sebi:WTM/SM/IVD/ID13/24252/2022-23
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Facts / Headnote
Held Noticee Nos. 6 and 7 liable for insider trading in Aptech Limited in violation of Section 12A(d) and (e) of SEBI Act, 1992 read with Regulations 3(1) and 4(1) of PIT Regulations, 2015; imposed debarment/restraint, disgorgement of wrongful notional gains and penalty under Section 15G.
Provisions invoked
- s. 11B
- s. 11
- s. 19
- s. 12A
- s. 12
- s. 15G
- s. 15J
- s. 15F
- s. 11(5)
- s. 11B(2)
Regulations
- Reg. 4(1)
- Reg. 3
- Reg. 4
- Reg. 2
- Reg. 2(1)(l)
- Reg. 3(1)
- Reg. 2(1)(d)(i)
- Reg. 2(1)
- Reg. 2(1)(g)
- Reg. 2(1)(n)
- Reg. 2(1)(f)
Parties
- Lashit Sanghvi
- Neha Sanghvi
Holding
The information about Aptech's foray into pre-school segment via alliance with Montana was UPSI from March 14, 2016 to September 07, 2016, and Noticee No. 6 as insider traded while in possession of/access to it and communicated it to Noticee No. 7 who also traded, violating insider trading prohibitions.
Full text
Order in the matter of Aptech Limited Page 2 of 34 (hereinafter referred to as "Aptech" or the “Company”), for the period of March 14, 2016 to September 07, 2016 (hereinafter referred to as the “investigation period”). The said investigation was undertaken by SEBI so as to ascertain as to whether certain entities have traded in the scrip of the Company on the basis of unpublished price sensitive information hereinafter referred to as the “UPSI”), in contravention of the provisions of the Securities and Exchange Board of India Act, 1992 (hereinafter referred to as the “SEBI Act, 1992”) and Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 (hereinafter referred to as the “PIT Regulations, 2015”).
Order in the matter of Aptech Limited Page 3 of 34 franchise management in all kinds of education products, educational consultancy, human resource consultancy, management consultancy, placement services, public relation exercise, language courses and software consultancy including providing educational infrastructure, buy, provide, sell any items required by students, teachers, schools, institutes, centres, educational software and technology solutions, educational CD ROMs, publish books, magazines, notes, content, and other material in typed, cyclostyled, video, audio, web-based, internet or any other forms/medias and to hold seminars, courses, exhibitions, training programs and business conferences, to build e-commerce platforms/aggregation models for e-commerce/m-commerce/e-learning/multimedia/other technologies for education/education services/allied services and any other product or service and to work with NGOs, National Skill Development Corporation, Ministry of Human Resource Development, Government of India, Ministry of Skills Development and other Central and State government agencies for various skill and training programs and projects across the country in connection with the above objects by all means and methods in any medium now known or hereafter developed.”
Order in the matter of Aptech Limited Page 4 of 34 Table no. 1: Trade details of Mr. Lashit Sanghvi Date BSE NSE Buy Qty. Wt. Avg. Buy Price (in INR) Sell Qty. Wt. Avg. Sell Price (in INR) Buy Qty. Wt. Avg. Buy Price (in INR) Sell Qty. Wt. Avg. Sell Price (in INR) 19/08/2016 - - - - 50000 114.31 - - 07/09/2016 25000 157.56 - - 75000 155.54 - - Total 25000 157.56 - - 125000 139.05 - -
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Source: SecMarx — sebi:WTM/SM/IVD/ID13/24252/2022-23. 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.