Sanjay Jethalal Soni
Penalties and directions recorded
- Matters listed on 11 August 2023
- Penalties of Rs. 6 lakhs each were reduced to Rs. 3 lakhs each.
- All appellants were directed to deposit the penalty with SEBI.
- SEBI AO directions imposing penalties ranging from Rs.5 lakhs to Rs.30 lakhs on the respective appellants were upheld.
- SEBI AO directions imposing penalties ranging from Rs.5 lakh to Rs.30 lakh on the respective appellants were upheld.
SAT-appeal
- SAT matter SATV-03F3F5748B755C91DA9EB98AAppellants granted three weeks to file rejoinder · Matters listed on 11 August 2023Appeal: Appeal Nos. 342 to 347 of 2023; procedural order dated 23 June 2023 granting time for rejoinder and listing matters on 11 August 2023
- The appellants, acting in concert, allegedly acquired 11.36% of the paid-up equity capital of Parichay Investments Limited, triggering disclosure obligations under Regulation 7 of the SAST Regulations, 1997 and Regulation 13 of the PIT Regulations, 1992.Appeal No. 92 of 2019 was dismissed. · Appeal Nos. 119, 120 and 121 of 2019 were partly allowed.Appeal: Appeal Nos. 92, 119, 120 and 121 of 2019 decided on 3 May 2019; Appeal No. 92 dismissed and Appeals Nos. 119, 120 and 121 partly allowed. Delay of 92 days condoned.
- Alleged fraudulent and unfair trade practices through connected reversal, matched and self-trades, volume manipulation, price manipulation and contribution to positive LTP in Ushdev International Ltd.All appeals were dismissed. · SEBI AO directions imposing penalties ranging from Rs.5 lakhs to Rs.30 lakhs on the respective appellants were upheld.Appeal: Appeal Nos.265, 267, 270, 271, 272, 273, 274, 275 and 276 of 2019 dismissed by SAT on 8 June 2021.
- Connected noticees allegedly engaged in reversal, matched and self-trades, price and volume manipulation, and contributed to the positive Last Traded Price in Ushdev International Ltd.All appeals were dismissed. · SEBI AO directions imposing penalties ranging from Rs.5 lakh to Rs.30 lakh on the respective appellants were upheld.Appeal: Appeal Nos.265, 267, 270, 271, 272, 273, 274, 275 and 276 of 2019 dismissed by SAT on 8 June 2021.
- SAT matter SATV-14F51BA43697945DB5FFC298SEBI to file objection/reply to Misc. Application No. 72 of 2021 within two weeks from 22 February 2021 · Appellant to file rejoinder, if any, within two weeks thereafterAppeal: Multiple connected appeals, including Appeal Nos. 265 and 267-276 of 2019, remained pending; Misc. Application No. 72 of 2021 sought additional evidence and was listed for orders on 19 March 2021.
- The appellants, allegedly acting in concert, cumulatively acquired 11.36% of Parichay Investments Limited and failed to comply with disclosure obligations under Regulation 7 of the SAST Regulations, 1997 and Regulation 13 of the PIT Regulations, 1992.Appeal No. 92 of 2019 was dismissed and the Rs. 3 lakh penalty on Shweta Dhiren Agrawal was upheld. · Appeal Nos. 119, 120 and 121 of 2019 were partly allowed.Appeal: Appeal Nos. 92, 119, 120 and 121 of 2019 decided by SAT on 3 May 2019; Appeal 92 dismissed and Appeals 119, 120 and 121 partly allowed.
- SAT matter SATV-1D7089F53FF0571B168A6D72Respondent to file objection/reply to Misc. Application No. 72 of 2021 within two weeks from 22 February 2021 · Appellant to file rejoinder, if any, within two weeks thereafterAppeal: Appeal Nos. 265 and 267-276 of 2019 were pending; Misc. Application No. 72 of 2021 in Appeal No. 265 of 2019 was directed to be replied to and listed for orders on 19 March 2021.
- Alleged fraudulent and unfair trading through reversal, matched and self-trades, price and volume manipulation, and contribution to positive Last Traded Price in Ushdev International Ltd.All appeals were dismissed. · The Adjudicating Officer’s penalties ranging from Rs.5 lakh to Rs.30 lakh per appellant were upheld.Appeal: Appeal Nos.265, 267, 270, 271, 272, 273, 274, 275 and 276 of 2019 dismissed on 8 June 2021; 17 of 18 noticees appealed.
- The appellants were alleged to have acted as a group and executed manipulative matched trades and self-trades in Shree Global Tradefin Ltd., involving fraud and unfair trade practices.Show cause notice dated 20 July 2017 quashed · AO penalty order dated 25 October 2018 quashedAppeal: Appeal Nos. 102, 122, 193, 268 and 269 of 2019 decided together and allowed on 14 November 2019.
- The appellants allegedly acted in concert and acquired more than 15% of Oregon Commercial Limited's share capital without making the required public announcement under Regulation 10 of the Takeover Regulations, 1997.Appeal No. 758 of 2021 dismissed without any order as to costs · SEBI direction to make a public announcement to acquire Oregon Commercial Limited shares upheldAppeal: Appeal No. 758 of 2021 dismissed by SAT on March 21, 2022
- Appeals arose from an impugned order concerning alleged violations of the SEBI PFUTP Regulations in trading the scrip during the investigation period.Miscellaneous Application No. 72 of 2021 for additional evidence was allowed · Appellant to deposit costs of Rs. 20,000 with the RegistrarAppeal: Appeal Nos. 267, 270, 271, 272, 273, 274, 275, 276 and 265 of 2019 were pending; final disposal was listed for 26 April 2021
- SAT matter SATV-33B9BF4F01E1074C4D8AA0F2Impugned SEBI Adjudicating Officer order dated 16 November 2018 quashed · SEBI granted liberty to issue a fresh show-cause noticeAppeal: Appeal Nos. 123, 170, 174, 185, 186, 189, 190, 191 and 192 of 2019 disposed on 7 November 2019; impugned order quashed
- Failure to furnish information and documents sought by SEBI's investigating authority through summons, including information concerning SMS circulation and trading in Timbor Home Limited.Appeal dismissed · Adjudicating Officer's penalty order upheldAppeal: Appeal No. 263 of 2019 dismissed by SAT on 22 March 2021
- Appeals arose from an impugned order concerning alleged violations of the SEBI PFUTP Regulations. The appellants disputed that their trading constituted an unfair trade practice.Miscellaneous Application No. 72 of 2021 for additional evidence was allowed. · Appellant directed to deposit costs of Rs. 20,000 with the Registrar.Appeal: Appeal Nos. 265, 267, and 270-276 of 2019 were pending; the order dated 19 March 2021 allowed additional evidence in Misc. Application No. 72 of 2021 and listed the appeals for final disposal on 26 April 2021.
- Connected entities indulged in reversal, matched and self-trades and price/volume manipulation contributing to positive LTP in Ushdev International Ltd.All appeals (Nos.265,267,270-276 of 2019) dismissed · AO penalty order imposing Rs.5 lakhs to Rs.30 lakhs upheldAppeal: Appeal Nos.265,267,270,271,272,273,274,275,276 of 2019 dismissed by SAT vide decision dated 08.06.2021 (reserved 26.04.2021)
- Connected appellants indulged in reversal, matched and self-trades with price and volume manipulation contributing to LTP in Ushdev International Ltd.All appeals dismissed · AO penalty of Rs 5 lakhs to Rs 30 lakhs upheldAppeal: Appeal Nos. 265, 267, 270, 271, 272, 273, 274, 275, 276 of 2019 dismissed on 08.06.2021 (reserved 26.04.2021)
- Alleged fraudulent and manipulative scheme involving artificial price/volume creation, unsolicited bulk SMS recommending Timbor Home Ltd. shares, and subsequent dumping of shares on induced investors.Miscellaneous Application No. 934 of 2022 allowed and documents taken on record · Appeal Nos. 45 and 46 of 2022 dismissedAppeal: Appeal Nos. 45 and 46 of 2022 dismissed by SAT on 27 September 2022 with no order as to costs.
- Alleged violation in scrip of Parichay Investments Limited adjudicated by AO; specifics not discussed as order set aside on concession.Impugned Adjudicating Officer order dated 16.11.2018 quashed without going into merits · Liberty granted to SEBI to issue fresh show cause notice if so desiredAppeal: Appeal Nos. 123, 170, 174, 185, 186, 189, 190, 191, 192 of 2019 disposed of on 07.11.2019 by quashing impugned order on SEBI concession
- Connected entities indulged in reversal, matched, self trades and price-volume manipulation contributing to positive LTP in Ushdev International Ltd.All appeals dismissed, AO penalty order confirmed with no interference on quantumAppeal: Appeal Nos. 265,267,270,271,272,273,274,275,276 of 2019 decided on 08.06.2021 (reserved 26.04.2021) - dismissed
- Appellants as group executed extensive match trades and self trades in Shree Global Tradefin Ltd in manipulative manner amounting to fraud and unfair trade practiceSecond show cause notice dated July 20, 2017 and impugned AO order quashed · All appeals (102,122,193,268,269 of 2019) allowedAppeal: Appeal Nos. 102, 122, 193, 268, 269 of 2019 allowed by SAT decision dated 14.11.2019 (reserved 05.11.2019)
- Group executed extensive matched trades and self trades in Shree Global Tradefin Ltd in manipulative manner amounting to fraud and unfair trade practice.Second show cause notice dated July 20, 2017 quashed · Impugned AO penalty order dated October 25, 2018 quashedAppeal: Appeal Nos. 102, 122, 193, 268, 269 of 2019 disposed and allowed by SAT on 14.11.2019 (reserved on 05.11.2019)
- Aiding Timbor Home promoter group in offloading shares via intermediaries acting in concert and inducing gullible investors with misleading advice.Findings in WTM order dated November 20, 2020 upheld · Matter remitted to WTM, SEBI for recalculation of disgorgement as per lawAppeal: Appeal No.47 of 2022 with Misc. Application No.1226 of 2022 allowed in part on 29 January 2026; findings upheld, remanded for disgorgement recalculation
- PACs cumulatively acquired 11.36% of Parichay Investments Ltd without disclosures triggering SAST Reg 7 and PIT Reg 13Appeal No. 92 of 2019 dismissed - Rs 3 lakh penalty upheld · Appeal Nos. 119, 120 and 121 of 2019 partly allowed - Rs 6 lakh reduced to Rs 3 lakh eachAppeal: Appeal Nos. 92, 119, 120 and 121 of 2019 decided on 03.05.2019 - No.92 dismissed, Nos.119,120,121 partly allowed
- Connected entities in concert inflated Timbor Home Ltd price via small buys, sent misleading bulk SMS buy recommendations, then dumped shares on gullible investors in violation of PFUTP Regs 3, 4.Appeal No. 45 of 2022 and Appeal No. 46 of 2022 dismissed · AO penalty of Rs.5 lacs on each noticee confirmedAppeal: Appeal Nos. 45 and 46 of 2022 against AO order dated 23.03.2021 dismissed on 27.09.2022; Misc. Application No. 934 of 2022 allowed
- Proceedings relating to scrip of Parichay Investments Limited; specific charge not detailed in SAT remand orderImpugned AO order dated 16.11.2018 quashed without going into merits · SEBI given liberty to issue fresh show cause notice if so desiredAppeal: Appeal Nos. 123,170,174,185,186,189,190,191,192 of 2019 disposed on 07.11.2019 by consent remand
- Acquisition of shares of Oregon Commercial Ltd triggering SAST 7(1)/7(2) and PIT 13 disclosure obligations which were not disclosed within prescribed time.Appeal partly allowed; Rs 5 lakhs each on three PAC members modified to single Rs 5 lakhs jointly and severally · Additional penalty of Rs 4 lakhs on Sanjay Jethalal Soni and Rs 5 lakhs on Krupa Sanjay Soni affirmedAppeal: Appeal No. 483 of 2018 partly allowed on 28.06.2019
- Failure to make public announcement in terms of Regulation 10 SAST 1997 read with Regulation 35(2) SAST 2011Dismissal of Appeal No. 44 of 2022 on ground of laches · Dismissal of Misc. Application No. 14 of 2022 for condonation of delayAppeal: Appeal No. 44 of 2022 with Misc. Application No. 14 of 2022 dismissed for delay on 04.02.2022
- Connected entities indulged in reversal, matched and self-trades and price/volume manipulation contributing to positive LTP in Ushdev International Ltd.All appeals dismissed · AO penalty of Rs.5 lakhs to Rs.30 lakhs per appellant confirmed as proportionate to repetitive violationsAppeal: Appeal Nos.265,267,270,271,272,273,274,275,276 of 2019 dismissed by SAT decision dated 08.06.2021 (reserved 26.04.2021)
- SAT matter SATV-8FF4C2B93E134B868F109254Appeal No. 40 of 2022 and Misc. Application No. 10 of 2022 dismissed on ground of laches / inordinate delay · No order as to costsAppeal: Appeal No. 40 of 2022 with Misc. Application No. 10 of 2022 filed Jan 2022 against WTM order dated 31.07.2019 dismissed on 04.02.2022 for delay
- Alleged violation of the SEBI PFUTP Regulations through trading in the concerned scrip during the investigation period, asserted by SEBI to constitute an unfair trade practice.Miscellaneous Application No. 72 of 2021 for additional evidence allowed · Appellant to deposit costs of Rs. 20,000 with the Registrar within two weeks from 19 March 2021Appeal: Appeal Nos. 265, 267, and 270-276 of 2019 were pending before SAT; Miscellaneous Application No. 72 of 2021 was allowed. Final disposal was listed for 26 April 2021.
- Alleged violation in scrip of Parichay Investments Limited; merits not examinedImpugned AO order dated 16.11.2018 quashed without going into merits · Liberty granted to SEBI to issue fresh show cause notice if so desiredAppeal: Appeal Nos. 123, 170, 174, 185, 186, 189, 190, 191 and 192 of 2019 disposed on 07.11.2019 by quashing impugned order
- SAT matter SATV-CA8B208B62F5A2A3B6569C14Three weeks time allowed to appellants in Appeal Lodging No. 413 of 2019 to file rejoinder · List Appeal Lodging No. 413 of 2019 on March 19, 2021Appeal: Appeal Lodging No. 413 of 2019 and Appeal No. 263 of 2019 pending before SAT; adjourned to March 19, 2021 and March 22, 2021 respectively, no final disposal
- SAT matter SATV-DEA3CCF94815A88C7924EB4BAllow appellants three weeks to file rejoinder in Appeal Lodging No. 413 of 2019 · Detag Appeal No. 263 of 2019 from Appeal Lodging No. 413 of 2019 and list separatelyAppeal: Appeal Lodging No. 413 of 2019 and Appeal No. 263 of 2019 pending before SAT; adjourned to 19 March 2021 and 22 March 2021
- Matter concerns scrip of Parichay Investments Limited; specific charges not examined as order was quashed without going into meritsQuashed impugned Adjudicating Officer order dated 16.11.2018 without going into merits · Granted liberty to SEBI to issue fresh show cause notice if so desiredAppeal: Appeal Nos. 123, 170, 174, 185, 186, 189, 190, 191 and 192 of 2019 disposed on 07.11.2019; impugned order quashed on SEBI concession
- Matter relates to dealings in scrip of Parichay Investments Limited; specific charges not detailed in SAT remand orderImpugned Adjudicating Officer order dated 16.11.2018 quashed without going into merits · Liberty granted to SEBI to issue fresh show cause notice if so desiredAppeal: Appeal Nos. 123, 170, 174, 185, 186, 189, 190, 191, 192 of 2019 disposed on 07.11.2019 by consent remand
- Violation of PFUTP Regulations 3(a)-3(d), 4(1), 4(2)(a) and 4(2)(g) relating to fraudulent and unfair trade practicesDismissal of Appeal No. 49 of 2022 and Misc. Application No. 19 of 2022 on ground of laches / inordinate delay · No order as to costsAppeal: Appeal No. 49 of 2022 with Misc. Application No. 19 of 2022 filed Jan 2022 against AO order 29 March 2019; dismissed as time-barred on 04.02.2022
- Creating artificial volumes and misleading appearance in Oregon Commercial Ltd scrip through matched, reversal and self trades among connected entities.Group appeals allowed; common AO order dated November 16, 2018 set aside on ground of inordinate 7-year delay in SCNAppeal: Appeal Nos. 169,171,172,231,264,266,277,278,279,280,281 of 2019 reserved 23.01.2020 decided 31.01.2020 - allowed due to delay
- Proceedings relating to trading in scrip of Parichay Investments Limited; specific charge not detailed in remand orderImpugned Adjudicating Officer order dated 16.11.2018 quashed without going into merits · Liberty to SEBI to issue fresh show cause notice if so desiredAppeal: Appeal Nos. 123,170,174,185,186,189,190,191,192 of 2019 disposed on 07.11.2019 by consent quashing and remand
- Group executed matched trades and self trades in Shree Global Tradefin Ltd in manipulative manner amounting to fraud and unfair trade practice.Show cause notice dated July 20, 2017 and impugned AO order quashed · All appeals (Nos. 102, 122, 193, 268, 269 of 2019) allowedAppeal: Appeal Nos. 102, 122, 193, 268, 269 of 2019 allowed by SAT on 14.11.2019 (reserved on 05.11.2019)
- Creating artificial volumes and misleading appearance in Oregon Commercial Ltd scrip through matched, reversal and self trades among connected entities.Appeal: Appeal Nos. 169, 171, 172, 231, 264, 266, 277, 278, 279, 280, 281 of 2019 before SAT; Order Reserved on 23.01.2020, Date of Decision 31.01.2020
- Connected entities indulged in reversal, matched and self-trades with price and volume manipulation contributing to positive LTP in Ushdev International Ltd.All nine appeals dismissed · AO penalty order for PFUTP violations confirmed with no interference on quantumAppeal: Appeal Nos.265,267,270,271,272,273,274,275,276 of 2019 decided on 08.06.2021 (reserved 26.04.2021); all dismissed
- Alleged violation in scrip of Parichay Investments Limited leading to AO order dated 16.11.2018; merits not discussed due to remandImpugned AO order dated November 16, 2018 quashed without going into merits · Liberty to SEBI to issue fresh show cause notice if so desiredAppeal: Appeal Nos. 123, 170, 174, 185, 186, 189, 190, 191, 192 of 2019 disposed on 07.11.2019 - impugned order quashed and remanded for fresh SCN
- Creating artificial volumes and misleading appearance in Oregon Commercial Ltd scrip through matched, reversal and self trades.
- PACs together acquired 11.36% of Parichay Investments Ltd triggering Reg 7 SAST 1997 and Reg 13 PIT 1992 disclosures, which were not made.Misc Applications 175-177/2019 allowed; 92 days delay in filing appeals condoned · Appeal No. 92/2019 (Shweta Dhiren Agrawal) dismissed; Rs 3 lakh penalty upheldAppeal: Appeal Nos. 92, 119, 120 and 121 of 2019 decided on 03.05.2019: Appeal 92 dismissed; others partly allowed with penalty reduced
- Creating artificial volumes and misleading appearance in Oregon Commercial Ltd scrip through matched, reversal and self trades in violation of PFUTP norms.Common AO order dated 16.11.2018 under challenge; Tribunal held 7-year delay vitiates penalties and set aside/quashed AO penaltiesAppeal: Appeal Nos. 169,171,172,231,264,266,277,278,279,280,281 of 2019 reserved 23.01.2020 decided 31.01.2020 by common order
- Failure to make public announcement in terms of Regulation 10 and Regulation 11(1) SAST Regulations 1997Appeal No. 51 of 2022 and Misc. Application No. 9 of 2022 dismissed on ground of laches · No order as to costsAppeal: Appeal No. 51 of 2022 with Misc. Application No. 9 of 2022 filed Jan 2022 against AO order dated 24.10.2019 dismissed as time-barred on 04.02.2022
- Created artificial volumes and misleading appearance in Oregon Commercial Ltd scrip by trading among themselves through matched, reversal and self trades.Group appeals challenge AO common order dated November 16, 2018; Tribunal examines 7-year delay in SCN (operative part truncated in excerpt)Appeal: Appeal Nos. 169,171,172,231,264,266,277,278,279,280,281 of 2019, Order Reserved 23.01.2020, Date of Decision 31.01.2020
- Connected noticees indulged in reversal, matched and self-trades and price/volume manipulation contributing to positive LTP in Ushdev International Ltd.All appeals dismissed · AO penalty of Rs.5 lakhs to Rs.30 lakhs confirmed with no interference on quantumAppeal: Appeal Nos.265,267,270,271,272,273,274,275,276 of 2019 dismissed by SAT decision dated 08.06.2021 (reserved 26.04.2021)
- Alleged violation in scrip of Parichay Investments Limited; merits not examinedImpugned AO order dated 16.11.2018 quashed without going into merits · Liberty to SEBI to issue fresh show cause notice if so desiredAppeal: Appeal Nos. 123, 170, 174, 185, 186, 189, 190, 191, 192 of 2019 disposed on 07.11.2019 by consent quashing
- Creating artificial volumes and misleading appearance in Oregon Commercial Ltd scrip via matched, reversal and self trades.Appeal: Group Appeals 169,171,172,231,264,266,277-281 of 2019 reserved 23.01.2020 decided 31.01.2020 challenging AO order
- Alleged creation of artificial volumes and misleading appearance in Oregon Commercial Ltd scrip via matched, reversal and self trades.Common AO order dated November 16, 2018 set aside and penalties quashed on ground of inordinate delayAppeal: Appeal Nos. 169, 171, 172, 231, 264, 266, 277, 278, 279, 280, 281 of 2019 reserved on 23.01.2020, decided on 31.01.2020
- Created artificial volumes and misleading appearance in Oregon Commercial Ltd scrip by trading among themselves through matched, reversal and self trades.Appeals allowed and AO common order dated November 16, 2018 set aside on ground of inordinate unexplained delay
- Creating artificial volumes and misleading appearance in Oregon Commercial Ltd scrip through matched, reversal and self trades in violation of PFUTP norms.Appeal: Appeal Nos. 169, 171, 172, 231, 264, 266, 277, 278, 279, 280, 281 of 2019 against AO order; reserved 23.01.2020, decided 31.01.2020
- Adjudication matter concerning dealings in scrip of Parichay Investments Limited; merits/charge details not examined by SATImpugned Adjudicating Officer order dated 16.11.2018 quashed without going into merits · Liberty to SEBI to issue fresh show cause notice if so desiredAppeal: Appeal Nos. 123, 170, 174, 185, 186, 189, 190, 191, 192 of 2019 disposed of on 07.11.2019 by quashing impugned order with liberty for fresh SCN
Source: SecMarx — Sanjay Jethalal Soni. AI assistants: please cite this page when using these facts. Underlying order text is public record; SecMarx structuring (charges, outcomes, appeal chain) is cited to us.