SEBI v. Rishabh Mahendra Shah and others (Mangalam Industrial Finance, 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 Mangalam Industrial Finance's promoter and managing director and a trader he linked up with ran a funded share-buying arrangement that created artificial volume in 2015, and penalised eight noticees. The case against 22 other noticees was not established.

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

Adjudicating officer Barnali Mukherjee of SEBI issued this order on 29 December 2022 against 30 noticees in the matter of Mangalam Industrial Finance Limited, listed on BSE since 21 March 2014. The company was tiny, with net sales of about Rs 0.16 to 2 crore over three years, and its share price went from Rs 32.05 to Rs 287.80 between March 2014 and January 2015 on very thin volume.

SEBI divided the period into three phases. In the second, from 28 January to 26 August 2015, the price stayed in a narrow band while average daily volume rose about thirty times. SEBI alleged that the company's promoter and managing director, Pradeep Kumar Daga, and Rishabh Mahendra Shah arranged for Mr Shah to buy shares from entities connected to Mr Daga, with the purchases funded by other entities connected to Mr Daga, so that the shares could then be pledged to raise funds for Mr Daga. Mr Shah was the largest buyer and Guide Dealcom LLP the largest seller.

The officer found the allegation established against noticees 1 to 8: Mr Shah and Mr Daga as the people who devised the scheme, and the six seller and funding entities as facilitators. The finding rests on connection evidence, call recordings and WhatsApp messages supplied by Mr Shah, bank statements and an email trail. The order says the scheme could not be carried out in full, but that it still created significant artificial volume, with Mr Shah and three seller entities accounting for 17.1 per cent of market volume in the second phase.

The charge against a ninth noticee was dismissed because no link to the others was shown and his buy orders followed sell orders. The remaining 21 noticees, who had traded circularly with counterparties, got the benefit of doubt as no connection, meeting of minds or synchronised pattern was shown. Penalties under section 15HA were imposed on noticees 1 to 8. The penalty table lists Rs 15,00,000 each for Mr Shah and Mr Daga and Rs 10,00,000 each for the six entities, a total of Rs 90,00,000 by the figures, but the words printed beside the ten-lakh entries read 'Fifteen Lakh', so this record does not state a total.

The record does not show whether the penalties were paid or appealed, or what profit was made. The order notes the scheme was not fully carried out. No criminal case is described.

This library tags the matter as matched orders and 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 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.

• Matched orders — see how it works, what statute it engages, and every other action tagged the same way.
• Price manipulation — 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.