SEBI v. MSS Trading System Centre and Valerian Louis Mendanha (unregistered portfolio management, assured returns, 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.
In August 2022 a SEBI whole time member confirmed a 2020 interim order against a trading-signal business and its proprietor, finding that it ran an unregistered portfolio management service and falsely promised clients assured returns. The order debars the proprietor for at least six months and directs refunds of fees; it carries no monetary penalty.
The record
| Agency | SEBI (India) |
|---|---|
| Date filed | 2022-08-18 |
| Date resolved | 2022-08-18 |
| Court | SEBI whole time member |
| Status | judgment |
| Asset class | equities |
| Criminal parallel | No |
| Bars imposed | Debarred from the securities market for six months, or six months after completing refunds if later, Ordered to refund fees collected from clients within three months, Barred from portfolio management or other securities-market activity without SEBI registration |
| Defendants | MSS Trading System Centre ; Valerian Louis Mendanha |
| Techniques |
What was ordered
- Civil penalty
- —
- Disgorgement
- —
- Prejudgment interest
- —
- Total relief
- —
- Alleged gain
- —
What is alleged to have happened
A SEBI whole time member decided this matter on 18 August 2022 as a final order under sections 11, 11B and 11D of the SEBI Act. The noticee is MSS Trading System Centre and its sole proprietor, Valerian Louis Mendanha, who also acted as an authorised person of the registered broker R.K. Global.
The proceedings grew out of an ad interim ex parte order and show cause notice of 29 July 2020. SEBI alleged that the business offered portfolio management without registration, promised clients assured returns, and collected fees directly from clients although an authorised person may be paid only by the broker. The PFUTP charges were Regulations 3, 4(2)(k) and 4(2)(s)(i) and section 12A of the SEBI Act. The proprietor sought inspection of documents and several adjournments, citing illness and personal difficulty, and argued that the agreements were for software and signals and that no fixed return was promised.
The order rejects that defence. It points to client agreements and statements showing a promised monthly return of Rs 20,000, treats the proprietor's remark that every intermediary promises returns as an admission, and finds that the assurance was false and misleading and was meant to induce clients to sign up. It finds the business breached PFUTP rules 4(2)(k) and 4(2)(s), and that it ran a portfolio management service without registration and took money from about 80 clients in breach of the authorised-person circular of 2009.
The directions are non-monetary. The noticee must refund fees received from clients within three months and publish a public notice on refund modalities, may not sell assets except to fund refunds, and is debarred from the securities market for six months or until six months after refunds are completed, whichever is later. He may not offer portfolio management services or similar activity without registration. The order states that clients keep any other legal remedies.
The record does not show how much money was collected in total or whether refunds were made, whether the order was appealed, or any trading loss to clients. The conduct is investor-facing misrepresentation rather than market price manipulation.
No library technique fits, so the technique list is empty.
This library tags the matter as misleading promises of assured returns by an unregistered adviser, with no more specific library technique. 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
Primary documents
Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.