Market Manipulation. Search

SEBI v. Giriraj Kishore Agarwal and others (funded preferential allotment, Esaar India, 2022)

Judgment entered

Checked against the primary document on October 9, 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.

Report an error in this record (sebi-61248-market-abuse-2022) by email

In July 2022 a SEBI adjudicating officer fined a former Esaar India director, his wife and daughter and a company they were linked to Rs 5,00,000 each over a funded preferential allotment. The order finds that the family routed Rs 19,00,000 to an allottee and that part of the issue proceeds then went to their finance company.

The record

Structured fields for this action, as recorded in our case library.
Agency SEBI (India)
Date filed 2022-07-27
Date resolved 2022-07-27
Court SEBI adjudicating officer
Status judgment
Asset class equities
Instruments Esaar (India) Limited shares (2011 preferential allotment)
Venue BSE
Criminal parallel No
Defendants Giriraj Kishore Agarwal (individual) ; Tanu Agarwal (individual) ; Saloni Agarwal (individual) ; Tilak Finance Limited (entity)
Techniques

What was ordered

Civil penalty
—
Disgorgement
—
Prejudgment interest
—
Total relief
—
Alleged gain
—
Penalty as published
2m 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

The order of 27 July 2022 is part of the SEBI examination of Esaar (India) Limited's May 2011 allotment of 31,77,000 shares to 44 non-promoter entities. The noticees were Giriraj Kishore Agarwal, a former Esaar director, Tanu Agarwal, also a former director, their daughter Saloni Agarwal, and Tilak Finance Limited, of which the Agarwals were directors.

SEBI alleged that Saloni Agarwal was allotted 40,000 shares and paid Rs 20,00,000, of which Rs 19,00,000 came to her from Tanu Agarwal on 12 May 2011. It said Mr Agarwal was a signatory on the bank account where Esaar's allotment proceeds were held, and that Tilak Finance then received Rs 10,00,000 from those proceeds on 25 May 2011. SEBI treated this as financing the allotment from the company's own circle, in breach of section 12A of the SEBI Act and Regulations 3(b) to (d) and 4(1) of the PFUTP Regulations.

The adjudicating officer found these allegations established on the record of bank transfers and the noticees' relationships, and held that the arrangement created a false appearance of an arm's-length subscription.

Each of the four noticees was fined Rs 5,00,000 under section 15HA of the SEBI Act, Rs 20,00,000 in total, payable within 45 days. No market restriction was imposed.

The record does not show whether the penalties were paid or appealed, or whether the Agarwals responded to SEBI's queries beyond what the order summarises. The wider fund flows among the other allottees are the subject of separate orders.

This library tags the matter as no specific technique, because the finding is a funded preferential allotment rather than one of the library's trading methods. 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.

Timeline

  1. 2022-07-27 SEBI adjudication order (27 July 2022)

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

The linked release is published by the issuing regulator under its own terms. Our summary and narrative above are our own writing.

Record added October 8, 2026. submit a correction.