SEBI v. Sushil Agarwal and others (Steel City Securities Ltd, synchronised trades, 2023)
Dismissed
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 July 2023 a SEBI adjudicating officer dropped allegations that a married couple traded among themselves in Steel City Securities shares to create false volume, and that their broker facilitated it. Forty-two synchronised trades over 36 days, 0.77 per cent of volume, were held too sparse to induce others to trade.
The record
| Agency | SEBI (India) |
|---|---|
| Date filed | 2023-07-27 |
| Date resolved | 2023-07-27 |
| Court | SEBI adjudicating officer |
| Status | dismissed |
| Asset class | equities |
| Instruments | Steel City Securities Ltd shares |
| Venue | NSE |
| Criminal parallel | No |
| Defendants | Sushil Agarwal ; Seema Agarwal ; Steel City Securities Limited |
| Techniques | Matched orders |
What was ordered
- Civil penalty
- —
- Disgorgement
- —
- Prejudgment interest
- —
- Total relief
- —
- Alleged gain
- —
What is alleged to have happened
This adjudication order was issued on 27 July 2023 by Amit Kapoor, a SEBI adjudicating officer. The noticees are Sushil Agarwal, Seema Agarwal and the stockbroker Steel City Securities Limited, whose own shares were the subject. They were listed on the NSE SME platform from February 2017 and moved to the main board in June 2019. The investigation period ran from 18 July 2017 to 22 July 2019, with the price rising from about Rs 58.70 to about Rs 147 by October 2017 and then falling.
SEBI alleged that the two individuals and their son, who has since died, traded among themselves in synchronised fashion to create false or misleading volume, in breach of section 12A of the SEBI Act and the PFUTP Regulations, and that the broker facilitated the synchronised and reversal trades in breach of its code of conduct. The show cause notice of April 2023 identified 42 synchronised trades over 36 trading days, all in the price-fall patch, and reversal trades on four days.
The adjudicating officer accepted that the buy and sell orders were for the same quantity and placed within moments of each other, but found that the trades were scattered, averaging one a day on the 36 days with a maximum of three, and totalled 84,000 shares, only 0.77 per cent of the 1,08,86,415 shares traded over the investigation period. The reversal trades were 1.37 per cent of volume. The order concluded these were too few to induce others to trade, and that fraud was not established.
Because the individuals were regular traders in 86 and 312 scrips respectively, with no default, there was nothing to make the broker suspicious among its 18,696 clients, so the broker's code-of-conduct charge also failed. The show cause notice was disposed of without penalty.
The record does not show whether SEBI appealed. This is a dismissal of an allegation, not a finding of manipulation, and the order records no gain or loss.
This library tags the matter as matched orders; the allegation was not sustained. 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.
- Matched orders — see how it works, what statute it engages, and every other action tagged the same way.
Timeline
- 2023-07-27 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. Shreedhar Yellaiah Kodam (synchronized trades, Well Pack Papers, 2026) | SEBI (India) | 2026-09-22 | Matched Orders , Price Manipulation | — | dismissed |
| SEC v. Corey Ortiz (free riding and parking, 2026) | SEC | 2026-09-03 | Free Riding And Parking , Matched Orders | — | judgment |
| SEBI v. Hanif Shekh and others (price and volume manipulation in five scrips, Mauria Udyog and others, 2026) | SEBI (India) | 2026-06-30 | Matched Orders , Pump And Dump +1 | — | judgment |
| SEC v. Christopher Flagg, Daquan Lloyd and Travis Treusch (free riding and parking, 2026) | SEC | 2026-04-30 | Free Riding And Parking , Matched Orders | — | judgment |
| SEBI v. Harsha Ishvarbhai Solanki and others (trading in ANI Integrated Services, 2026) | SEBI (India) | 2026-02-12 | Price Manipulation , Matched Orders | — | judgment |
| SEBI adjudication orders on illiquid stock options at BSE (2026 batch) | SEBI (India) | 2026-01-05 | Matched Orders | — | judgment |