SEBI v. Madhukar Dubey (HPC Biosciences IPO funding scheme, 2024)
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; 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.
On 29 February 2024 a SEBI adjudicating officer, after a tribunal remand, again penalised Madhukar Dubey and his three proprietorship firms Rs 10 lakh for helping fund applicants so that the 2013 IPO of HPC Biosciences appeared fully subscribed.
The record
| Agency | SEBI (India) |
|---|---|
| Date filed | 2024-02-29 |
| Date resolved | 2024-02-29 |
| Court | SEBI adjudicating officer |
| Status | judgment |
| Asset class | equities |
| Instruments | HPC Biosciences Ltd. shares offered in its IPO |
| Venue | BSE SME |
| Criminal parallel | No |
| Defendants | Madhukar Dubey ; N V Sales Corporation ; Magnum Industrial ; Alliance Traders |
| Techniques |
What was ordered
- Civil penalty
- —
- Disgorgement
- —
- Prejudgment interest
- —
- Total relief
- —
- Alleged gain
- —
- Penalty as published
- 1m INR
What is alleged to have happened
SEBI adjudicating officer Amar Navlani issued this order on 29 February 2024. The noticee is Madhukar Dubey together with his proprietorship firms N V Sales Corporation, Magnum Industrial and Alliance Traders. A February 2022 order had penalised thirteen noticees a combined Rs 1.56 crore, including Rs 10 lakh for him, but the Securities Appellate Tribunal quashed it as to him in August 2023 because no show cause notice had been served, and sent the matter back.
The case arose from SEBI's inquiry into the initial public offering of HPC Biosciences Ltd., which raised Rs 15.75 crore at Rs 35 a share and listed on the BSE SME platform on 19 March 2013. SEBI had restrained 254 entities in an interim order of June 2015. It alleged that the company, its promoters and a group of funders ran a scheme to reach the minimum subscription needed for listing, with about 29 percent of the allotted shares, 1,324,000 of 4,560,000, taken up by applicants who were funded by that group rather than genuinely subscribing. It also alleged misleading statements in the prospectus about the use of the proceeds.
The officer found that the noticee was part of the funding group and party to the arrangement, and held that this breached Regulations 3(a)-(d) and 4(1) of the PFUTP Regulations 2003 and section 12A of the SEBI Act. No gain or loss was quantified, but the officer noted penalties against him in three other IPO matters.
The penalty was Rs 10 lakh under section 15HA, payable within 45 days. No market restriction was imposed in this order.
The record does not show whether he appealed again or paid, or the outcome for the other twelve noticees on remand. Other SEBI IPO-funding orders are catalogued separately.
This library does not assign a technique tag to the matter, because no technique in the library fits the conduct. 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.
Timeline
- 2024-02-29 SEBI adjudication order on remand
Primary documents
Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.