SEBI v. V. P. Patel and others (listing-day trading, Bharatiya Global Infomedia IPO, 2022)

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; 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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SEBI alleged that 22 allottees, brokers and company-linked entities used structured and circular trades to create artificial volume and an exit for allottees on the listing day of Bharatiya Global Infomedia's 2011 IPO. On remand from the Securities Appellate Tribunal, an adjudicating officer found the alleged violations not made out and disposed of the proceedings in February 2022 without any penalty.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

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Total relief

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Alleged gain

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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.

What is alleged to have happened

The adjudication order of 14 February 2022 was passed by a SEBI adjudicating officer under Section 15-I of the SEBI Act, in the matter of Bharatiya Global Infomedia Limited. It followed an earlier order of 25 March 2014 that had imposed penalties on the noticees, ranging up to Rs 6 crore on the first noticee, which the Securities Appellate Tribunal set aside on 6 April 2016 and sent back for fresh decision on the merits. The 22 noticees include individuals, family HUFs, companies said to be connected to the issuer, and several stock brokers.

The company raised Rs 55.10 crore in an IPO on a price band of Rs 75 to Rs 82, graded below average and 1.47 times subscribed, and was listed on 28 July 2011. On that day about 8.83 crore shares traded on the two exchanges, of which only about 6.5 percent were delivery based, and the price fell from about Rs 82 to under Rs 31 at the close, while many large allottees sold. SEBI alleged that the noticees, linked to each other or to the company, traded without any intention of changing beneficial ownership through structured, synchronized and circular trades, that company-related entities and two brokers gave allottees an exit, and that this created artificial volume and a misleading appearance of trading, in breach of the PFUTP Regulations and the stock broker regulations.

On the remand the officer examined the noticees individually, taking account of the Tribunal's directions, the time that had passed, and the evidence of matching order timing, price and quantity. In several instances, for example for two brokers, the order found no matching of time or quantity and no clear evidence of a device or scheme or of aiding clients, or accepted explanations such as an operator's failure to run clients' pre-order files, for which one broker had compensated its clients.

The order concluded that the noticees were not liable to a penalty under Section 15HA or Section 15HB, that the question of the amount did not arise, and that the case did not warrant any monetary penalty, and it disposed of the proceedings begun by the notice of 6 May 2013. No restraint was imposed.

The record does not show whether SEBI appealed the disposal or what became of the interim directions of December 2011 against the company and directors, which belong to other proceedings. The order does not find that the listing-day trading was legitimate, only that the violations were not established against these noticees. 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. 2022-02-14 SEBI adjudication order on remand, disposing of the proceedings

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.