SEBI v. N & N Financial Consultants Pvt Ltd and Novak Exim Overseas Pvt Ltd (alleged false reason on transfer slips, 2022)
Dismissed
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 November 2022 a SEBI adjudicating officer decided that two companies that gave "loan" as the reason on share transfer slips had not committed a fraudulent or unfair trade practice, and that summons non-compliance was not proved. He disposed of the proceedings without penalty.
The record
| Agency | SEBI (India) |
|---|---|
| Date filed | 2022-11-29 |
| Date resolved | 2022-11-29 |
| Court | SEBI adjudicating officer |
| Status | dismissed |
| Asset class | equities |
| Instruments | Delta Leasing & Finance shares (off-market transfers) |
| Venue | BSE |
| Criminal parallel | No |
| Defendants | N & N Financial Consultants Private Limited ; Novak Exim Overseas Private Limited |
| Techniques |
What was ordered
- Civil penalty
- —
- Disgorgement
- —
- Prejudgment interest
- —
- Total relief
- —
- Alleged gain
- —
What is alleged to have happened
This adjudication order of 29 November 2022 was made by SEBI adjudicating officer Maninder Cheema. It is one of several orders SEBI issued in the matter of Delta Leasing & Finance Ltd, a company listed on BSE. The noticees are N & N Financial Consultants Private Limited and Novak Exim Overseas Private Limited.
SEBI alleged that in 2013 the two had moved Delta Leasing shares off-market and described each transfer on the depository instruction slip as a loan or return of a loan. Depositories had confirmed that none of the transfers was a pledge, so SEBI said the stated reason was false and a deceit used to avoid the rule that such spot delivery trades be settled within a set time. That was charged as a breach of PFUTP Regulation 4(1). SEBI also alleged that neither noticee had answered summons.
The adjudicating officer found the summons charge unproved because the record did not show delivery to either company: the email for one had bounced and the address used for the other did not match the address on the client records. On the fraud charge he noted that the wrong reason on a slip was perhaps deceitful in itself but did not interfere with demand and supply, and that nothing showed anyone was induced to deal in the shares or that fairness for the parties or the market had been affected.
He held the PFUTP charge not established and disposed of the proceedings with no penalty. The noticees did not reply to the notice or attend the hearing, and the notice could not be served on the second company at all.
The record does not show whether SEBI appealed or whether any later proceeding followed.
No library technique fits a wrong reason on a transfer slip, so the technique list is empty.
This library tags the matter with no technique and records it as a dismissed fraud allegation. It is a marginal fit for the library. 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
- 2022-11-29 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.