SEBI v. Brij Bhushan and others (synchronised trades and bulk-SMS exit, Srestha Finvest, 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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In February 2023 a SEBI adjudicating officer penalised six people a combined Rs 27 lakh over trading in Srestha Finvest Ltd shares in February 2018, when bulk text messages urged investors to buy the thinly traded stock. The order found that four created artificial volume that let shareholders sell, and two raised the price with small purchases above the last price.

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

2.7m 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

Srestha Finvest Ltd was a thinly traded BSE stock. In February 2018 bulk SMS messages recommended buying it at the upper circuit price, and BSE reported the pattern to SEBI. Between 5 and 27 February 2018 the price rose from Rs 12.25 to a high of Rs 15.93. The top net sellers in that period, including Brij Bhushan and Mahaveer Yeswanti Bai, were also small shareholders in the company, who between them sold some 6.2 lakh shares, around 24 per cent of market volume.

SEBI named six noticees. The notice alleged that Mr Brij Bhushan, his relative Mr Parth Bhushan, Mrs Kalpna Ajaykumar Min and Mr Yeswanti Bai created a misleading appearance of trading and artificial volume. It said that on the first day of the messages Mr Brij Bhushan sold about 1.36 lakh shares, to buyers including Mrs Min and the two other noticees, and that shares were then passed back to him indirectly through Mr Parth Bhushan. It alleged separately that Ashwin Jamnudas Merchant and Ramavadh Jangu Yadav, by a handful of purchases above the last traded price, supplied over 80 per cent of the market's positive price movement and so manipulated the price.

The adjudicating officer rejected the argument that screen-based trading and anonymous counterparties meant there was no manipulative intent, citing the Supreme Court's Kishore Ajmera ruling that preponderance of probabilities is the test and that a meeting of minds can be inferred from the pattern. He held the violations of section 12A of the SEBI Act and Regulations 3 and 4 of the fraud-on-the-market rules established against all six, and found no quantifiable gain or investor loss and no earlier violations.

The section 15HA penalties are Rs 10 lakh jointly and severally on Mr Merchant and Mr Yadav, Rs 7 lakh jointly and severally on Mr Brij Bhushan and Mr Parth Bhushan, and Rs 5 lakh each on Mrs Min and Mr Yeswanti Bai, Rs 27 lakh in all, payable within 45 days. There is no market bar or disgorgement.

The record does not show appeals, payment, who sent the bulk messages, or what became of the other sellers named in the investigation. It describes no criminal case.

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. 2023-02-28 SEBI adjudication 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.