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SEBI adjudication orders on illiquid stock options at BSE (2026 batch)

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. 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.

Report an error in this record (sebi-illiquid-stock-options-bse-2026-matched-orders) by email

SEBI adjudicating officers issued 152 orders from January to September 2026 on reversal trades in illiquid BSE stock options in 2014-15, more than a decade after the trading. The sampled orders each impose Rs 5,00,000 under section 15HA, one of them jointly on two noticees.

The record

Structured fields for this action, as recorded in our case library.
Agency SEBI (India)
Date filed 2026-01-05
Date resolved 2026-09-09
Court SEBI adjudicating officer
Status judgment
Asset class options
Instruments Illiquid stock options
Venue BSE
Criminal parallel No
Defendants Parmeswar Commercial Private Limited (entity) ; Anju Agarwal (individual) ; Amanat Developers Private Limited (entity) ; Mukund Dubey (individual) ; Nitesh Singh (individual)
Techniques Matched orders

What was ordered

Civil penalty
—
Disgorgement
—
Prejudgment interest
—
Total relief
—
Alleged gain
—

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.

What is alleged to have happened

This record groups 152 separate SEBI adjudication orders published between 2026-01-05 and 2026-09-09, each issued by an adjudicating officer to one noticee (or a small group) in the matter of dealings in illiquid stock options at BSE. It is read from a sample of orders, not from all 152; the individual noticees beyond the sample are not named here.

SEBI's investigation covered stock options trading on BSE between April 2014 and September 2015. It found that most trades in that segment, roughly 2.9 lakh trades or more than 81 percent, were reversals: a client bought or sold a contract and then took the opposite position with the same counterparty on the same day, often at prices that differed sharply. SEBI treated these trades as non-genuine because ownership did not meaningfully change hands, and said they inflated reported volume in contracts that otherwise barely traded. The investigation identified about 14,720 entities that executed such trades, and each was pursued in a separate adjudication proceeding.

In each order SEBI alleged that the noticee's trades created a false or misleading appearance of trading and breached Regulations 3(a) to (d), 4(1) and 4(2)(a) of the PFUTP Regulations 2003, and the adjudicating officer, after a show cause notice and a hearing opportunity, found the violation proved and penalised the noticee under section 15HA of the SEBI Act. Several of the later orders note that the noticee had first been offered SEBI's settlement scheme. Four orders were sampled. Amanat Developers Private Limited (28 January 2026) was alleged to have made 8 non-genuine trades in 3 contracts totalling 3,88,000 units. Anju Agarwal (18 March 2026) was alleged to have made 2 trades in one contract creating 13,000 units, and did not take up the settlement scheme. Parmeswar Commercial Private Limited (20 April 2026) was alleged to have made 4 trades in 2 contracts totalling 5,13,250 units. In a fourth order of 20 April 2026, Mukund Dubey and Nitesh Singh were penalised together, the notice having described 6 trades in 2 contracts totalling 13,88,000 units by an entity connected to them.

Each sampled order imposes Rs 5,00,000 under section 15HA. The joint order on Mukund Dubey and Nitesh Singh sets Rs 5,00,000 payable jointly and severally, so the two noticees share one penalty rather than each paying it. The record does not show whether other orders in the 2026 batch differ.

The record does not show the outcome of any appeal to the Securities Appellate Tribunal, whether penalties were paid, the profit or loss of any noticee, or the circumstances of noticees outside the sample. Because the penalties are set by statute for each noticee, no total for the batch is stated here.

This library tags the batch as matched orders, because the conduct found was pre-arranged reversal trades between the same parties. 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.

Timeline

  1. 2026-01-05 First order of the year in the batch published
  2. 2026-09-09 Last order of the year in the batch published (152 orders in 2026)

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

The linked release is published by the issuing regulator under its own terms. Our summary and narrative above are our own writing.

Other actions in the library sharing at least one technique tag with this one.

Action Agency Filed Technique Penalty Status
SEBI v. Shreedhar Yellaiah Kodam (synchronized trades, Well Pack Papers, 2026) SEBI (India) 2026-09-22 Matched Orders , Price Manipulation — dismissed
SEC v. Corey Ortiz (free riding and parking, 2026) SEC 2026-09-03 Free Riding And Parking , Matched Orders — judgment
SEBI v. Hanif Shekh and others (price and volume manipulation in five scrips, Mauria Udyog and others, 2026) SEBI (India) 2026-06-30 Matched Orders , Pump And Dump +1 — judgment
SEC v. Christopher Flagg, Daquan Lloyd and Travis Treusch (free riding and parking, 2026) SEC 2026-04-30 Free Riding And Parking , Matched Orders — judgment
SEBI v. Harsha Ishvarbhai Solanki and others (trading in ANI Integrated Services, 2026) SEBI (India) 2026-02-12 Price Manipulation , Matched Orders — judgment
SEBI v. Usha Devi and others (price and volume manipulation of DU Digital Technologies, 2025) SEBI (India) 2025-12-31 Price Manipulation , Matched Orders +1 — judgment

Record added October 8, 2026. submit a correction.