SEBI v. Divya Agarwal and others (price manipulation, Sulabh Engineers, remand order, 2023)

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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On remand from the Securities Appellate Tribunal, SEBI's chief general manager in January 2023 re-examined 32 people tied to a scheme that allegedly pushed up the price of Sulabh Engineers and Services Ltd. The order restrained 24 of them from the securities market for three years, took no further step against 3, and disposed of the notice against 5.

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

This order is a rehearing of an earlier SEBI case over trading in the shares of Sulabh Engineers and Services Ltd on the BSE between December 2011 and January 2015. SEBI's investigation began with a reference from the income tax investigation wing in Kolkata and covered 150 entities. A September 2020 order by a whole-time member had restrained 102 of them. The Securities Appellate Tribunal then sent about 20 appeals covering 32 people back for fresh consideration, particularly to test whether these people's trades resembled those of other preferential allottees who had been cleared.

SEBI's case, set out in a 2017 show cause notice, was that new promoters took over the company, held almost the whole free float through connected entities, and then used tiny sell orders priced above the last traded price, delivery defaults, and later connected buying to lift the price many times over. It alleged the connected entities supplied most of the upward price movement in three phases, and that promoters, directors and others sold shares at the inflated prices. The notice invoked section 12A of the SEBI Act and Regulations 3 and 4 of the fraud-on-the-market rules.

On remand the chief general manager sorted the 32 noticees by what their own trades showed. He restrained 24 for three years from accessing the securities market, dealing in securities or being associated with it, freezing their holdings during that period and crediting the roughly 19 months already served under the 2020 order. For three noticees he treated the earlier debarment as enough, and for five others, including one whose link to the promoters he found not established, he disposed of the notice without a further direction.

The order imposes no monetary penalty. It records the profits of some noticees in the findings, including a figure of about Rs 9.9 crore for one noticee who traded in the later phase, but does not order disgorgement. It states that it does not prevent other SEBI action.

The record does not show whether the restrained noticees appealed again to the Tribunal, nor does it set out the final position of the other 118 noticees from the original case. It describes no criminal case.

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. 2023-01-27 SEBI order on remand from the Securities Appellate Tribunal

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.