Market Manipulation. Search

SEBI v. Pragya Dairies and Agro Limited and others (unregistered cattle and ghee scheme, 2022)

Judgment entered

Checked against the primary document on October 9, 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-56501-market-abuse-2022) by email

In February 2022 a SEBI adjudicating officer imposed a penalty of Rs 60 lakh, payable jointly and severally, on Pragya Dairies and Agro Limited and five of its directors for running an unregistered cattle and ghee collective investment scheme. The order treats the directors' conduct as a fraudulent practice under the PFUTP Regulations.

The record

Structured fields for this action, as recorded in our case library.
Agency SEBI (India)
Date filed 2022-02-28
Date resolved 2022-02-28
Court SEBI Adjudicating Officer
Status judgment
Asset class other
Instruments unregistered cattle and ghee collective investment scheme
Criminal parallel No
Defendants Pragya Dairies and Agro Limited (entity) ; Punam Chand Patidar (individual) ; Nana Lal Patidar (individual) ; Pooja Patidar (individual) ; Durga Patidar (individual) ; Ansar Ahmed (individual)
Techniques

What was ordered

Civil penalty
—
Disgorgement
—
Prejudgment interest
—
Total relief
—
Alleged gain
—
Penalty as published
6m 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

This adjudication order of 28 February 2022 concerns Pragya Dairies and Agro Limited, an Indore company, and five individuals who were its directors: Punam Chand Patidar, Nana Lal Patidar, Pooja Patidar, Durga Patidar and Ansar Ahmed. SEBI started from a 2016 complaint that the company had collected money from about 200 investors and had not responded to its information requests.

The company sold what it called joint venture arrangements in cattle and ghee, with investors paying in instalments and receiving certificates promising an expected sum on expiry of the term. The officer examined the four statutory conditions for a collective investment scheme under section 11AA of the SEBI Act and found that the arrangement met them, because investors pooled contributions for returns, the property was managed on the investors' behalf, and they had no day-to-day control. The company held no registration.

The show cause notice alleged breach of Regulation 4(2)(t) of the PFUTP Regulations, which treats a director of a company running an unregistered collective investment scheme as having committed a fraudulent practice. The officer found the violation made out against all six noticees and observed that the scheme put a large number of investors' money at risk. A whole time member order of 6 March 2020 had already directed refunds to investors with returns due.

Citing that refund direction, the officer imposed a total penalty of Rs 60 lakh under section 15HA of the SEBI Act, for which the company and the five directors are jointly and severally liable, payable within 45 days. The order records the statutory range as a minimum of Rs 5 lakh and a maximum of Rs 25 crore or three times the profits, and chose a lower figure because investor refunds were paramount.

The record does not show the total amount collected in the order itself, whether the refunds were made, whether anyone appealed, or the criminal case against the company and directors that the companion order mentions.

This library applies no technique tag to the matter, because no technique, because the order concerns an unregistered investment scheme penalised under a director-specific fraud provision, which fits none of the library's techniques with confidence. 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.

Timeline

  1. 2022-02-28 SEBI adjudication order

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.

Record added October 8, 2026. submit a correction.