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SEBI v. Mohammad Rashid and R K Stockholding Pvt. Ltd. (synchronized and reversal trades, Religare 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.

Report an error in this record (sebi-56098-matched-orders-2022) by email

A SEBI adjudicating officer found that a broker's employee traded Religare Enterprises shares back and forth with a single counterparty within seconds, in synchronized and reversal trades, in April and May 2011. The February 2022 order penalised him Rs 5 lakh and closed the case against his employer, the broker, with the benefit of the doubt.

The record

Structured fields for this action, as recorded in our case library.
Agency SEBI (India)
Date filed 2022-02-15
Date resolved 2022-02-15
Court SEBI adjudicating officer
Status judgment
Asset class equities
Instruments Religare Enterprises Ltd shares
Venue NSE, BSE
Criminal parallel No
Defendants Mohammad Rashid (individual) ; R K Stockholding Pvt. Ltd. (entity)
Techniques Matched orders , Wash trading

What was ordered

Civil penalty
—
Disgorgement
—
Prejudgment interest
—
Total relief
—
Alleged gain
—
Penalty as published
500k 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 15 February 2022 was passed by a SEBI adjudicating officer under Section 15-I of the SEBI Act, in the matter of Religare Enterprises Ltd. It names Mohammad Rashid, an employee of the stock broker R K Stockholding Pvt. Ltd., and the broker itself. SEBI examined trading from 13 April to 2 May 2011.

SEBI alleged that Mr Rashid entered into synchronized trades and reversals with one other client, Promila Lal, through the broker. The synchronized trades amounted to 51.90 percent of his BSE volume and 49.52 percent of his NSE volume in the scrip; the order's examples show buy and sell orders for identical quantities and prices entered within a second or two of each other, and reversals within seconds or minutes. SEBI also alleged that the broker credited his ledger with Rs 14,83,048 for transactions that never took place, produced altered contract notes, lent him shares that he sold off-market for Rs 16,35,753, and funded about Rs 31.19 lakh of his trading.

The officer found that the near-perfect matching of time, price and quantity pointed to pre-meditated trading, apparently by one person for both sides, and that Mr Rashid avoided the proceedings, did not attend hearings and did not take up the inspection he had requested, which the officer treated as indicating his role. Both the price effect of the trades and any gain were small or unquantified, but they were held to breach Regulations 3(a) to (d), 4(1), 4(2)(a) and 4(2)(g) of the PFUTP Regulations.

A penalty of Rs 5,00,000 under Section 15HA was imposed on Mr Rashid. As to the broker, the officer noted that he was its employee with access to its registers and ledgers and may himself have been responsible for the ledger and account irregularities, gave the broker the benefit of the doubt, and disposed of the proceedings against it without a penalty.

The record does not show whether Mr Rashid appealed or paid, who Ms Lal was beyond the counterparty, or any loss to other investors. The order names its first noticee inconsistently in the heading and the body. It describes no criminal case.

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

Timeline

  1. 2022-02-15 SEBI adjudication order imposing a penalty

Primary documents

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

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

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

Action Agency Filed Technique Penalty Status
SEBI v. Usha Devi and others (price and volume manipulation of DU Digital Technologies, 2025) SEBI (India) 2025-12-31 Price Manipulation , Matched Orders +1 — judgment
SEBI v. Panchal Shanti Lal (alleged reversal and synchronized trades, Swan Energy, 2025) SEBI (India) 2025-09-17 Matched Orders , Wash Trading — dismissed
SEBI v. Vijay Pujara and others (synchronized and circular trades, Kavit Industries, 2025) SEBI (India) 2025-02-28 Matched Orders , Wash Trading — judgment
SEBI v. Rajendra D. Shah and 35 others (NIFTY index options trades, 2024) SEBI (India) 2024-08-30 Matched Orders , Wash Trading — judgment
SEBI v. Jayesh Rawal and others (Generic Engineering Construction and Projects, 2023) SEBI (India) 2023-08-10 Price Manipulation , Matched Orders +1 — judgment
SEBI v. Divyaben Hiteshbhai Gangani and others (Kapil Raj Finance Ltd, circular trades, 2023) SEBI (India) 2023-06-16 Wash Trading , Matched Orders — judgment

Record added October 8, 2026. submit a correction.