SEBI v. United Polyfab Gujarat Ltd and others (SME board migration price rigging, 2024)

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 29 February 2024 a SEBI adjudicating officer held that United Polyfab Gujarat Ltd and seven connected noticees traded among themselves to lift the share price so the company could move from NSE's SME platform to its main board. It imposed one joint and several penalty of Rs 48 lakh.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

—

Total relief

—

Alleged gain

—

Penalty as published

4.8m 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

The adjudication order of 29 February 2024 involves eight noticees: United Polyfab Gujarat Limited, listed on the SME platform Emerge of the National Stock Exchange, its promoter Gagan Nirmalkumar Mittal, and six connected entities and relatives including Shiv Marketing and Trading, Vishwakarma Trading House, Anilkumar Mittal, Amay Spincot Pvt. Ltd., Aditi Mittal and Dhaval Mittal.

SEBI alleged a plan to satisfy the exchange's conditions for moving to the main board, which require a minimum paid-up capital of Rs 10 crore and a minimum market capitalisation of Rs 25 crore. The company issued bonus shares in February 2021 to meet the capital test, and the connected entities were said to have pushed the price up between August and November 2021 so the average price over the preceding three months would satisfy the market capitalisation test. The company applied for migration on 25 November 2021 and moved to the main board on 30 December 2021.

The order examined the connected entities' trades in two periods. It found that they traded with each other, accounted for large shares of buying and selling volume in some periods, placed orders above the last traded price, and thereby made a large positive contribution to the price rise. It held that the company acted in collusion with the others, and that the charges under section 12A of the SEBI Act and the 2003 fraud and unfair trade practice regulations were established.

On penalty, the order noted that neither the gain nor the investor loss could be quantified, and that the company had received an administrative warning in 2018. It imposed a single penalty of Rs 48 lakh under section 15HA, payable by the eight noticees jointly and severally, with 45 days to pay.

The record does not show whether any noticee appealed, whether the penalty was paid, or what happened to the company's main-board listing. It describes no criminal case.

This library tags the matter as price manipulation and matched orders. 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.

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

Timeline

1. 2024-02-29 SEBI adjudication 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
• 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.