SEBI v. Kajalben Kiranbhai Trivedi and others (Cosyn, Tera Software, Flex Foods and Jubilant Industries, 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.

Report an error in this record (sebi-72197-wash-trading-2023) by email

In May 2023 a SEBI adjudicating officer found that three traders pushed up last-traded prices in small-cap stocks with small orders in 2015 and 2016, and that a brokerage firm also traded against itself in Jubilant Industries. The four noticees were fined Rs 5 lakh, Rs 7 lakh, Rs 6 lakh and Rs 12 lakh, Rs 30 lakh in all.

The record

What was ordered

Civil penalty

—

Disgorgement

—

Prejudgment interest

—

Total relief

—

Alleged gain

—

Penalty as published

3m 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 Amar Navlani, a SEBI adjudicating officer, after earlier appointments of two predecessors. It addresses four noticees: Kajalben Kiranbhai Trivedi, Rachita Shripalkumar Shah, Shripal Sheshmal HUF and MBL & Co. Ltd, in four stocks: Cosyn Limited, Tera Software Limited, Flex Foods Limited and Jubilant Industries Limited. The investigation periods differed by stock and fell between December 2015 and November 2016.

SEBI alleged that each of the first three noticees contributed more than 5 per cent of the positive last-traded-price movement in their stocks by placing small orders, and that MBL & Co. did the same in Jubilant Industries and also executed self-trades. It alleged breaches of section 12A of the SEBI Act and the PFUTP Regulations, including the provisions on a false appearance of trading and on price manipulation.

For the periods concerned, the price of Cosyn rose from Rs 53.15 to Rs 151.55, Tera Software and Flex Foods rose more modestly, and Jubilant Industries rose from Rs 177.50 to Rs 302.65 during a seventeen-day period. The order records that MBL & Co. executed 1,426 self-trades in the stock and that a number of them raised the price. It also notes that one noticee accepted that she had lent her trading account to another person, which the adjudicating officer did not treat as a defence.

The order finds the allegations established and imposes penalties under section 15HA of the SEBI Act of Rs 5,00,000 on Ms Trivedi, Rs 7,00,000 on Ms Shah, Rs 6,00,000 on Shripal Sheshmal HUF and Rs 12,00,000 on MBL & Co., which had a previous penalty for similar conduct. The total is Rs 30 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 the traders' profits, whether any noticee appealed or paid, or who actually controlled the accounts used.

This library tags the matter as price manipulation, with self-trades (wash trading) by one noticee. 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.
• Wash trading — 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.