SEBI v. Girraj Kishore Agarwal and others (circular and reversal trades, Octant Interactive Technologies, 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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After the Securities Appellate Tribunal upheld findings that 15 entities used circular and reversal trades in Octant Interactive Technologies shares in 2009 but found the original penalties excessive, a SEBI adjudicating officer re-fixed the penalty at Rs 2 lakh for each of 14 of them, Rs 28 lakh in total. The case against the fifteenth, which had merged into another company, was closed.

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

2.8m 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 28 February 2022 was passed by a SEBI adjudicating officer under Section 15-I of the SEBI Act, in the matter of Octant Interactive Technologies Limited, listed on BSE. It deals with 15 of 35 entities penalised in an adjudication order of 2 August 2019 for trading between January and September 2009; the 15 had appealed.

The earlier order found that these entities violated Regulations 3 and 4 of the PFUTP Regulations through circular and reversal trades. On 17 September 2021 the Securities Appellate Tribunal affirmed those findings against all the appellants except one unrelated appellant, but held the penalties excessive in light of a 2021 fresh decision in another case in which a Rs 10 lakh penalty had been cut to Rs 2 lakh, and sent the matters back only for reconsideration of the amount.

The officer therefore did not re-examine whether the trades were manipulative, and treated the Tribunal's affirmation of the fraud findings as settled. For the fifteenth noticee, Keystone Stock Finance, the officer found that the company had been merged into another company and that, given SEBI's stance before the Tribunal and the terms of the merger, the proceedings could not continue, and closed the notice without penalty.

The officer imposed a penalty of Rs 2,00,000 under Section 15HA on each of the other 14 noticees, 12 of whom are listed in this record by name, Rs 28 lakh in all, payable within 45 days. No trading restraint was ordered in this order.

The record does not show how the conduct was carried out in detail beyond the Tribunal's summary, because this order is limited to the penalty, or whether anyone appealed the revised amounts. It describes no criminal case.

This library tags the matter as matched orders and wash trading. 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.
• Wash trading — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2022-02-28 SEBI adjudication order on remand reducing penalties

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.