SEBI v. Dhananjay Kumar (synchronized trades and price rise, Kushal Tradelink, 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.
On remand because he had not been served in the first proceeding, a SEBI adjudicating officer found that Dhananjay Kumar and four connected traders traded among themselves in Kushal Tradelink shares in 2014 and 2015, creating artificial volume and lifting the price about 567 percent. The February 2022 order imposed a penalty of Rs 20 lakh.
The record
| Agency | SEBI (India) |
|---|---|
| Date filed | 2022-02-22 |
| Date resolved | 2022-02-22 |
| Court | SEBI adjudicating officer |
| Status | judgment |
| Asset class | equities |
| Instruments | Kushal Tradelink Limited shares |
| Venue | BSE |
| Criminal parallel | No |
| Defendants | Dhananjay Kumar |
| Techniques | Matched orders , Price manipulation |
What was ordered
- Civil penalty
- —
- Disgorgement
- —
- Prejudgment interest
- —
- Total relief
- —
- Alleged gain
- —
- Penalty as published
- 2m INR
What is alleged to have happened
The adjudication order of 22 February 2022 was passed by a SEBI adjudicating officer under Section 15-I of the SEBI Act against Dhananjay Kumar, in the matter of Kushal Tradelink Limited. A common order of 22 December 2017 had penalised him and four others Rs 20 lakh each, but the Securities Appellate Tribunal quashed it as to Mr Kumar on 25 June 2021 because he had not been served the show-cause notice, and sent the case back for a fresh decision after service.
SEBI's investigation covered 1 August 2014 to 11 March 2015, when the shares traded on the SME platform of BSE. It recorded a price rise from Rs 22.95 to Rs 153, or 566.67 percent, and alleged that Mr Kumar and four connected persons carried out 72 synchronized trades among themselves for 3,24,000 shares, 13.19 percent of market volume, over many days, and bought repeatedly above the last traded price, contributing about 12.9 percent of the market's positive price movement. Their net position was zero.
Mr Kumar replied and was heard in the remand proceedings. The officer found that his trading with the connected entities, over about a month and a half, contributed to price rise through first trades, last-traded-price and new-high-price contributions without any change in meaningful ownership, and held that he had violated Regulations 3(a) to (d), 4(1), 4(2)(a), 4(2)(e) and 4(2)(g) of the PFUTP Regulations.
A penalty of Rs 20,00,000 was imposed on Mr Kumar under Section 15HA, the same amount as in the original order, payable within 45 days. No trading restraint was ordered.
The record does not show whether he appealed the new order, what gain the group made, or what has become of the four connected persons, whose original penalties are outside this order. It describes no criminal case.
This library tags the matter as matched orders and price manipulation. 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.
- Matched orders — see how it works, what statute it engages, and every other action tagged the same way.
- Price manipulation — see how it works, what statute it engages, and every other action tagged the same way.
Timeline
Primary documents
Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.
Related actions
Other actions in the library sharing at least one technique tag with this one.