SEBI v. Om Hari Mahabir Halan HUF and others (Shree Global Tradefin, synchronised trades, 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.
In April 2023 a SEBI adjudicating officer found that five connected noticees executed synchronised trades with each other in Shree Global Tradefin Ltd shares on BSE, creating a false appearance of trading without a real change of ownership. They were jointly and severally fined Rs 5,00,000.
The record
| Agency | SEBI (India) |
|---|---|
| Date filed | 2023-04-28 |
| Date resolved | 2023-04-28 |
| Court | SEBI adjudicating officer |
| Status | judgment |
| Asset class | equities |
| Instruments | Shree Global Tradefin Ltd shares |
| Venue | BSE |
| Criminal parallel | No |
| Defendants | Om Hari Mahabir Halan HUF ; Vanshika Om Hari Halan ; Harshit Pavankumar Halan ; Ayushi Hansraj Halan ; Naresh Saraaf |
| Techniques | Matched orders , Wash trading |
What was ordered
- Civil penalty
- —
- Disgorgement
- —
- Prejudgment interest
- —
- Total relief
- —
- Alleged gain
- —
- Penalty as published
- 500k INR
What is alleged to have happened
This adjudication order was issued on 28 April 2023 by Soma Majumder, a SEBI adjudicating officer. The five noticees are Om Hari Mahabir Halan HUF, Vanshika Om Hari Halan, Harshit Pavankumar Halan, Ayushi Hansraj Halan and Naresh Saraaf. The shares concerned are those of Shree Global Tradefin Ltd, listed on BSE. The investigation period ran from 15 April to 16 September 2021, during which the price first rose from about Rs 2.80 to about Rs 9.50 and then fell back.
SEBI alleged that the noticees matched trades among themselves in synchronised fashion, with the intention of creating a false and misleading appearance of trading, without any intention to change beneficial ownership. It relied on common addresses in exchange client records, telephone call records and bank transfers to show that they were connected, and on the exchange trade log to show that buy and sell orders were placed within a minute of each other.
The first four noticees answered together and argued, among other things, that their orders were placed by telephone through a broker, that the counterparty broker differed, that the orders were minutes apart, that no price manipulation or investor loss was alleged, and that fraud needs a higher standard of proof. The fifth noticee said he was an unconnected seller and that a friendly relationship proved nothing. The adjudicating officer rejected these points, held that brokers act on client instructions, applied the preponderance-of-probabilities test used by the Supreme Court and found that the synchronised trades induced investors to trade.
The order finds breaches of section 12A(a), (b) and (c) of the SEBI Act and the PFUTP Regulations 3(a) to (d), 4(1) and 4(2)(a), and imposes a single penalty of Rs 5,00,000 under section 15HA, payable jointly and severally by all five within 45 days. No market bar or disgorgement was ordered.
The record does not show the number or value of the synchronised trades, whether any noticee appealed or paid, or whether any criminal case followed. This is a monetary penalty, not a criminal judgment.
This library tags the matter as matched orders, with elements of wash trading. 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.
- Wash trading — see how it works, what statute it engages, and every other action tagged the same way.
Timeline
- 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.
Related actions
Other actions in the library sharing at least one technique tag with this one.
| Action | Agency | Filed | Technique | Penalty | Status |
|---|---|---|---|---|---|
| SEBI v. Usha Devi and others (price and volume manipulation of DU Digital Technologies, 2025) | SEBI (India) | 2025-12-31 | Price Manipulation , Matched Orders +1 | — | judgment |
| SEBI v. Panchal Shanti Lal (alleged reversal and synchronized trades, Swan Energy, 2025) | SEBI (India) | 2025-09-17 | Matched Orders , Wash Trading | — | dismissed |
| SEBI v. Vijay Pujara and others (synchronized and circular trades, Kavit Industries, 2025) | SEBI (India) | 2025-02-28 | Matched Orders , Wash Trading | — | judgment |
| SEBI v. Rajendra D. Shah and 35 others (NIFTY index options trades, 2024) | SEBI (India) | 2024-08-30 | Matched Orders , Wash Trading | — | judgment |
| SEBI v. Jayesh Rawal and others (Generic Engineering Construction and Projects, 2023) | SEBI (India) | 2023-08-10 | Price Manipulation , Matched Orders +1 | — | judgment |
| SEBI v. Divyaben Hiteshbhai Gangani and others (Kapil Raj Finance Ltd, circular trades, 2023) | SEBI (India) | 2023-06-16 | Wash Trading , Matched Orders | — | judgment |