SEBI v. Ace Consultant (Esteem Bio Organic Food Processing IPO, 2022)
Dismissed
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.
In March 2022 a SEBI adjudicating officer disposed of, without penalty, allegations that the proprietorship Ace Consultant helped fund applications in the IPO of Esteem Bio Organic Food Processing. The officer found the loan and application links explained and the charges not established.
The record
| Agency | SEBI (India) |
|---|---|
| Date filed | 2022-03-29 |
| Date resolved | 2022-03-29 |
| Court | SEBI Adjudicating Officer |
| Status | dismissed |
| Asset class | equities |
| Instruments | Esteem Bio Organic Food Processing Limited IPO shares |
| Venue | BSE SME |
| Criminal parallel | No |
| Defendants | Ace Consultant |
| Techniques |
What was ordered
- Civil penalty
- —
- Disgorgement
- —
- Prejudgment interest
- —
- Total relief
- —
- Alleged gain
- —
What is alleged to have happened
This adjudication order of 29 March 2022 concerns Ace Consultant, a proprietorship firm of Sunita Khemka, in the matter of the IPO of Esteem Bio Organic Food Processing Limited. The company raised Rs 1,125 lakh through 45 lakh shares at Rs 25 each and listed on the BSE SME segment on 7 January 2013.
SEBI's investigation, set out in a show cause notice of 29 November 2017, looked at how the IPO proceeds were used and found that information given by the company was incomplete and misleading. It alleged that entities connected to the company directly or indirectly funded the IPO applicants, and that IPO money moved on to some of those entities, including a finance company called Goldline. The notice alleged that Ace Consultant funded Ms Khemka's own application for 6,000 shares, worth Rs 1.5 lakh, and received money from Goldline, and that it was linked to a director of another company, B K Sabharwal. The charge was breach of section 12A of the SEBI Act and Regulations 3(a) to (d) and 4(1) of the PFUTP Regulations.
The adjudicating officer was unconvinced by the explanation that Mr Sabharwal stayed on as a director only for handover, but still found the charges unproved. A proprietorship cannot itself apply for shares, so funding the application of its own proprietor was not a violation. The Goldline transactions were shown, through bank statements and account copies, to be a genuine loan repaid with interest of Rs 5,81,917 and settled in July 2014.
The officer concluded that no charge was established, saw no penalty warranted, and disposed of the notice. The order notes that a parallel proceeding before a whole time member over the same facts was dropped in December 2020 without directions against the noticee.
The record does not show how the IPO proceeds were ultimately used, what happened to the company or other noticees, whether SEBI appealed, or any criminal case.
This library applies no technique tag to the matter, because no technique, because the allegation concerned funding of IPO applications and use of IPO proceeds, and it was not established. 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
- 2022-03-29 SEBI adjudication order (no 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.