SEBI v. Sterling International Enterprises Ltd (issuer in circular-trading case, 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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In a companion to the order against 49 other entities, a SEBI adjudicating officer found that Sterling International Enterprises, now in liquidation, was part of the scheme in which connected entities and the company's directors traded circularly in its own shares in 2008 and 2009. The February 2022 order imposed a penalty of Rs 2 lakh so that SEBI could lodge its claim with the liquidator.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

—

Total relief

—

Alleged gain

—

Penalty as published

200k 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 17 February 2022 was passed by a SEBI adjudicating officer under Section 15-I of the SEBI Act against Sterling International Enterprises Ltd, whose shares were listed on BSE only. It is the issuer-level counterpart to the order of 31 January 2022 against 49 connected entities and directors in the same investigation covering May 2008 to September 2009.

SEBI's show-cause notice of 12 February 2020 alleged that the company and six of its directors were part of a scheme in which connected entities created artificial volume through circular trades, synchronized trades and trading among themselves, in 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 company's promoters Nitin and Chetan Sandesara were also directors.

The company, represented through its insolvency liquidator, argued that it had gone through a corporate insolvency process from July 2018 and into liquidation on 18 October 2021, that the trading was done by its promoters and directors, who ran its day-to-day affairs, and that the proceedings were barred or unfair. The officer accepted that the insolvency orders created a bar and a moratorium, but held that these proceedings could go ahead for the limited purpose of deciding whether the company violated securities law and fixing the penalty so that SEBI can set out its claim to the liquidator.

The officer held the violations established and imposed a penalty of Rs 2,00,000 under Section 15HA, payable by the company to the extent of the liquidation scheme. No restraint was ordered.

The record does not show whether anything will be recovered from the liquidation estate, whether SEBI or the liquidator appealed, or what the company itself gained. 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. 2022-02-17 SEBI adjudication order imposing a penalty on the issuer

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.