SEBI v. Shubham Mittal and others (Max Heights Infrastructure share-split proposal, 2025)

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. 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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In September 2025 a SEBI adjudicating officer found that an independent director of Max Heights Infrastructure Limited and connected entities floated a misleading share-split proposal in late 2022 to lift the share price, which the connected entities then sold into. Seven noticees were penalised Rs 10 lakh, jointly and severally, and one entity was let off.

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

—

Penalty as published

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

This adjudication order of 22 September 2025 concerns trading in the shares of Max Heights Infrastructure Limited (MHIL), listed on BSE, between October 2022 and March 2023, after an exchange alert prompted an investigation. The noticees are Shubham Mittal, an independent director of the company, and seven connected entities and individuals, including Skylarge Realcon, Gaurav Narang, Bigsea Trading Company, Rekha Narang, Jagtarni Traders and Tilak Raj.

SEBI alleged that Mr Mittal, in connivance with the others, put forward a proposal to split the company's shares that the board approved but the shareholders later rejected, and that the proposal was misleading and pushed up the price and volume. The other noticees were then said to have sold their holdings at the inflated prices. The show cause notice of November 2024 charged breaches of section 12A of the SEBI Act and regulations 3 and 4 of the PFUTP Regulations.

The officer found the charge established against seven of the eight. The order traces money flows showing that several of the connected entities owed loans of about Rs 1.5 crore to one person and passed sale proceeds through to him, and concludes that they were under pressure to repay and that the split proposal was floated to raise the price so they could offload. One entity, Superfast Media, was cleared and its proceedings disposed of without penalty.

Each of the seven penalised noticees is liable for Rs 10 lakh under section 15HA, jointly and severally, payable in 45 days. The order records that neither gain nor investor loss was quantified.

The record does not show the profit made on the sales, whether any noticee appealed, or what became of the company's shareholders.

This library tags the matter as misleading issuer disclosure 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.

• Misleading issuer disclosure — 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. 2025-09-22 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 page
• 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.