SEBI v. Mainak Comtrade Pvt Ltd and others (Dhyana Finstock, adjudication, 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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On remand from the Securities Appellate Tribunal, a SEBI adjudicating officer again penalised thirty entities in November 2022 over trading in Dhyana Finstock in 2014-15, finding they gave an exit to preferential allottees and nudged the price up. Penalties of Rs 5 to 22 lakh each totalled Rs 1.97 crore.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

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Total relief

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Alleged gain

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Penalty as published

19.7m 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

Adjudicating officer N. Hariharan of SEBI issued this order on 30 November 2022. It concerns 30 of 81 entities that had been penalised in an August 2020 adjudication order about trading in Dhyana Finstock Limited between 13 June 2014 and 27 July 2015. The Securities Appellate Tribunal set that order aside as to these 30 on 10 June 2022 and sent the matter back for a fresh decision after a hearing. The lead noticees are Mainak Comtrade Private Limited and Pranatpal Tradelink Private Limited, with a large group of individuals, many apparently related.

SEBI alleged that the company and entities connected to it made preferential allotments of shares to seven allottees for which no real consideration had been received, and that the noticees then bought those shares from the allottees in volume, giving them an exit at inflated prices, while some also pushed up the last traded price and set new highs. The tribunal's earlier ruling had already described the preferential allotment as fraudulent. The charges were under section 12A of the SEBI Act and regulations 3 and 4 of the PFUTP Regulations 2003.

The officer held that Mainak Comtrade, a company-connected entity, took part in the fraudulent allotment, and that Mainak and Pranatpal had funded other noticees. Seventeen noticees were held to have manipulated the price and created a misleading appearance of trading, collectively raising the price although each contributed under one per cent. The remaining 13 did not move the price but bought from the allottees with funds routed from the two companies and so were held to have misled the market. The order also records that nine of the first group made unlawful profits of about Rs 3 lakh to Rs 10 lakh.

Under section 15HA the officer imposed Rs 20 lakh on Mainak Comtrade, Rs 22 lakh on Pranatpal Tradelink, Rs 6 lakh each on 15 noticees and Rs 5 lakh each on 13, which comes to Rs 1,97,00,000. Investor loss was not quantified in the investigation and no earlier violations are on the record.

The record does not show whether these penalties were paid or challenged again before the tribunal, and no market bar or disgorgement is in this order. A separate whole-time member order in the same matter is not part of this record. No criminal case is described.

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. 2022-11-30 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.