SEBI v. Sunil Kumar Purohit (circular trades, Gravity India, 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 case against an individual accused of circular trading in Gravity India shares in 2003-04. The officer found the original trade and order logs missing, no link to the other traders, and the noticee's share of the trades minuscule.

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

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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, Suresh B Menon, decided the matter on 31 March 2022. The sole noticee is Sunil Kumar Purohit, and the shares are those of Gravity India Limited, which traded only on BSE. The case arose from a BSE report on trading between December 2003 and March 2004, when the price rose from Rs 10.60 to a high of Rs 32 and closed at Rs 21.

SEBI alleged that a group of entities bought about 64.5 lakh shares and sold about 64.7 lakh, roughly 71 per cent of gross volume, in circular and reversal trades that created artificial volume and a price rise. It said the noticee, trading through the broker Southern Shares & Stocks Limited, bought 1,39,700 shares and sold the same number, mostly within the group, in breach of regulations 3 and 4 of the PFUTP Regulations.

The officer held the allegation not established. The trade log, order log and the noticee's account-opening documents were not available, so the figures in the notice could not be checked, no connection between him and the group was shown, and the investigation report did not support the reversal-trade charge. Even on SEBI's figures his circular trading was about 1.48 per cent of buy volume within the group and 0.23 per cent of sales, the smallest among the clients.

The adjudication proceedings were disposed of with the benefit of doubt to the noticee and no penalty.

The record does not show whether SEBI appealed, and the order makes no finding on whether the group as a whole 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. 2022-03-31 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.