SEBI v. Shailesh Pednekar and others (Cox and Kings Financial Service directors, 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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In December 2022 a SEBI adjudicating officer held two finance officers of Cox and Kings Financial Service Ltd responsible for overstated profit figures published in March 2019, fining each Rs 5 lakh, and found the case not proved against five other directors who signed the same document.

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

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

Adjudicating officer Soma Majumder of SEBI issued this order on 21 December 2022. It is the individual-liability companion to a separate order of 7 December 2022 against Cox and Kings Financial Service Limited itself (CKFSL), whose shares were listed on BSE and NSE from April 2019. The seven noticees were the directors and the chief financial officer who signed the company's information memorandum of 13 March 2019: Vellatu Puthanveetil Ravindran Menon, Sampath Kumar Krishnan, Shailesh Pednekar, Bapi Munshi, Matangi Gowrishankar, Jayesh Shah and Milind Gandhi.

SEBI alleged that the nine-month profit figures to 31 December 2018, published in that memorandum and in a newspaper advertisement of 29 March 2019, were inflated because interest costs had been left out, and that the signatories failed in their duty to see that the financial statements gave a true and fair view. It charged them under section 12A of the SEBI Act and regulations 3 and 4 of the PFUTP Regulations 2003.

The officer relied on the company's own explanation, which the earlier order had accepted as the factual basis: some interest had been missed during a demerger and was corrected in the final quarter, but the incorrect figures were still published in that quarter. Mr Gandhi, the chief financial officer when the documents were published, was held to have known of the misstatement. Mr Pednekar, who had resigned as chief financial officer but stayed an executive director, was shown by emails of March 2019 to have received the December 2018 financials and audit report, and was held to be aware. Both were found to have violated the fraud provisions.

The officer was not satisfied that the other five, who included independent directors, knew of or consented to the misstatements, and found the charge against them not established. The penalty on Mr Pednekar and on Mr Gandhi was Rs 5,00,000 each, Rs 10,00,000 in all. The text of the order cites section 15HA as the basis, while the penalty table refers to section 15HB; this record follows the text. The officer treated the later correction as mitigating and found no quantified gain or investor loss.

The record does not show whether the penalties were paid or appealed. The company itself was in liquidation. No criminal case is described.

This library tags the matter as misleading issuer disclosure. 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.

• Misleading issuer disclosure — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2022-12-21 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.