SEBI v. Kailash Kumar Lakhani and others (last-traded-price pushing, Surabhi Chemicals, 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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A SEBI adjudicating officer fined four connected individuals a combined Rs 6 lakh for trading in Surabhi Chemicals & Investments shares on the BSE in a way that the order finds lifted the share's last traded price. The penalty is payable only depending on the outcome of a pending Supreme Court appeal.

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

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Penalty as published

600k 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 adjudicating officer of the Securities and Exchange Board of India decided the matter on 28 July 2022. The noticees were Kailash Kumar Lakhani and Saroj Devi Lakhani, and Abhisek Bhutra and Gita Devi Bhutra, two pairs of individuals who SEBI said were linked by shared client-registration details. The shares concerned were those of Surabhi Chemicals & Investments Limited (later renamed Superspace Infrastructure Ltd), listed on the BSE.

SEBI's investigation covered August 2013 to January 2015 and singled out a stretch in which the price rose from about Rs 6 to about Rs 38 after a share split. SEBI alleged that each pair repeatedly entered small sell orders, often as the first trade of the day, that executed against large buy orders resting above the last traded price. Each such trade nudged the last traded price upward, and the order records that the pairs together accounted for a substantial share of the stock's positive price movement in that stretch.

The adjudicating officer found that this pattern created a misleading appearance of trading and was a fraudulent act under the SEBI Act and the PFUTP Regulations. Having weighed the gravity of the conduct, he treated the long delay since 2013 as a mitigating factor.

Under section 15HA of the SEBI Act the order imposes Rs 4,00,000 jointly and severally on the first pair and Rs 2,00,000 jointly and severally on the second pair, Rs 6,00,000 in all. The order says the penalty becomes payable only once the Supreme Court decides SEBI's appeal against a Securities Appellate Tribunal order of 14 June 2021 in a related line of authority, after which recovery under section 28A can follow if payment is not made within 45 days.

The record does not show whether the noticees appealed this order, whether any amount has been paid, or what profit or loss resulted. No restraint on market access was imposed, and the order describes no criminal case.

This library tags the matter as price manipulation by pushing up the last traded price. 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.

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

Timeline

1. 2022-07-28 SEBI adjudication 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.