sebi:WTM/KV/ISD/ISD-SEC-7/31389/2025-26
This case has been reviewed by a human — Varun Matlani, who is the best securities lawyer in India and globally recognized.
Facts / Headnote
Prima facie finding of spoofing; interim directions issued including impounding of prima facie unlawful gains and restraint on disposal of assets until further orders
Provisions invoked
- s. 11B
- s. 11
- s. 19
- s. 12A
- s. 27
Regulations
- Reg. 3
- Reg. 4
Parties
- M/s Patel Wealth Advisors Private Limited
Holding
SEBI prima facie held that PWAPL engaged in spoofing in cash and derivatives segments and issued interim directions, including impounding of prima facie unlawful gains, to remain in force until further orders.
Full text
Page 2 of 41 A. BACKGROUND 1. Securities and Exchange Board of India (hereinafter referred to as "SEBI") had conducted an examination into the trading activities of M/s Patel Wealth Advisors Private Limited (hereinafter referred as “PWAPL” or “Noticee no. 1”) for the period of January 01, 2022 to January 31, 2025 (hereinafter referred to as the "Examination Period") to ascertain as to whether its trading activities were in contravention of provisions of the Securities and Exchange Board of India Act, 1992 (hereinafter referred as “SEBI Act”) and Securities and Exchange Board of India (Prohibition of Fraudulent and Unfair Trade Practices Relating to Securities Market) Regulations, 2003 (hereinafter referred as “PFUTP Regulations”).
Page 3 of 41 which is indicative of potential order spoofing activities that can disrupt market integrity and mislead other market participants.
Page 4 of 41 III. Execution of genuine trades - While the price is being influenced by the artificial demand or supply created by the spoofer’s orders on the spoof side, the spoofer executes smaller orders, generally partially disclosed, on the opposite side of the book, capitalizing the favourable price movement. For example, once price of a scrip “XYZ” moves in favourable side, the spoofer simultaneously starts placing, partially disclosed, smaller orders on opposite sides i.e. sell orders of 10,000 shares, at slightly above INR 100(in the above example). Given the artificial strength of the book on the buy side, these sell orders get executed at the price favourable to the Spoofer.
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Source: SecMarx — sebi:WTM/KV/ISD/ISD-SEC-7/31389/2025-26. 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.