SEBI v. Shreedhar Yellaiah Kodam (synchronized trades, Well Pack Papers, 2026)
Dismissed
Checked against the primary document on October 8, 2026. The library's summary, tags and figures for this record were compared with the regulator's own document by an AI model (Claude) following written instructions, in a single reading of the order; an independent second reading of 60 SEBI records agreed on every field for 56, the four misses being penalty amounts. No lawyer has reviewed them. A checked record can still contain errors, and checked does not mean endorsed. See how we check records or report a correction.
On remand from the Securities Appellate Tribunal, a SEBI adjudicating officer re-examined the allegation that a Mumbai pan-shop owner was part of a 51-member group whose synchronized trades inflated Well Pack Papers and Containers Ltd. In September 2026 the officer found the fraud charge unproven and disposed of the proceedings without a penalty.
The record
| Agency | SEBI (India) |
|---|---|
| Date filed | 2026-09-22 |
| Date resolved | 2026-09-22 |
| Court | SEBI adjudicating officer |
| Status | dismissed |
| Asset class | equities |
| Instruments | Well Pack Papers and Containers Ltd shares |
| Criminal parallel | No |
| Defendants | Shreedhar Yellaiah Kodam |
| Techniques | Matched orders , Price manipulation |
What was ordered
- Civil penalty
- —
- Disgorgement
- —
- Prejudgment interest
- —
- Total relief
- —
- Alleged gain
- —
What is alleged to have happened
The order was issued on 22 September 2026 by a SEBI adjudicating officer under Section 15-I of the SEBI Act. It concerns Shreedhar Yellaiah Kodam, one of 56 noticees in an earlier 2015 adjudication over trading in Well Pack Papers and Containers Ltd, in which a penalty of Rs 5,00,000 had been imposed on him. The Securities Appellate Tribunal set that 2015 order aside on 13 February 2026 for breach of natural justice and sent the matter back to SEBI for a fresh hearing.
SEBI alleged that Mr Kodam belonged to a group of about 51 traders, referred to in the order as the Walmiki Shah Group, which executed synchronized trades and off-market share transfers that created artificial volume and moved the price of the scrip between November 2008 and June 2010. The case was framed under Regulations 3 and 4 of the PFUTP Regulations and the penalty provision in Section 15HA. The scrip was recorded as rising from Rs 9.54 to Rs 499.45 in the first period examined.
Mr Kodam answered that he is a Class IX pass pan-shop owner who never traded, and that an individual who offered to file his income-tax returns had used his papers to open bank, demat and trading accounts. He pointed to the absence of fund links or off-market transfers with the core group members, to his tiny share of market volume (0.01 to 0.03 percent in the first period and 0.00 percent in the second), and to a same-day credit and debit of 2,69,776 shares that left a zero net position.
The adjudicating officer accepted that the evidence did not show deliberate intent, a meeting of minds, or financial gain, and found that the element of fraud was missing. The charges under the PFUTP Regulations were held not sustainable, the question of penalty did not arise, and the proceedings begun by the show-cause notice of 20 November 2013 were disposed of. No penalty and no restriction was ordered.
The record does not show whether SEBI appealed, whether the identity-misuse complaint Mr Kodam says he lodged led to any action against the person he names, or what became of the other noticees in the original matter. It describes no criminal case.
This library tags the matter as matched orders and price manipulation. The tagging is ours, not the regulator's.
For the regulator's own account of the facts, read the primary document linked above. This page deliberately summarises the structured record rather than reproducing the order.
What technique is this, and how does it work?
This action is tagged with 2 techniques in our taxonomy. The tagging is ours: regulators charge statutory provisions, not technique names, so the mapping is an editorial judgement described in our editorial policy.
- Matched orders — see how it works, what statute it engages, and every other action tagged the same way.
- Price manipulation — see how it works, what statute it engages, and every other action tagged the same way.
Timeline
Primary documents
Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.
Related actions
Other actions in the library sharing at least one technique tag with this one.