SEBI v. Manash Das and others (Angels Enterprises Limited, connected-entity trading, 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.

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On 29 March 2023 a SEBI adjudicating officer disposed of proceedings against 17 noticees accused of manipulating the share price of Angels Enterprises Limited through connected-entity trades in 2015, finding the fraud charges not established and imposing no penalty.

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

—

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

A SEBI adjudicating officer, Barnali Mukherjee, issued this order on 29 March 2023 under section 15-I of the SEBI Act. The 17 noticees were a group of small companies that had traded in the shares of Angels Enterprises Limited and the directors of several of them, many of the companies having since been struck off the register of companies.

SEBI's investigation covered 11 July 2014 to 15 June 2015. It alleged that nine connected entities had traded among themselves between 17 March and 2 June 2015, a period in which the share price roughly doubled from Rs 5 to Rs 10. It said their ten trades, including trades at higher prices than the prevailing market, accounted for Rs 1.43 of positive last-traded-price movement, about 19 percent of the market total. SEBI therefore charged breaches of Regulations 3 and 4 of the PFUTP Regulations 2003 and section 12A of the SEBI Act, with penalty sought under section 15HA, and treated the directors as answerable for the struck-off companies under the Companies Act.

The order records that one director had died, so proceedings against him were abated without a ruling on the merits, and that two struck-off companies had their notices discharged. For the remaining noticees the officer examined whether the entities were connected and whether the trading showed a manipulative pattern. Relying on appellate and Supreme Court authority that trading in an illiquid scrip is not manipulative absent a proved nexus or meeting of minds, the officer found no sufficient link between the entities and no manipulative pattern in their trades.

The allegations of violating the PFUTP Regulations were held not established, the benefit of the doubt was given, and the show cause notice was disposed of without any penalty. No money was ordered and no restriction was imposed.

The record does not show whether SEBI appealed, whether anyone gained from the price rise, or what became of the underlying investigation beyond this order.

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. 2023-03-29 SEBI adjudication order (proceedings disposed of without penalty)

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
• SEBI order (PDF)

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.