SEBI v. Ilesh Madhusudan Patel and others (SFL International, 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 decided ex parte in December 2022 that thirteen traders manipulated the price of the illiquid SFL International in 2016-17, mainly through tiny buy orders and first trades that lifted the last price, and through matched buying and selling. Penalties of Rs 5 or 10 lakh each totalled Rs 80 lakh.

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

8m 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 29 December 2022 over trading in SFL International Limited, listed on BSE, between 30 December 2016 and 14 July 2017. The thirteen noticees were Ilesh Madhusudan Patel, Nilesh Rameshchandra Shah, Kalpesh Dineshbhai Patel, Shital Navnitbhai Chokshi, Rahul D Shah, Maltiben Lalitbhai Gandhi, Nishant Rajivkumar Sheth, Pahadsinh Dolatsinh Sisodiya, Active Nirman Private Limited, Sumangal Vintrade Pvt. Ltd., Viewpoint Advisory Private Limited, Sairabanu Fanaswala and Sunilkumar Bhikhabhai Nayi.

SEBI alleged breaches of section 12A of the SEBI Act and regulations 3 and 4 of the PFUTP Regulations 2003. Only one noticee replied to the show cause notice, and notice to several others was given through newspaper publication, so the officer decided on the record. The order is lengthy and I have read the findings and directions, not every table.

The officer held that noticees 1 to 7 manipulated the price and created a misleading appearance of trading through small trades. In the first phase, four first trades of the day by a suspected group, including noticees 1 to 4, accounted for Rs 5.85 of the Rs 9.95 of positive price movement from first trades. The eighth noticee was found to have placed buy orders of between one and ten shares when larger sell orders were already available, and sometimes above the offered price, showing no genuine intention to buy. Noticees 9 to 13 were held, as buyers and sellers, to have acted together to create artificial volume in the illiquid stock through matched trades.

Under section 15HA the officer imposed Rs 10,00,000 each on noticees 1, 2 and 3 and Rs 5,00,000 each on the other ten, Rs 80,00,000 in all, noting that no gain or investor loss was quantified.

The record does not show whether any noticee paid or appealed, and several were served only by publication. No criminal case is described.

This library tags the matter as price manipulation and matched orders. 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 2 techniques 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.
• Matched orders — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2022-12-29 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.

• 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.