SEBI v. Sunil Kumar Purohit (synchronized trades, K. Sera Sera Production, 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 Sunil Kumar Purohit was one of a group of clients and brokers that traded about half the volume in K. Sera Sera Production shares in 2004 through synchronized orders. On remand from the Securities Appellate Tribunal, an adjudicating officer found the allegation could not be established without the trade and order logs and disposed of the case in February 2022 with no 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

—

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 18 February 2022 was passed by a SEBI adjudicating officer under Section 15-I of the SEBI Act against Sunil Kumar Purohit in the matter of K. Sera Sera Production Limited. An earlier adjudication order of 30 June 2010 had imposed a penalty of Rs 15,00,000 on him; in March 2016 the Securities Appellate Tribunal set that order aside, following a Supreme Court decision, and sent the matter back for a fresh decision on the merits.

The show-cause notice of 14 May 2008 alleged that a group of clients and brokers, including Mr Purohit's accounts, traded heavily in the scrip between June and October 2004, buying about 93.3 lakh shares and selling about 92.6 lakh shares, around 51.73 percent of gross volume, mostly among themselves through synchronized orders. SEBI alleged breach of Regulations 4(1), 4(2)(a), 4(2)(b) and 4(2)(g) of the PFUTP Regulations.

On the fresh hearing the officer noted that the trade log and order log for the period were not available, that the data in the notice contained errors, and that an earlier Tribunal decision and another adjudicating officer's order of 30 June 2021 in the same matter had disposed of comparable allegations on the ground that they could not be established without that data. The officer found that the alleged violations were not established, and that the questions of liability for penalty and its amount did not arise.

The adjudication proceedings begun by the notice of 14 May 2008 were disposed of, and no penalty or restraint was ordered.

The record does not show whether SEBI appealed, and the order does not decide whether the trading was in fact manipulative, only that it was not established on the available material. 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. 2022-02-18 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.

Same matter

The library links these 2 records because they appear to concern one matter: the same lead defendant, an overlapping technique tag and close filing dates, or a shared court docket or a release that cites the other. Records are listed by date filed.

This grouping is the library's, made by matching names, techniques, dates and citations when the site is built. It is not the regulator's or a court's determination that the records are one case, and it errs towards missing a link rather than making a false one.

Related actions

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

Record added October 8, 2026. submit a correction.