SEBI v. Henal C Patel and others (Exdon Trading Company, 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 SEBI adjudicating officer found in December 2022 that five connected traders pushed the price of the illiquid Exdon Trading Company from about Rs 14 to Rs 381 in 2014 using single-share trades above the last price. Each was fined Rs 5 lakh, Rs 25 lakh in all.

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

2.5m 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 Asha Shetty of SEBI issued this order on 27 December 2022 over trading in Exdon Trading Company Limited, listed on BSE until trading was suspended in March 2015. The five noticees were Henal C Patel, Keval Chandrakant Shah, Nikunj C Patel, Dhaval Chandrakant Shah and Vishal Pravinbhai Soni. SEBI's investigation covered 2 May 2013 to 3 March 2015.

The order recounts that the share price opened at Rs 1.69 in May 2013, rose from Rs 14 to Rs 381 between May and December 2014 largely through single-share trades, and then trading almost stopped. Only 757 trades occurred in the period, the company had no operating income and was making continuing losses, and its announcements were routine. The price rise ran up to the end of the lock-in on a 2014 preferential allotment in January 2015. SEBI alleged the noticees were connected, that a finance company supplied them with shares by off-market transfer, and that they set the price above the last traded price.

The officer found that the sellers, who were connected with each other, held back supply by offering tiny quantities repeatedly while large buy orders sat in the market, giving a false picture of demand that nothing in the company's business could explain. By trading above the last price they were found to have raised the price and created a misleading appearance of trading. The officer held that the noticee who said a broker traded without his knowledge could not escape, as he had sent money to the broker and passed on shares off-market. All five were found to have breached regulations 3 and 4 of the PFUTP Regulations 2003.

Each of the five noticees was fined Rs 5,00,000 under section 15HA of the SEBI Act, Rs 25,00,000 in all.

The record does not show whether the penalties were paid or appealed, how much the noticees gained, or what happened to the finance company that supplied the shares, which was not a noticee. 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. 2022-12-27 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.