SEBI v. Chiranjilal Jayaram Vyas and others (circular trades, Sunteck Realty, 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.

Report an error in this record (sebi-57190-wash-trading-2022) by email

In March 2022, on remand from the Securities Appellate Tribunal, a SEBI adjudicating officer re-set penalties on six traders and a brokerage at about Rs 3.82 crore for circular trading in Sunteck Realty shares, using SEBI's computed unlawful gains as the measure. Two noticees who made losses were fined Rs 5 lakh each.

The record

What was ordered

Civil penalty

—

Disgorgement

—

Prejudgment interest

—

Total relief

—

Alleged gain

—

Penalty as published

38.2m 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

A SEBI adjudicating officer, Barnali Mukherjee, decided the matter on 25 March 2022. The noticees are six individuals, led by Chiranjilal Jayaram Vyas, and the brokerage Shripal Shares and Securities Ltd. The shares are those of Sunteck Realty Limited (formerly Insul Electronics). The case returned to the adjudicating officer after the Securities Appellate Tribunal remitted an earlier December 2019 penalty order in September 2021 so that the method of computing unlawful gains could be reconsidered.

SEBI's earlier finding, which the tribunal left in place on the merits and which the order treats as settled, was that the group moved large blocks of shares among themselves through off-market transfers, passed them on to front entities and sold them on the exchange. The pattern formed a circular route that created artificial volume in the scrip, in breach of regulations 3 and 4 of the PFUTP Regulations.

The only issue reopened was the penalty. Having heard the noticees, who argued for the average-cost method, the officer computed gains on that method and set each of the first five noticees' penalties equal to their gain. These were about Rs 2.86 crore, Rs 57.7 lakh, Rs 3.6 lakh, Rs 23.5 lakh and Rs 1.3 lakh respectively. The sixth noticee and the brokerage made a loss on the calculation, but were fined Rs 5,00,000 each for their active part in the group.

The penalties were imposed under section 15HA of the SEBI Act and total about Rs 3.82 crore (Rs 3,81,59,780). The officer also noted the time that had passed since the trades.

The record does not show whether the new order was appealed or paid, or what share price effect the circular trading had.

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. 2022-03-25 SEBI 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.

• 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.