SEBI v. Dinesh Jajodia and others (Geodesic Limited, 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. 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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On 31 July 2023 a SEBI chief general manager found that tax adviser Dinesh Jajodia and two company directors helped Geodesic Limited's directors falsify its accounts through bogus bills from shell companies. Each was penalised Rs 5,00,000 and barred from the securities market for one year.

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

1.5m 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

SEBI's chief general manager issued this order on 31 July 2023 against three noticees in the matter of Geodesic Limited: Dinesh Jajodia, who had been the company's tax consultant and adviser, and Mangiram Sharma and Manoj Sharma, directors of companies that dealt with Geodesic. Earlier action had already been taken against Geodesic's own directors for bogus entries in its 2011-12 accounts and a default on foreign currency convertible bonds.

In 2016 lawyers for holders of the bonds sent SEBI documents pointing to Mr Jajodia's role, which led to a second investigation covering 2008 to 2014 and a further forensic audit. SEBI alleged that the three set up paper companies with no business of their own, issued fake bills for software purchases against commission, and so helped the directors manipulate the accounts, in breach of section 12A of the SEBI Act and Regulations 3 and 4 of the PFUTP Regulations.

The order finds those charges made out on circumstantial evidence: the forensic report, the trail of funds from the Geodesic group through the shell companies to entities controlled by or linked to Mr Jajodia, and statements recorded from the noticees by SEBI and other agencies, which it said contradicted their claims of ignorance. It holds that the false financial statements and annual report misled investors, and that the noticees aided and facilitated the scheme. The notice quantified no unfair enrichment.

SEBI restrained all three from the securities market for one year and from associating with any listed or proposed-to-be-listed company for three years, froze their holdings during the restraint, and imposed Rs 5,00,000 each under section 15HA of the SEBI Act, Rs 15,00,000 in all.

The order notes that proceedings by the Economic Offences Wing and the Enforcement Directorate over the diversion of the bond funds are sub judice; it does not say how far they have gone, and this record does not treat the matter as having a documented criminal outcome. It does not show whether any noticee appealed.

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. 2023-07-31 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

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.