SEBI v. Subodh Agarwal and others (price manipulation, Sulabh Engineers & Services, 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 118-page SEBI adjudication order fined 67 of more than 120 noticees a combined Rs 2.61 crore for a scheme that pushed up the price of Sulabh Engineers & Services shares on the BSE between 2011 and 2015. The penalties range from Rs 1 lakh to Rs 20 lakh each.

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

26.1m 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 30 August 2022. SEBI's investigation of Sulabh Engineers & Services Ltd, covering December 2011 to January 2015, began after the Principal Director of Income Tax (Investigation) in Kolkata wrote to SEBI in April 2015 saying that certain entities had generated bogus long-term capital gains through trades in several scrips, including this one. The order covers more than 120 noticees, among them the individuals Subodh Agarwal, Divya Agarwal and Manoj Kumar Agarwal, the issuer and many family and corporate entities.

SEBI alleged that new promoters took over the company, built up their stake through an open offer and preferential allotment, and kept the free float very small before trading resumed on the BSE. It alleged that connected noticees then traded in patterns that pushed the price up several-fold, and that the promoters and connected entities sold into the higher price.

The adjudicating officer examined whether noticees were connected to the company or its promoters and whether their trades in three stretches of the investigation period breached Regulations 3 and 4 of the PFUTP Regulations. For 67 noticees he found violations established, rejecting contentions such as that sales were small or came after the price had already risen. Others, including some who were not shown to be connected, were not penalised.

The penalties under section 15HA were Rs 20 lakh each on the issuer and seven individuals who were its principal beneficiaries or controllers, Rs 10 lakh each on two noticees, Rs 5 lakh each on five noticees, and Rs 1 lakh each on 51 further noticees, Rs 2.61 crore in total, payable within 45 days.

The record does not show whether anyone appealed, how much the manipulation yielded, or any tax-related outcome. No market bars were imposed and the order describes no criminal case.

This library tags the matter as price manipulation. 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. 2022-08-30 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.