SEBI v. Sure Portfolio Services Private Limited (Sun and Shine Worldwide price manipulation, struck-off company, 2022)
Dismissed
Checked against the primary document on October 9, 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; a later sample of 50 of the SEBI records added on 9 October agreed on every field for 46. 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.
In January 2022 a SEBI adjudicating officer disposed of proceedings against Sure Portfolio Services Private Limited, accused of trading with connected entities to push up the price of Sun and Shine Worldwide shares, because the company had been struck off and dissolved. No finding on the allegations and no penalty resulted.
The record
| Agency | SEBI (India) |
|---|---|
| Date filed | 2022-01-03 |
| Date resolved | 2022-01-03 |
| Court | SEBI Adjudicating Officer |
| Status | dismissed |
| Asset class | equities |
| Instruments | Sun and Shine Worldwide Limited shares |
| Criminal parallel | No |
| Defendants | Sure Portfolio Services Private Limited |
| Techniques | Matched orders |
What was ordered
- Civil penalty
- —
- Disgorgement
- —
- Prejudgment interest
- —
- Total relief
- —
- Alleged gain
- —
What is alleged to have happened
This adjudication order of 3 January 2022 concerns Sure Portfolio Services Private Limited, one of a group of connected entities in the matter of Sun and Shine Worldwide Limited (SSWL). SEBI examined trading in SSWL between 1 October 2012 and 30 September 2014, a period in which the price rose from Rs 21.90 to a high of Rs 109.70 in February 2014 and ended at Rs 17.50, without any corporate announcement that SEBI considered to explain it.
SEBI's show cause notice of 5 August 2019 alleged that a group of about 180 connected entities took part in the run-up. It singled out 4 entities that traded among themselves in the first rising phase and 23 more, including the noticee, that traded among themselves in the second phase, when the price went from Rs 79.50 to Rs 107.35. The noticees in the second phase were said to have contributed 13.79 percent of positive last-traded-price movement in 19 trades. SEBI alleged breaches of section 12A(a), (b) and (c) of the SEBI Act and the PFUTP Regulations (3, 4(1), 4(2)(a) and 4(2)(e)). No adverse inference was drawn from the group's trading in the falling phase.
The notice came back undelivered. The adjudicating officer checked the corporate affairs ministry website and found that the noticee's name had been struck off the register and the company dissolved on 8 August 2018. Relying on case law that proceedings against a dissolved company cannot continue, the officer concluded that the proceedings could not be pursued and disposed of them. No penalty was imposed.
The order therefore makes no finding on whether the trading was manipulative, and it says nothing about the other noticees, who are dealt with in separate orders. The record does not show whether anyone appealed, and it records no criminal case.
This library tags the matter as matched orders, because the allegation is that connected entities traded among themselves to move the price; the allegation was never tested. 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 one technique 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.
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.
| Action | Agency | Filed | Technique | Penalty | Status |
|---|---|---|---|---|---|
| SEBI v. Shreedhar Yellaiah Kodam (synchronized trades, Well Pack Papers, 2026) | SEBI (India) | 2026-09-22 | Matched Orders , Price Manipulation | — | dismissed |
| SEC v. Corey Ortiz (free riding and parking, 2026) | SEC | 2026-09-03 | Free Riding And Parking , Matched Orders | — | judgment |
| SEBI v. Hanif Shekh and others (price and volume manipulation in five scrips, Mauria Udyog and others, 2026) | SEBI (India) | 2026-06-30 | Matched Orders , Pump And Dump +1 | — | judgment |
| SEC v. Christopher Flagg, Daquan Lloyd and Travis Treusch (free riding and parking, 2026) | SEC | 2026-04-30 | Free Riding And Parking , Matched Orders | — | judgment |
| SEBI v. Harsha Ishvarbhai Solanki and others (trading in ANI Integrated Services, 2026) | SEBI (India) | 2026-02-12 | Price Manipulation , Matched Orders | — | judgment |
| SEBI adjudication orders on illiquid stock options at BSE (2026 batch) | SEBI (India) | 2026-01-05 | Matched Orders | — | judgment |