SEBI v. Nafeez Hakeem and others (Generic Engineering Construction and Projects Ltd, 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 May 2023 a SEBI adjudicating officer fined six of twelve noticees Rs 40 lakh in total over manipulative trading among connected entities that lifted the price of Generic Engineering Construction and Projects shares on BSE in 2016 and 2017, and over broker code-of-conduct lapses. The other six noticees were not penalised.

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

4m 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

This adjudication order was issued on 31 May 2023 by Barnali Mukherjee, a SEBI adjudicating officer. It covers twelve noticees in the matter of Generic Engineering Construction and Projects Ltd, listed on BSE, over an investigation period from 4 November 2016 to 20 September 2017. The company's reported revenue jumped from Rs 0.56 crore in the year to March 2016 to Rs 38.56 crore in the year to March 2017.

SEBI identified two groups of suspected connected entities, one of 27 and one of two, linked by client-registration details and off-market transfers, and alleged that the larger group traded among themselves in circular fashion and contributed heavily to positive price movement. It alleged breaches of section 12A of the SEBI Act and the PFUTP Regulations by traders and a sub-broker, and breaches of the stock-broker code of conduct by the brokers and sub-brokers that handled the orders.

The adjudicating officer found the PFUTP violations proved against Nafeez Hakeem, Rajani Dusad, Vijendra Kumar Jain and the sub-broker Anil Dusad, who was held to have facilitated the trades, and found code-of-conduct lapses by the brokers Mehta Equities Ltd and JSEL Securities Ltd and by the sub-broker. The order records that the investigation did not establish any gain to the noticees or loss to investors. The remaining six noticees, including the broker Marfatia Stock Broking and Vijaykumar Natubhai Kapadiya, were not penalised.

Penalties under sections 15HA and 15HB of the SEBI Act were Rs 7 lakh each for the four found to have traded or facilitated manipulative trades, plus Rs 3 lakh under section 15HB for each of Mr Hakeem and Anil Dusad, and Rs 3 lakh each for the two brokers. The total is Rs 40 lakh. No market bar or disgorgement was ordered.

The order is an administrative penalty, not a criminal judgment, and the record shows no criminal case. It does not show whether any noticee appealed or paid, or how the 27 connected entities were disposed of in other proceedings.

This library tags the matter as price manipulation through circular trades among connected entities. 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.

• Price manipulation — see how it works, what statute it engages, and every other action tagged the same way.
• Matched orders — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2023-05-31 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.