SEBI v. Peeyush Agarwal (alleged synchronized trades, Polar Pharma India, 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 Peeyush Agarwal, a former director of Polar Pharma India, was connected to a group that raised the price and created artificial volume in the scrip through synchronized trades in 2005. A February 2022 adjudication order accepted that he was simply liquidating a long-held stake and closed the proceedings 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

—

Alleged gain

—

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 24 February 2022 was passed by a SEBI adjudicating officer under Section 15-I of the SEBI Act, in the matter of Polar Pharma India Limited, whose shares traded on BSE. SEBI had investigated 4 July to 13 September 2005. An ad-interim order of 2 February 2016 had impounded alleged gains from eight entities, including Mr Agarwal, and a show-cause notice followed on 8 November 2017.

SEBI alleged that Mr Agarwal was connected to a group of entities that contributed significantly to positive last-traded-price variation by trading among themselves, and that he took part in synchronized trades creating artificial volume, contributing about 13.77 percent of the scrip's volume on the sell side.

Mr Agarwal answered that he was a former director who had held 4 lakh shares for years, sold 3,95,000 shares during the investigation period and made no purchases, that he had a person watching the screen who placed sell orders against visible buy orders, that synchronized trades happened on only 8 of 14 trading days with the rest executed against third parties, and that the 13.77 percent figure counted one side of volume only. The officer noted a finding in earlier proceedings that he was not connected with the group, held that inferring connection from trades with its members was therefore illogical, and treated the sales as liquidation of a long-term investment rather than manipulation.

The officer gave him the benefit of that view and closed the proceedings without any monetary penalty. No restraint was ordered. The question whether an earlier whole-time member's findings bind an adjudicating officer was left undecided.

The record does not show whether SEBI appealed, or what happened in the proceedings against the other seven entities named in the 2016 interim 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

1. 2022-02-24 SEBI adjudication order closing the proceedings without 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.

• 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.