SEBI v. Sushiladevi N. Didwania and others (Finalysis Credit and Guarantee review, 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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On 27 May 2022 a SEBI whole-time member closed review proceedings that sought to impose penalties on 30 entities an adjudicating officer had held to have traded among themselves in Finalysis Credit and Guarantee shares but left unpenalised. He disposed of the notice as not maintainable and made no directions.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

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Total relief

—

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 whole-time member, S K Mohanty, decided the matter on 27 May 2022 under section 15-I(3) of the SEBI Act, which lets the Board review and enhance an adjudicating officer's order. The proceedings named 30 noticees, among them Sushiladevi N Didwania, Manju Devi Bothra, Mukesh Ramniranjan Ruia and Kshitiz Nirman Pvt Ltd; this record lists twelve. One noticee, Sanjay Kumar Goyal, had died in July 2021.

The underlying case was that many entities traded among themselves in the shares of Finalysis Credit and Guarantee Company Ltd and created artificial volume. In an order of 22 May 2019, repeated after a remand on 3 September 2020, an adjudicating officer held 42 noticees to have violated Regulations 3 and 4 of the 2003 fraudulent and unfair trade practices regulations, but imposed a penalty of Rs 18 lakh, jointly and severally, on only 12 of them and no penalty on 30 who each accounted for a small share of the artificial volume. The Securities Appellate Tribunal had criticised that cut-off as arbitrary when it sent the penalised entities' appeals back.

SEBI issued notices on 1 October 2020 asking why the September 2020 order should not be called back and penalties imposed on the 30. The noticees argued that no review had been started against the earlier 2019 order, that the new order was no different on the facts, and that none of them had appealed.

The whole-time member accepted that those arguments had persuasive force. He said the officer's failure to address the Tribunal's remand concern might amount to non-adherence but was not a ground for review under section 15-I(3), and disposed of the notices without any direction. No penalty was imposed on these 30 noticees.

The record does not show how much artificial volume each noticee generated, whether SEBI appealed, or whether the matter was reopened another way. The result is a procedural disposal, and the companion order concerning the 12 penalised entities is a separate record.

This library tags the matter as 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 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.

• Matched orders — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2022-05-27 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

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.