Market Manipulation. Search

This action was dismissed. The allegations described below were not established. This page is kept online so that the outcome is visible alongside the original filing.

SEBI v. Sulabh Engineers and Services Ltd and others (alleged funding of preferential allotments, 2023)

Dismissed

Checked against the primary document on October 9, 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.

Report an error in this record (sebi-67465-market-abuse-2023) by email

In January 2023 a SEBI adjudicating officer dismissed charges against 43 noticees, including the listed company Sulabh Engineers, that it had funded its own preferential allottees through conduit accounts. The only link was a Rs 1 crore loan that came after the allotments and was repaid with interest.

The record

Structured fields for this action, as recorded in our case library.
Agency SEBI (India)
Date filed 2023-01-23
Date resolved 2023-01-23
Court SEBI adjudicating officer
Status dismissed
Asset class equities
Instruments Sulabh Engineers and Services shares (preferential allotments)
Venue BSE
Criminal parallel No
Defendants Sulabh Engineers & Services Ltd (entity) ; Manoj Kumar Agarwal (individual) ; Krishana Agarwal (individual) ; Ruchi Agarwal (individual) ; Santosh Kumar Agarwal (individual) ; Sandhya Agarwal (individual) ; Santosh Kumar Agarwal HUF (entity) ; Govind Mercantile Pvt Ltd (entity) ; Manish Agarwal (individual) ; Manish Kumar Garg (individual) ; Praveen Kumar Kurele (individual) ; Naveen Kumar Kurele (individual)
Also named elsewhere Sulabh Engineers & Services Ltd is named in 1 other matter
Techniques

What was ordered

Civil penalty
—
Disgorgement
—
Prejudgment interest
—
Total relief
—
Alleged gain
—

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

This adjudication order of 23 January 2023 was made by SEBI adjudicating officer Maninder Cheema. It covers 43 noticees: Sulabh Engineers & Services Ltd, eight promoters, sixteen preferential allottees and eighteen entities said to have been used as conduits. Twelve are named above, so the other 31 are not listed in this record.

SEBI alleged that the company had funded the allottees of two preferential issues, on 28 March 2011 and 23 March 2012, totalling about Rs 19.60 crore, by routing money through conduit accounts, to give a false picture of fresh capital and so defraud investors, in breach of section 12A of the SEBI Act and PFUTP Regulations 3(b) to (d) and 4(1), with penalty proceedings under section 15HA. SEBI's chain began with a Rs 100 lakh transfer by the company to a jeweller, Sona Chandi, on 27 March 2012.

The adjudicating officer held that the chain did not hold. The transfer came a year after the first allotment and four days after the second, and the allottees' application money for the Rs 14 crore second issue had reached the company 13 days before it. He found the Rs 1 crore was a loan by a registered non-bank lender, with interest booked, tax deducted at source and full repayment in October and November 2013. He also found no documents proving the alleged links between noticees, that the notice rested partly on confusing two people with the same name, and that many noticees had shown their transfers were ordinary business.

He concluded that funding of the allotments by the company was not established and that the fraud provisions were therefore not breached, and disposed of the proceedings against all 43 noticees with no penalty. A typing error in the notice, which cited the wrong penalty section, was noted but was not decisive.

The record does not show whether SEBI appealed, or what the actual source of the allottees' money was.

No library technique fits an unproven allegation of funding an issue, so the technique list is empty.

This library tags the matter with no technique and records it as a dismissed fraud allegation. 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.

Timeline

  1. 2023-01-23 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.

The linked release is published by the issuing regulator under its own terms. Our summary and narrative above are our own writing.

Record added October 8, 2026. submit a correction.