SEBI v. Mainak Comtrade Pvt Ltd and others (Dhyana Finstock, whole-time member order, 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, SEBI whole-time member S.K. Mohanty reaffirmed in December 2022 that thirty entities took part in a scheme around Dhyana Finstock shares, declined to add further market bars because they had already been debarred, and ordered eighteen of them to disgorge a total of about Rs 1.28 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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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.

What is alleged to have happened

Whole-time member S.K. Mohanty of SEBI issued this order on 5 December 2022. It follows a Securities Appellate Tribunal ruling of 10 June 2022 in Appeal 448 of 2020 which sent the matter back as to 30 noticees, and it is the market-regulatory counterpart of an adjudication order issued five days earlier in the same matter, which dealt with money penalties. The lead noticees are Mainak Comtrade Private Limited and Pranatpal Tradelink Private Limited, with 28 other mostly individual noticees.

The tribunal had considered an earlier SEBI order of 29 July 2020 which debarred noticees and ordered disgorgement. Its remand turned on arguments that 17 noticees each contributed under one per cent of the upward price movement, and that 13 others did not move the price at all. SEBI's case was that cumulatively these noticees accounted for most of the positive price movement during the period, and that the group provided an exit to preferential allottees whose shares had been allotted in a manner the tribunal itself had called fraudulent.

The member rejected the arguments for exoneration. He treated the earlier findings, which the tribunal had accepted on the facts, as sufficient to show violations of the SEBI Act and the PFUTP Regulations, and declined to follow a different earlier SEBI order, Nikki Global, which had cleared minor contributors, saying it turned on its own facts. Because the noticees had already served market debarments under the 2016 interim order and the 2020 order, no further debarment was directed.

The order directs 18 noticees (including Pranatpal Tradelink and sixteen individuals) to disgorge unlawful gains stated per person, ranging from about Rs 3.70 lakh to about Rs 10.31 lakh and totalling about Rs 1.28 crore with interest accrued, to be taken from retained BSE pay-outs. No monetary penalty is imposed in this order.

The record does not show whether the order was appealed again, whether the sums were transferred in full, or how the nine other noticees who were not ordered to disgorge are treated. 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. 2022-12-05 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.