SEBI v. Tilak Ventures Limited and others (preferential-issue proceeds, 2023)

Judgment entered

✓ Checked against the primary document on October 9, 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. 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-74463-market-abuse-2023) by email

On 27 July 2023 a SEBI executive director found that Tilak Ventures and its two directors had misused proceeds of two preferential share issues and misrepresented the company's affairs, restraining them for six months, ordering Rs 2.13 crore returned and imposing penalties of Rs 28 lakh in total.

The record

What was ordered

Civil penalty

—

Disgorgement

—

Prejudgment interest

—

Total relief

—

Alleged gain

—

Penalty as published

2.8m 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 final order was issued on 27 July 2023 by SEBI executive director Pramod Rao. The noticees are Tilak Ventures Limited, its managing director Girraj Kishor Agrawal and its director Tanu Girraj Agrawal.

SEBI's investigation looked at two preferential issues of equity shares, made in July 2010 and October 2012, which raised about Rs 16.5 crore and Rs 14.4 crore respectively, and at how the money was then used. SEBI alleged that subscription money was collected from some allottees before the allotments and treated as loans, that large sums were passed to other parties and some were repaid as loans, and that the company's reports and filings misrepresented how the proceeds were used. It alleged breaches of the PFUTP Regulations 2003, the issue-of-capital regulations, and the listing agreement and the listing obligations regulations.

The noticees argued that there was no misutilisation and that the objects had been met. The order found the violations established, held that the two directors had a part in the misrepresentation of the company's affairs, and noted that the delay in starting the investigation and the proceedings was a mitigating factor.

The directions were a six-month restraint from the securities market on all three noticees and a joint order to bring back Rs 2,13,47,647 to the company, money said to have been diverted as loan repayments to three named lenders. Penalties totalled Rs 28 lakh: Rs 14 lakh on the company and Rs 7 lakh on each director, made up of section 15HA, section 15A(b) and SCRA section 23A(a) amounts.

The record does not show whether the money was returned, whether anyone appealed, or what shareholders lost.

This library tags the matter as misleading issuer disclosure. 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.

• Misleading issuer disclosure — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2023-07-27 SEBI executive director final 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
• SEBI 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.