SEBI v. Vijay Pujara and others (synchronized and circular trades, Kavit Industries, 2025)

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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A SEBI adjudicating officer found that three men operated the trading accounts of twenty front entities to create artificial volume in Kavit Industries shares through synchronized, circular and reversal trades. The order imposed penalties of Rs 10 lakh, Rs 6 lakh and Rs 5 lakh, Rs 21 lakh in total.

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

2.1m 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

On 28 February 2025 a SEBI chief general manager acting as adjudicating officer issued an order against Vijay Pujara, Ajay Pujara and Natvarbhai Vegda in the matter of trading in the shares of Kavit Industries Limited, which is listed on the Bombay Stock Exchange. The proceedings arose from an investigation of 1 August to 23 December 2019, a period in which the share price rose from Rs 44 to Rs 93.80, about 113 per cent.

SEBI alleged that the three controlled twenty nominee accounts that traded the stock intraday, producing about 13.04 lakh shares of artificial volume, roughly a quarter of total market volume, through synchronized, circular and reversal trades. The show cause notice of 26 April 2024 relied on points such as third-party mobile numbers registered for the accounts, cash deposits that were forwarded straight to brokers, undelivered summonses, one account holder who said he was paid a small monthly sum to lend his accounts, and matching device identifiers. The charges rested on section 12A(a), (b) and (c) of the SEBI Act and Regulations 3 and 4 of the PFUTP Regulations.

The adjudicating officer found the allegations established and rejected the argument that a penalty is optional once a violation is found. The order says the record shows neither a quantified gain to the noticees nor investor loss, but notes that SEBI had penalised them before for similar conduct and that creating false liquidity harms price discovery.

Under section 15HA of the SEBI Act the order imposed Rs 10,00,000 on Vijay Pujara, Rs 6,00,000 on Ajay Pujara and Rs 5,00,000 on Natvarbhai Vegda, a total of Rs 21,00,000, payable within 45 days. It imposed no market bar.

The record does not show whether any noticee appealed, whether the penalties were paid, or what the trading gain or investor losses were. The order is an adjudication, a civil penalty, and not a criminal conviction.

This library tags the matter as matched orders and wash trading. 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.
• Wash trading — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2025-02-28 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
• 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.