SEBI v. Sagar Kadam and others (Finalysis Credit and Guarantee penalties, 2022)

Judgment entered

✓ 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 converted a Rs 18 lakh joint and several penalty on twelve Finalysis Credit and Guarantee noticees into separate penalties of Rs 1.5 lakh each. The twelve had already paid those amounts.

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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Penalty as published

1.8m INR

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. This regulator states penalties in INR. The figure is recorded as published and is not converted, so it does not appear in the USD totals or medians used elsewhere on this site.

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. The twelve noticees were Sagar Kadam, Dharmendra Harilal Bhojak, Mahadev Zilu Gawade, Sorab Wadia, Kalpana Mukesh Ruia, Vallabhbhai Kakadiya, Santosh Agarwal, Jigna Vipul Vora, Ashraf Usmani, Ravi Ramniklal Kothari, Nandkishore Didwania and Pankaj Jayantilal Dave.

SEBI's investigation of Finalysis Credit and Guarantee Company Ltd found that many entities traded among themselves and created artificial volume in the stock. An adjudicating officer held 42 entities to have violated Regulations 3 and 4 of the 2003 fraudulent and unfair trade practices regulations, but penalised only these twelve, Rs 18 lakh jointly and severally, by an order of May 2019 repeated in September 2020 after the Securities Appellate Tribunal's remand. The Tribunal had asked that the joint and several liability be looked at again because the entities said they were not connected to one another.

SEBI's notice of 1 October 2020 asked why the joint and several penalty should not be replaced with a separate penalty on each entity under section 15HA. The noticees contested the legal basis of the review. By the time of the order, all twelve had paid Rs 1.5 lakh each, which equals the original Rs 18 lakh in total.

The whole-time member decided that the ends of justice would be met by modifying the penalty into an individual penalty of Rs 1.5 lakh on each of the twelve and disposed of the notice without further directions. The payments already made were credited against the original liability.

The record does not show each noticee's share of the artificial volume, the size of any profit, or whether anyone appealed. The order is a review of penalty structure; the finding of violation came from the earlier adjudication order.

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.