SEBI v. Shilpi Krishnakumar Modi (self-trades, Mefcom Agro Industries, 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, proceedings against an individual accused of self-trades and order-book manipulation in Mefcom Agro Industries shares in 2006 and 2007. The officer found no proven link to the promoters' group and gave her the benefit of doubt.

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, Vijayant Kumar Verma, decided the matter on 30 March 2022. The sole noticee is Shilpi Krishnakumar Modi, now known as Shilpi Jayesh Chawla, and the shares are those of Mefcom Agro Industries Limited. SEBI examined trading from January 2006 to June 2007.

SEBI alleged that she was the fourth largest buyer in the period, buying about 17.19 lakh shares and selling about 17.22 lakh, and that as part of a 'Mefcom Group' she had made repeated self-trades at prices above the last traded price and manipulated the order book, in breach of regulations 3 and 4 of the PFUTP Regulations. The group was said to include the company's promoters and entities that acted as their counterparties.

The order finds the evidence did not establish any connection between her and the promoters or the group. It notes that contributing to the last traded price requires collusion between buyer and seller, which was not shown, and that SEBI's own 2017 policy treats self-trades as improper only where intent or manipulation is shown. It adds that a parallel whole-time member order of February 2020 had reached the same conclusion about the group link.

The notice was disposed of without penalty, giving her the benefit of doubt, and the officer noted that the events dated from 2006 and 2007.

The record does not show whether SEBI appealed, and the order does not decide whether the Mefcom group itself manipulated the scrip.

This library tags the matter as wash trading and price manipulation. 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.
• Price manipulation — 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.

Related actions

Other actions in the library sharing at least one technique tag with this one.

Record added October 8, 2026. submit a correction.