SEBI v. Gokul Solutions Ltd and others (matched trades, 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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On 8 September 2023 a SEBI executive director found that Gokul Solutions, two directors and six connected entities manipulated the price of its thinly traded BSE SME shares through matched trades between 2014 and 2018. Each of the nine was penalised Rs 5,00,000 and restrained for six months, and six had to disgorge gains of about Rs 2.28 crore.

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

4.5m 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 executive director issued this final order on 8 September 2023 against nine noticees: Gokul Solutions Limited, its directors Sanjay Kumar Agarwal and Sunita Agarwal, and six companies, among them Arrowline Distributors, Aryavrat Suppliers, Metrocity Suppliers and three Sourav companies. The shares were listed directly on the SME platform of BSE in December 2014.

The matter began with a February 2018 complaint and a BSE examination. SEBI investigated trading from December 2014 to February 2018, when the price went from Rs 38 at listing to Rs 349, although the company made no announcements and its profits were falling to a small loss. SEBI alleged that a connected group bought shares placed at rising prices by others in the group, lifting the last traded price.

The order finds that the connected entities executed 83 trades among themselves in the shares, 5,95,450 shares worth Rs 12.54 crore, adding Rs 256 or 67.54 percent of the market's total upward price movement. Buy and sell orders were entered with almost the same limit prices and between 3 seconds and about 6 hours apart. It concluded the six sellers made gains of Rs 2.28 crore by selling at manipulated prices to connected buyers, and that the company and its two directors, who handled the preferential allotments, enabled it.

SEBI restrained all nine from the securities market for six months and froze their holdings in that period. It directed the six sellers to disgorge the individual amounts in its table, with interest at 12 percent a year from 9 December 2014, and imposed a Rs 5,00,000 penalty on each of the nine under section 15HA of the SEBI Act, Rs 45,00,000 in total.

The record does not show whether any noticee appealed. Several noticees delayed the proceedings, which the order says it took into account. The order mentions no criminal case.

This library tags the matter as matched orders and 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 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.

• Matched orders — see how it works, what statute it engages, and every other action tagged the same way.
• Price manipulation — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2023-09-08 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.