy Private Limited using MNPI communicated by dealer Nirav Mahendra Sapani, with Kadam and Jugmi Sapani facilitating/receiving gains, and issued interim impoundment, freeze, cease-and-desist directions cum show-cause notice.
Full text
Interim Order cum SCN in the matter of Front Running by Ashish Kirti Kothari and Others Page 2 of 40 CONTENTS A. BACKGROUND ...................................................................................................... 3 B. FACTS UNEARTHED DURING INVESTIGATION ................................................. 3
Interim Order cum SCN in the matter of Front Running by Ashish Kirti Kothari and Others Page 3 of 40 A. BACKGROUND 1. Securities and Exchange Board of India (hereinafter referred to as “SEBI”) conducted an investigation in respect of the alleged front running of the trades of an entity named Gagandeep Consultancy Private Limited (hereinafter referred to as the “Big Client/ BC/ Gagandeep”) by certain entities. The focus of investigation was to ascertain the violation of provisions of the SEBI (Prohibition of Fraudulent and Unfair Trade Practices Relating to Securities Market) Regulations, 2003 (hereinafter referred as “PFUTP Regulations”) and Securities and Exchange Board of India Act, 1992 (hereinafter referred as “SEBI Act”) by the Noticees. The period of investigation was from September 1, 2018 to September 30, 2023 (hereinafter referred as “Investigation Period/ IP”).
Interim Order cum SCN in the matter of Front Running by Ashish Kirti Kothari and Others Page 4 of 40 of the Big Client were placed by Mr. Anuj and Mr. Thakore. The said trades were placed through following dealers of Anvil: Table No.1 – Details of dealers TM Code Trading Member Mode of Order placement In case of CTCL orders Dealer Name Dealer PAN 10468 Anvil Share & Stock Broking Pvt. Ltd. CTCL Mr. Nirav Mahendra Sapani AAQPS8479K Mr. Ketan Gangji Gala AACPG2487P Mr. Himanshu Mahendra Gandhi AEQPG3540K Mr. Vinay Prabhulal Trivedi ABDPT8068M Mr. Ravi Motiram Advani AEPPA3528L Mr. Jitendra Kanji Masani AJXPM5484G
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Source: SecMarx — sebi:WTM/AS/IVD-3/ID14/31131/2024-25. 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.