SEBI v. Bharat Babubhai Trivedi (Midvalley Entertainment IPO, 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 June 2023, after the Securities Appellate Tribunal sent the case back for a fresh hearing, a SEBI adjudicating officer again fined Bharat Babubhai Trivedi Rs 5,00,000 for trading in Midvalley Entertainment shares funded by money traced from the company's IPO proceeds in early 2011.

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

500k 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 14 June 2023 by Amit Kapoor, a SEBI adjudicating officer. The sole noticee is Bharat Babubhai Trivedi. The company is Midvalley Entertainment Ltd, which listed on BSE on 27 January 2011 after an IPO at Rs 70 a share. The stock fell to about Rs 50.50 by 10 February 2011 and then rose to a high of Rs 99.15 on 25 February 2011, and SEBI investigated 27 January to 28 February 2011.

An earlier adjudication order of May 2022 had fined him Rs 5,00,000, but the Securities Appellate Tribunal quashed it in May 2023 for want of a proper hearing and sent the matter back. The officer heard it afresh on 5 June 2023, with the noticee arguing that the show cause notice came more than six years late, that he did not know where the money in his account came from, and that a lower penalty regime applied to the old conduct.

SEBI's case, as summarised in the order, is that the IPO money earmarked for cinema digital equipment was instead moved to a company with almost no assets, Aman Tie-Up, which was connected to the IPO's merchant banker. It was then passed through a chain of intermediary firms to 14 entities that traded in the stock, including Mr Trivedi, who received Rs 1 crore. The order treats this as funding for trading that supported the price after a weak listing.

The adjudicating officer rejected the delay argument, noting that investigation started in 2012 and was held up by non-cooperating entities, and held the PFUTP violations proved, including the provisions on a false appearance of trading, payment to induce dealing and price manipulation. The penalty was again Rs 5,00,000 under section 15HA, with no bar or disgorgement.

The order finds no quantified gain or investor loss. The record does not show whether he appealed again, whether the sum was paid, or how the other thirteen recipients were treated, since proceedings against them were separate.

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. 2023-06-14 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.