SEBI v. Nimi Enterprises and others (order-book spoofing, 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 April 2023 a SEBI whole-time member found that a partnership firm repeatedly placed large, away-from-market orders it then cancelled after small opposite-side orders executed, across 16 scrips on 58 scrip days. The order disgorges Rs 52.55 lakh of gains with interest, bars the firm for two years and its people for a year, and fines the four noticees Rs 25 lakh in total.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

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Total relief

—

Alleged gain

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Penalty as published

2.5m 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

SEBI's whole-time member S. K. Mohanty issued this order on 28 April 2023. The noticees are the partnership firm Nimi Enterprises, its partners Dilip Talakshi Vora and his daughter Nishi Dilip Vora, who was also an authorised person of the broker Edelweiss, and Rohit Bhawanji Chheda, a dealer on her terminal. The investigation covered 1 July 2017 to 28 February 2018.

SEBI alleged a repeated pattern. Early in the session the firm placed a large, fully displayed order on one side at a price well away from the market, then placed a smaller opposite-side order near the market price, and cancelled the large order once the small one had executed. The show cause notice said this happened in 16 scrips over 58 scrip days, that buy orders were inflated by about 4.22 crore shares and sell orders by about 3.12 crore, and that the large orders sat 6 per cent to 28 per cent from the market. The alleged violations were of section 12A of the SEBI Act and the PFUTP Regulations.

The order finds the charge proved: the large orders created a false impression of demand or supply and the firm earned profits of Rs 52.55 lakh from the small orders. It notes that the noticees' only defence was a thin claim that the trades were genuine, and treats Ms Vora as having acted with the firm through her broker role.

The directions bar Nimi Enterprises from the securities market for two years and each of the other three for one year, with Ms Vora's bar limited to her own proprietary account. The first three must jointly and severally disgorge Rs 52.55 lakh with simple interest at 9 per cent a year from 28 February 2018. Penalties under section 15HA are Rs 10 lakh for the firm and Rs 5 lakh each for the other three, Rs 25 lakh in all.

The order is an administrative sanction, not a criminal judgment, and the record shows no criminal case. It does not show whether the noticees appealed, whether the sums were paid, or whether the broker faced its own proceedings.

This library tags the matter as spoofing and layering of the order book. 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.

• Spoofing — see how it works, what statute it engages, and every other action tagged the same way.
• Layering — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2023-04-28 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
• 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.