SEBI v. Narendra Ramshankar Dubey (last-traded-price contributions, Max Heights Infrastructure, 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 an individual investor pushed up the last traded price of Max Heights Infrastructure shares with 176 tiny buy orders priced above the market, and imposed a Rs 5 lakh penalty. The investor said he traded in good faith and lost money.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

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Total relief

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Alleged gain

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Penalty as published

500k 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 26 September 2025 a SEBI adjudicating officer issued an order against Narendra Ramshankar Dubey in the matter of trading in the shares of Max Heights Infrastructure Ltd., listed on BSE. After an exchange alert, SEBI investigated 31 October 2022 to 15 March 2023.

SEBI alleged that Mr Dubey was one of the top ten buyers contributing to rises in the last traded price. He placed 176 buy orders of one to ten shares each, 165 of them for a single share, priced above the last trade even though much larger sell orders were available. These small orders accounted for about 17 per cent of the market's positive price contributions in the period, and 171 of them, which each met larger sell orders, added about Rs 346.57, or 16.56 per cent. The notice charged section 12A(a), (b) and (c) of the SEBI Act and the PFUTP Regulations.

Mr Dubey said he bought small quantities through a mobile app whose minimum order was one share, believed the price would rise, had no link to other traders, and lost money overall. He also said that every trade moves the last traded price and that the investigation report served on him was incomplete. The officer did not accept these arguments, held that the manipulation and misleading appearance of trading were established, and noted that a penalty under the Act does not depend on intent or on gain.

Under section 15HA the order imposed a penalty of Rs 5,00,000, the statutory minimum. The officer recorded that the order quantified no gain and no investor loss and that there was no sign of repeat conduct. No market ban was ordered.

The record does not show whether Mr Dubey appealed or paid. It does not show any link between him and other traders, and the order makes none. It is a civil penalty, not a criminal conviction.

This library tags the matter as 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 one technique 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.

Timeline

1. 2025-09-26 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.