SEBI v. Sunil Purohit (circular trades, Rajesh Exports, 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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In March 2022 a SEBI adjudicating officer closed, without penalty, a remanded case against an individual accused of circular trading in Rajesh Exports shares in 2003. The officer found the records too incomplete to show he had traded or that the trades created artificial volume.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

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Total relief

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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

A SEBI adjudicating officer, Maninder Cheema, decided the matter on 30 March 2022. The sole noticee is Sunil Purohit, and the shares are those of Rajesh Exports Limited, traded on BSE and NSE. A show cause notice dated August 2007 had led to a 2011 order, which the Securities Appellate Tribunal set aside in March 2016 and sent back for fresh consideration.

SEBI alleged that between June and August 2003 a group of brokers and their clients executed circular transactions in about 9.16 lakh shares, and that the noticee, as a client of the broker Ajmera Associates, took part in circular trades for 1,10,095 shares, about 6.66 per cent of market volume. The charge was creating artificial volume in breach of the PFUTP Regulations.

The officer accepted that delay did not bar the case but held the evidence insufficient. BSE no longer held trade and order books from before 2006, some annexures to the notice were illegible, the circular-trade data showed broker codes but not client codes, and his account opening documents were not on record. No connection between him and the other brokers and clients was shown.

The officer found the allegation not established and disposed of the proceedings without a penalty.

The record does not show whether SEBI appealed, and the order makes no finding on whether circular trading in the scrip actually took place.

This library tags the matter as 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 one technique 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.

Timeline

1. 2022-03-30 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.