SEBI v. Nitin Jayantilal Sandesara and others (circular trades, Sterling International Enterprises, 2022)

Judgment entered

✓ 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; 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.

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A SEBI adjudicating officer found that 49 connected companies, directors and individuals, including two directors of the issuer, traded in circles among themselves in Sterling International Enterprises shares in 2008 and 2009 to create artificial volume. The January 2022 order imposed penalties from Rs 1 lakh to Rs 4 lakh per group of noticees, about Rs 49 lakh in all.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

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Total relief

—

Alleged gain

—

Penalty as published

4.9m INR

A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars. This regulator states penalties in INR. The figure is recorded as published and is not converted, so it does not appear in the USD totals or medians used elsewhere on this site.

What is alleged to have happened

The adjudication order of 31 January 2022 was passed by a SEBI adjudicating officer under Section 15-I of the SEBI Act. It concerns 49 of 61 entities proceeded against in the matter of Sterling International Enterprises Limited, whose shares were listed on BSE only. The lead noticees are Nitin and Chetan Sandesara, directors of the company, and the others are companies, their directors and several individuals and HUFs. SEBI investigated May 2008 to September 2009.

SEBI alleged that the noticees were linked by shared client-code details, know-your-customer information, directorships, addresses, introducers, fund transfers and off-market transfers, and that they executed repeated circular trades among themselves in three stretches (May to June 2008, July to August 2008 and February to March 2009), creating artificial volume and a misleading appearance of trading. The charge was breach of Section 12A of the SEBI Act and Regulations 3, 4(1), 4(2)(a) and 4(2)(g) of the PFUTP Regulations.

The officer found the connections and the trading pattern established, concluded that the group's purpose was to create artificial volumes to entice other investors and then buy or sell at more favourable prices while the shares stayed within the group, and held the violations proved against all 49. The investigation had not quantified profit or loss, and the officer weighed that the trades dated from 2008 and 2009.

Penalties under Section 15HA were set per group, payable jointly and severally by the members of each group, between Rs 1,00,000 and Rs 4,00,000, for example Rs 3 lakh for each of the groups around the two issuer directors, Faith Finstock, Prolific Mercantile and Adore Merchantile, and Rs 4 lakh for the Kingfisher, Dollex and Akhila-Meghana-Robosoft groups. The group amounts sum to about Rs 49 lakh. No trading restraint was ordered.

The record does not show whether any noticee appealed, what the group gained, or what happened to the remaining 12 entities in the original proceedings, who are not covered by this order. It describes no criminal case.

This library tags the matter as wash trading and matched orders. 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.

• Wash trading — see how it works, what statute it engages, and every other action tagged the same way.
• Matched orders — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2022-01-31 SEBI adjudication order imposing penalties

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

• SEBI order
• Order (PDF)

The linked release is published by the issuing regulator under its own terms. Our summary and narrative above are our own writing.

Related actions

Other actions in the library sharing at least one technique tag with this one.

Record added October 8, 2026. submit a correction.