Adjudication Order Against 17 Entities in The Matter of LGS Global Limited

Page1of32
BEFORE THE ADJUDICATING OFFICER

SECURITIES AND EXCHANGE BOARD OF INDIA
[ADJUDICATION ORDER NO. EAD-2/AO/DSR/RG/205-221/2014]

UNDER SECTION 15 I OF SECURITIES AND EXCHANGE BOARD OF
INDIA ACT, 1992 READ WITH RULE 5 OF SECURITIES AND
EXCHANGE BOARD OF INDIA (PROCEDURE FOR HOLDING
INQUIRY AND IMPOSING PENALTIES BY ADJUDICATING OFFICER)
RULES, 1995

In respect of:

1. Shri Bharat Shantilal Thakkar (PAN:AAZPT9542R)
2. Shri Bipin Jayant Thaker (PAN: ABYPT4984H)
3. Shri Bharat G Vaghela (PAN: ADYPV0844N )
4. Shri Chirag Rajnikant Jariwala (PAN: AFMPJ7543L)
5. Shri Kishore Chauhan (PAN: AFPPC9703G)
6. Shri Bhavesh Pabari (PAN: AKGPP8679N)
7. Shri Prem Mohanlal Parikh (PAN: ALHPP3489N )
8. Shri Hemant Madhusudan Sheth (PAN: ANOPS8607E)
9. Ms Mala Hemant Sheth (PAN: AZXPS0694J)
10. Shri Vivek Kishanpal Samant (PAN:BRSPS0294N)
11. Shri Ankit Sanchaniya (PAN: BLNPS3316L )
12. Shri Gaurang Ajit Seth (PAN: BGEPS6596Q)
13. Shri Ketan Babulal Shah (PAN: AACPS0667F)
14. Shri Vasudev Ramchandra Kamat (PAN: ADCPK2552N)
15. Shri Jigar Praful Ghoghari (PAN: ASFPG8598L )
16. Shri Vipul Hiralal Shah (PAN: AZCPS9537P)
17. Arcadia Share & Stock Brokers Pvt. Ltd. (PAN:AAACA4562G)

In the matter of LGS Global Limited
(Now known as Ybrant Digital Limited)

Brought to you by http://StockViz.biz
Page2of32
1. Securities and Exchange Board of India (hereinafter referred to as SEBI),

pursuant to the detection of a huge rise in the traded volumes and/or price of
the shares of LGS Global Limited (now known as Ybrant Digital Limited
and hereinafter referred to as LGS/company), a company listed at Bombay
Stock Exchange Limited (BSE) conducted an investigation into the alleged
irregularity in the trading in the shares of LGS and into the possible
violation of the provisions of the Securities and Exchange Board of India
Act, 1992 (hereinafter referred to as the Act) and various Rules and
Regulations made there under during the period from February 10, 2009 to
May 07, 2010. It was observed that the price of the scrip unusually
increased from ` 20.15 to ` 133.60 and the daily high-low traded volume
was 46 shares to 12, 21, 140 shares.

2. SEBI vide its interim order dated February 02, 2011 had restrained 39
persons/entities from accessing the securities market and further, had
prohibited them from buying, selling or dealing in securities in any manner
whatsoever, till further directions, in various scrips including LGS. The said
order was later confirmed by SEBI vide its order dated J uly 08, 2011.

3. The investigation, inter alia, revealed that certain entities namely, 1) Shri
Bharat Shantilal Thakkar, 2) Shri Bipin J ayant Thaker, 3) Shri Bharat G
Vaghela, 4) Shri Chirag Rajnikant J ariwala, 5) Shri Kishore Chauhan, 6)
Shri Bhavesh Pabari, 7) Shri Prem Mohanlal Parikh, 8) Shri Hemant
Madhusudan Sheth, 9) Ms Mala Hemant Sheth, 10) Shri Vivek Kishanpal
Samant, 11) Shri Ankit Sanchaniya, 12) Shri Gaurang Ajit Seth, 13) Shri
Ketan Babulal Shah, 14) Shri Vasudev Ramchandra Kamat, 15) Shri J igar
Praful Ghoghari, 16) Shri Vipul Hiralal Shah (hereinafter referred to as
Page3of32
Noticee No. 1 to 16 and collectively referred to as the Noticees), connected

to each other by one way or the other, had dealt in the scrip of LGS through
multiple brokers, in a fraudulent and manipulative manner, without real
change in ownership of shares, by indulging in synchronized trades thereby,
creating artificial volumes and price rise in the scrip.

4. It was further observed that Noticee Nos. 1 to 12 had also indulged in
certain trades which were self trades in nature while trading through
multiple brokers one of them being Arcadia Share and Stock Brokers
Private Limited (hereinafter referred to as Noticee No. 17), a registered
intermediary thereby, creating artificial volumes which gave a false and
misleading appearance of trading in the scrip of LGS.

5. SEBI has, therefore initiated adjudication proceedings against Noticee Nos.
1 to 16 for the alleged violation of the provisions of Regulation 3(a), (b),
(c), (d), 4(1) and 4(2)(a), (b), (e) & (g) of the SEBI (Prohibition of
Fraudulent and Unfair Trade Practices relation to Securities market)
Regulations, 2003 (hereinafter referred to as the PFUTP Regulations) and
against Noticee No. 17 for the alleged violation of the provisions of Clause
A(1), (2) & (3) of the Code of Conduct as specified under Schedule II of the
SEBI (Stock Brokers and Sub-Brokers) Regulations, 1992 (hereinafter
referred to as Broker Regulations) read with Regulation 7 of the said
Regulations.

Page4of32

Appointment of Adjudicating Officer
6. I have been appointed as the Adjudicating Officer, in place of the previous
Adjudicating Officer, vide order dated August 29, 2013 under section 15 I
of the SEBI Act read with Rule 3 of the SEBI (Procedure for Holding
Inquiry and Imposing Penalties by Adjudicating Officer) Rules, 1995
(hereinafter referred to as Rules) to inquire into and adjudge under Section
15HA of the Act against the Noticee Nos. 1 to 16 for the alleged violation
of the provisions of PFUTP Regulations and under Section 15HB of the Act
against Noticee No. 17 for the alleged violation of the Broker Regulations.

Show Cause Notice, Reply and Personal Hearing

7. The Noticees were issued a common show cause notice (hereinafter to as
SCNs) dated October 08, 2013 in terms of Rule 4(1) of the Rules to show
cause as to why an inquiry should not be held and why penalty be not
imposed on them for the aforesaid violations. The SCNs were sent by
Registered Post Ack. Due and were duly delivered to the Noticees except in
case of Noticee Nos. 3 and 11 as the same were returned undelivered.
Therefore, the said SCNs were affixed at the last known addresses of the
said Noticees and the report thereof is available on record.

8. Vide letter dated October 22, 2013 one Ms. Rupal K. Chauhan, wife of
Noticee No. 5 informed that the Noticee No. 5 had passed away on May 29,
2013 and enclosed certified copy of the death certificate of Noticee No. 5 as
issued by the Department of Health and Family Welfare, Government of
Gujarat, in support thereof. In view of the same, the adjudication
Page5of32
proceedings initiated against Noticee No. 5 stand abated. However, I shall

examine the role of Noticee No. 5 for the limited purpose of examining the
role and findings against the other Noticees in the matter.

9. Further, vide letter dated J uly 01, 2014, Noticee No. 9 filed her reply to the
SCN. Vide letter dated October 21, 2013, Noticee No. 12 also filed his reply
to the SCN. With regard to Noticee No. 17, vide letter dated October 29,
2013, it requested 3 weeks time to file its reply in the matter. Further, vide
letter dated November 18, 2013, the Noticee No. 17 submitted its reply. The
other Noticees did not file any replies in the matter.

10. Thereafter, in the interest of natural justice and in order to conduct an
inquiry as per Rule 4(3) of the Rules, an opportunity of personal hearing
was granted to the Noticee Nos. 3 and 11 on April 07, 2014 vide separate
notices dated March 07, 2014. The said notices were also affixed at the last
known addresses of the said Noticees and report of affixture is available on
record. However, the Noticee Nos. 3 and 11 did not attend the said hearing
on the scheduled date. Further, all the Noticees were granted an opportunity
of personal hearing on August 11, 2014 vide separate notices dated J uly 24,
2014. The said hearing notices were duly delivered to the Noticees except
for Noticee Nos. 3 and 11 and therefore, the same were again affixed at the
last known addresses of the said Noticees and report of affixture is available
on record. In the meantime, vide separate letters dated August 08, 2014, the
Noticee Nos. 1, 2, 4, 7, 10 and 11 filed their replies in the matter.

11. Noticee Nos. 6 and 8 attended the hearing on August 11, 2014 and made
oral submissions by denying the allegations levelled against them. Further,
Page6of32
the Noticee Nos. 6 and 8 filed their separate replies vide letters dated
August 11, 2014 and further sought one week's time to file their detailed
replies in the matter. Accordingly, the said request was acceded to and the
Noticees were advised to file their respective replies on or before August
19, 2014. However, no replies have been received from the said Noticees
till date.

12. With respect to Noticee No. 17, the authorized representative attended the
hearing on the scheduled date and reiterated the submissions made by
Noticee No. 17 vide its reply dated November 18, 2014. The other Noticees
did not attend the hearing on the scheduled date. Noticee No. 12 vide letter
dated August 11, 2014 filed his additional reply and vide separate letters
dated August 11 and 21, 2014, Noticee Nos. 13, 14 and 15 filed their
preliminary replies in the matter and further requested extension of time to
file their detailed replies. However, no replies have been received from the
said Noticees till date.

13. In view of the above, with respect to Noticee Nos. 3 and 16, I note that
ample opportunities and time was granted to them for filing their replies and
presenting their case in the matter. Further, with respect to Noticee Nos. 1,
2, 4, 6, 7, 8, 10, 11, 13, 14 and 15, I note that the said Noticees have been
granted sufficient time to file their replies in the matter as the SCN in the
present case was issued on October 08, 2013 i.e. appx more than 10 months
back. Therefore, I am proceeding further against the said Noticees on the
basis of material available on record in the matter.

Consideration of Issues, Evidence and Findings
Page7of32
14. I have carefully perused the charges levelled against the Noticees in the
SCN, written submissions made and all the documents available on the
record. In the instant matter, the following issues arise for consideration and
determination:
a)Whether the Noticee Nos. 1 to 4 and 6 to 16 have violated
Regulations 3(a), (b), (c), (d), 4(1) and 4(2)(a), (b), (e) & (g) of the
PFUTP Regulations?
b)Whether the Noticee No. 17 has violated Clauses A(1), (2) and (3) of
the Code of Conduct for Stock Brokers as specified under Schedule
II read with Regulation 7 of Broker Regulations?
c)Does the violations, if any, on the part of the Noticees attract
monetary penalty under Sections 15 HA and 15HB of the SEBI Act?
d)If so, what would be the quantum of monetary penalty that can be
imposed on the Noticees taking into consideration the factors as
mentioned under Section 15J of the SEBI Act?

15. Before proceeding forward, I would like to refer to the relevant provisions
of the PFUTP Regulations and the Brokers Regulations, which read as
under:
Relevant provisions of PFUTP Regulations
3. Prohibition of certain dealings in securities
No person shall directly or indirectly
(a) buy, sell or otherwise deal in securities in a fraudulent manner;
(b) use or employ, in connection with issue, purchase or sale of any security listed
or proposed to be listed in a recognized stock exchange, any manipulative or
deceptive device or contrivance in contravention of the provisions of the Act or
the rules or the regulations made there under;
(c) employ any device, scheme or artifice to defraud in connection with dealing in
or issue of securities which are listed or proposed to be listed on a recognized
stock exchange;
Page8of32
(d) engage in any act, practice, course of business which operates or would
operate as fraud or deceit upon any person in connection with any dealing in or
issue of securities which are listed or proposed to be listed on a recognized stock
exchange in contravention of the provisions of the Act or the rules and the
regulations made there under.

4. Prohibition of manipulative, fraudulent and unfair trade practices
(1) Without prejudice to the provisions of regulation 3, no person shall indulge in
a fraudulent or an unfair trade practice in securities.
(2) Dealing in securities shall be deemed to be a fraudulent or an unfair trade
practice if it involves fraud and may include all or any of the following, namely:
(a) indulging in an act which creates false or misleading appearance of trading in
the securities market;
(b) dealing in a security not intended to effect transfer of beneficial ownership but
intended to operate only as a device to inflate, depress or cause fluctuations in the
price of such security for wrongful gain or avoidance of loss;
(c).............
(d).............
(e) any act or omission amounting to manipulation of the price of a scrip
(g) entering into a transaction in securities without intention of performing it or
without intention of change of ownership of such security;

Relevant provisions of the Broker Regulations
Stock brokers to abide by Code of Conduct.
7. The stock broker holding a certificate shall at all times abide by the Code of
Conduct as specified in Schedule II.

SCHEDULE II
CODE OF CONDUCT FOR STOCK BROKERS
[Regulation 7]

A. General.
(1) Integrity: A stock-broker, shall maintain high standards of integrity,
promptitude and fairness in the conduct of all his business.
(2) Exercise of due skill and care: A stock-broker shall act with due skill, care
and diligence in the conduct of all his business.
Page9of32
(3)Manipulation: A stock-broker shall not indulge in manipulative, fraudulent or

deceptive transactions or schemes or spread rumours with a view to distorting
market equilibrium or making personal gains.

16. I find from the SCN that LGS is a company listed on the BSE. On analysis
of the trading activity in the scrip of LGS, it was noticed that a group of
entities identified as the Pabari-Parikh group in the investigation report,
including Noticee Nos. 1 to 16, who were all connected to each other in one
way or the other, had traded heavily in the scrip of LGS through multiple
brokers, one of them being Noticee No. 17. The relationship between the
entities is detailed as under:
Client
Name
KYC Relation Fund
Move
ment

Share
moveme
nt
through
off
market
Client
Name
KYC Relation Fund
Move
ment

Share
moveme
nt
through
off
market
1. Bharat
Shantilal
Thakkar
Sl. no. 6 is his
nephew.
Same address with
sl. no.6.
Sl. no. 6 is his
nominee.
J oint a/c with sl. no.
6.
BR* with sl. no. 2, 4,
5, 7, 8, 11, 10
With
sl. no.
6, 7,
11,
With sl.
no. 6, 15
10.
Vivek
Kishan
pal
Samant
Sl. no. 6 is the
brother in law &
shares common Tel.
no. & sl.no. 6 is the
nominee of sl. no.
10 for trading a/c &
bank a/c.
Shares email with sl.
no. 8.
Shares email with sl.
no. 7.
With
sl. no.
8,
With sl.
no. 6, 8,
4, 5, 7,
11.
2. Bipin
Jayant
Thaker
Same Tel. no. with sl.
no. 6.
5, 6, 7, 8, 11, 10,
With
sl. no.
6.
With sl.
no. 16, 4,
6, 7, 8,
11.
Ankit
Sancha
niya
Same Tel. no. with
sl. no. 7 and also
shares Tel. no. with
sl. no. 6 who is the
nominee for his a/c.
BR* with sl. no.1, 4,
5, 6, 7, 8, 10,
With
sl. no.
6, 7,
With sl.
no. 6, 7,
8, 4, 16,
10,
3. Bharat
G
Vaghela
Sl. No. 4 is nephew
of sl. no. 6 and
shares same Tel. no.
with sl. no. 6.
With
sl. no.
4.

12.
Gauran
g Ajit
Seth
Has common
address & Tel. no.
with sl. no. 8. & sl.
no. 8 and 6 both
directors of Rajnandi
Yarns Pvt. Ltd.

4. Chirag
Rajnikant
Jariwala
Same Tel. no. with
sl.no.6.
Sl. no. 6 is his uncle.
With
sl. no.
6, 8, 3
With sl.
no.2
13.
Bhupe
sh
Rathod
Introduced sl. no.8,
7, 6, 5 for trading a/c
and knows sl. No. 9
With
Sl. No.
11

Page10of32
5, 6, 8, 11, 10
5.
Kishore
Chauhan
J oin a/c with sl. no. 6
Sl. no. 6 & 8 are
witness for demat
a/c.
4, 6, 7, 8, 11,
With
sl. no.
6, 7, 8
With sl.
no. 6, 7,
8, 10, 14.
Ketan
Babulal
Shah
With sl.
no.7
6.
Bhavesh
Pabari
Sl. no. 1 is his uncle
& sl. no. 10 is his
brother in law.
Sl. no. 7 is cousin of
sl. no.6
Sl. no. 6 & 8 both
Yarns Pvt. Ltd.
Share common Tel.
no. with sl. no. 11,
10, 2.
Sl. no. 13 introduced
him for trading a/c.
5, 7, 8, 9, 11
With sl.
no. 7, 8,
1, 2, 11,
10,
15.
Vasude
v
Ramch
andra
Kamat
Sl. no. 1 shares the
same address with
sl. no.6.
With sl.
no.1

7. Prem
Mohanlal
Parikh
Sl. no. 7 is cousin of
sl. no.6
Common email with
sl. 11, 7 & 10.
Sl. no. 8 is nominee
of sl. no.7.
4, 5, 6, 8, 11, 10.
With
sl. no.
6, 8, 5
With sl.
no. 6, 8,
5, 1, 2, 8,
16, 11,
10,
16.
Jigar
Praful
Ghogh
ari
With sl.
no. 2, 7,
8, 11,
8.
Hemant
Madhusu
dan
Sheth
Sl. no. 6 & 8 both
Yarns Pvt. Ltd.
Same email with sl.
no. 10.
BR* with 13, 1, 7, 11,
10, 2, 4, 5, & sl. no.
9 is his wife & sl. no.
12 is his nephew.
With
sl. no.
6, 7, 5
With sl.
no. 6, 7,
5, 9, 11,
10, 16, 2,
17.
Vipul
Hiralal
Shah
With sl.
no.6

9. Mala
Hemant
Sheth
Sl. no. 9 is the wife of
sl. no. 8 and sl. no.
12 is the nephew.
With
sl. no.
6, 7.
With sl.
no. 8,

* Business Relations

17. In addition to the above, it was revealed that the Pabari-Paikh Group,
including Noticee Nos. 1 to 16, had indulged in certain off-market transfers
for 11,90,750 shares of LGS amongst themselves during the relevant period.
These off-market transfers among the group further allegedly confirmed the
relationship / connection between the said group.
Page11of32

18. From the trade log analysis, I find that the group of entities, as mentioned in
above paras, had purchased 1,02,42,859 shares accounting for 50.35% of
the total traded volume and sold 88,25,263 shares accounting for 43.38% of
the total traded volume during the relevant period. Out of the said entities,
Noticee Nos. 1 to 16 had traded for 71,94,984 shares (i.e. 35.37% of the
market volume) accounting for 70.24 % of the total purchase of the group
and 81.53% of the total sale of the group within the said Pabari-Parikh
Group entities and 35.37% of the market volume from within the group
entities. Out of the 71,94,984 shares traded within the group entities, the
buy and sell orders for 33,92,951 shares, constituting 16.68% of the market
volume, were placed within one minute time difference. Further, it was
noted that 33,92,951 shares constituted 33.13% of the total purchase of
Pabari-Parikh Group entities and 38.45% of the total sale of the Pabari-
Parikh Group entities.

19. Further, out of 33,92,951 shares, for 5,98,895 shares which accounted for
2.94% of the total market volume, the buy and sell orders were allegedly
placed in synchronised manner (i.e. difference between placement of order
by buyer and seller within one minute and order rate as well as order
quantity of buy side and sale side being the same) by Noticee Nos. 1 to 12.
The volume of 5,98,895 shares constituted 5.85% of the total purchase of
Pabari-Parikh Group entities and 6.79% of the total sale of the Pabari-
Parikh Group entities. The summary of the said synchronized trades entered
into by the Noticee Nos. 1 to 12 is as under:

Page12of32

PANNO ClientName
Synchronised
buytrade
%of
sync
to
total
buy
by
client
%ofMarket
Volume
Synchronised
saletrade
%of
sync
to
total
sale
by
client
%of
Market
Volume
AAZPT9542R
BharatShantilal
Thakkar
(NoticeeNo.1) 120195 10.21 0.59 77632 6.58 0.38
ABYPT4984H
BipinJayantThaker
(NoticeeNo.2) 49386 7.61 0.24 23177 4.12 0.11
ADYPV0844N
BharatGVaghela
(NoticeeNo.3) 0 0.00 0.00 500 0.24 0.00
AFMPJ7543L
ChiragRajnikant
Jariwala
(NoticeeNo.4) 27000 5.74 0.13 37757 11.71 0.19
AFPPC9703G
KishoreChauhan
(NoticeeNo.5) 69500 7.44 0.34 54997 7.62 0.27
AKGPP8679N
BhaveshPabari
(NoticeeNo.6) 28149 4.02 0.14 24734 3.60 0.12
ALHPP3489N
Prem Mohanlal
Parikh
(NoticeeNo.7) 57062 6.34 0.28 73036 11.63 0.36
ANOPS8607E
Hemant
MadhusudanSheth
(NoticeeNo.8) 108777 3.67 0.53 213521 8.22 1.05
AZXPS0694J
MalaHemant
Sheth
(NoticeeNo.9) 0 0.00 0.00 8500 2.65 0.04
BGEPS6596Q
GaurangAjitSeth
(NoticeeNo.12) 500 2.27 0.00 0 0.00 0.00
BLNPS3316L
AnkitSanchaniya
(NoticeeNo.11) 28101 3.08 0.14 36150 4.13 0.18
BRSPS0294N
VivekKishanpal
Samant
(NoticeeNo.10) 110225 13.58 0.54 48891 8.03 0.24
GrandTotal 598895 5.85 2.94 598895 6.79 2.94

20. I also find that Noticee Nos. 1 to 12 had allegedly indulged in certain trades
which were self trades in nature while trading through their multiple brokers
Page13of32
including Noticee No. 17. The details of the said fictitious trades are as
under:
PANNO ClientName TotalBuy TotalSale
Self
trade
qty
%of
Total
Buy
%
Total
Sale
%of
Mark
et
Volu
me
No
of
Self
trad
es
AAZPT9542R
BharatShantilal
Thakkar
(NoticeeNo.1) 1176987 1179456 23264 1.98 1.97 0.11 22
ABYPT4984H
BipinJayantThaker
(NoticeeNo.2) 648777 562659 26898 4.15 4.78 0.13 26
ADYPV0844N
BharatGVaghela
(NoticeeNo.3) 256572 211799 20 0.01 0.01 0.00 1
AFMPJ7543L
ChiragRajnikant
Jariwala
(NoticeeNo.4) 470041 322300 45685 9.72 14.17 0.22 10
AFPPC9703G
KishoreChauhan
(NoticeeNo.5) 934416 722216 1000 0.11 0.14 0.00 1
AKGPP8679N
BhaveshPabari
(Noticeeno.6) 700032 686402 28860 4.12 4.20 0.14 9
ALHPP3489N
PremMohanlal
Parikh
(NoticeeNo.7) 900352 627742 79563 8.84 12.67 0.39 18
ANOPS8607E
Hemant
MadhusudanSheth
(NoticeeNo.8) 2960225 2599035 484619 16.37 18.65 2.38 138
AZXPS0694J
MalaHemantSheth
(NoticeeNo.9) 320268 320756 8725 2.72 2.72 0.04 2
BGEPS6596Q
GaurangAjitSeth
(NoticeeNo.12) 22000 18000 1565 7.11 8.69 0.01 1
BLNPS3316L
AnkitSanchaniya
(NoticeeNo.11) 912651 875458 43410 4.76 4.96 0.21 9
BRSPS0294N
VivekKishanpal
Samant
(NoticeeNo.10) 811677 608829 51000 6.28 8.38 0.25 9
GrandTotal 10113998 8734652 794609 7.86 9.10 3.91 246

21. For the above fictitious trades, it was noted that the brokers mentioned in
the table below were appearing on both the sides of the trade i.e. acted as
broker and counter party broker. The number of instances wherein the
Page14of32
Noticee No. 17 had executed self trades on behalf of its clients was
significant and the details of the same are as under:.

BuyandSaleMemberName ClientName TotalTradedQty
No.ofTrades
ArcadiaShare&Stock
BrokersPvt.Ltd.
AnkitRajendraSanchaniya
(Noticeeno.11) 3762 2
BharatGVaghela
(Noticeeno.3) 20 1
BharatShantilalThakkar
(NoticeeNo.1) 12154 19
BhaveshPabari
(NoticeeNo.6) 110 2
BipinJayantThaker
HemantMadhusudanSheth
(NoticeeNo.8) 200 1
KishoreChauhan
ArcadiaShare&StockBrokersPvt.Ltd.
(NoticeeNo.17)Total 18745
28
FairwealthSecuritiesP.Ltd.
AnkitRajendraSanchaniya
FairwealthSecuritiesPvt.Ltd.Total 500
1
GlobeCapitalMarketLtd.
ChiragRajnikantJariwala
(NoticeeNo.4) 85 1
GlobeCapitalMarketLtd.Total 85 1
GrandTotal 19330 30

22. From the price volume data analysis, I note that the scrip of LGS was traded
on 301 trading days. Out of 301 trading days, the group entities including
the Noticee Nos. 1 to 16 had traded among themselves on 145 days, i.e.
48% of the total number of days the scrip was traded during the period
under investigation. It was noted that the Pabari-Parikh Group entities had
contributed to daily market volume of the scrip in the range from 0.90% on
March 08, 2010 to 95.07% on April 09, 2010. It was further alleged in the
SCN that out of 145 trading days, on 68 trading days the Pabari-Parikh
Page15of32
Group entities, including the Noticee Nos. 1 to 16, had traded amongst
themselves and thereby had contributed more than 50% to the total market
volume traded in the scrip during the relevant period.

23. On further examination, I find that out of 145 trading days on which the
Pabari-Parikh Group had entered into trades in the scrip of LGS, on 125
trading days both the buy and sell orders were placed within time difference
of one minute. It was, therefore, alleged in the SCN that the Pabari-Parikh
Group entities, including the Noticee Nos. 1 to 16, had contributed to daily
market volume of the scrip in the range from 0.30% on August 31, 2009 to
88.88% on February 15, 2010. Out of 125 trading days, on 11 trading days
the Pabari-Parikh Group entities, including the Noticee Nos. 1 to 16, had
contributed more than 50% to the total market volume by placing both the
buy and sell order within one minute time difference. It was also alleged
that out of 125 trading days, on 41 trading days the trades executed by the
Pabari-Parikh Group entities, including the Noticee Nos. 1 to 16, were
synchronised in nature. By executing synchronised trades among the group
entities, the Pabari-Parikh Group entities had contributed to total market
volume of the scrip in the range from 0.2% on November 20, 2009 to
56.11% on J anuary 14, 2010. Further, on two trading days, by entering into
synchronised trades the group entities had contributed more than 50% to the
total market volume traded in the scrip during the relevant period.

24. It was, therefore, alleged in the SCN that the Noticee Nos. 1 to 16, by
indulging in the manipulative trade practices as mentioned above, had
violated Regulations 3(a), (b), (c), (d), 4(1) and 4(2)(a), (b), (e) & (g) of the
PFUTP Regulations thereby, created artificial volumes and price in the scrip
Page16of32
of LGS and further alleged that the Noticee No. 17, by executing the
manipulative trades on behalf of Noticees, had violated Clauses A(1), (2)
and (3) of the Code of Conduct for Stock Brokers as specified under
Schedule II read with Regulation 7 of the Broker Regulations.

Submissions made by the Noticees:
Noticee Nos. 1, 2, 4, 6, 7, 8, 10 and11:
25. Vide separate but identical letters dated August 08, 2014, the Noticee Nos.
1, 2, 4, 7, 10 and 11 submitted that they have been debarred from buying,
selling and dealing in the securities market vide SEBI order dated February
02, 2011. Further, the said Noticees stated that as the investigation period is
4 years old, they are in a process of collating the data and file their detailed
reply in the matter. They further sought 25 to 35 days time for filing
detailed reply in the matter. With respect to Noticee Nos. 6 and 8, vide
separate but identical letters dated August 11, 2014, denied all the charges
levelled against them in the SCN and further sought 30 days time for filing
detailed reply in the matter. However, it is noted that the said Noticees have
not filed any further replies in the matter till date.

Noticee No. 9:
26. The Noticee No. 9 vide her reply dated J uly 01, 2014 submitted that vide
SEBI order dated J uly 08, 2013 the Noticee is still debarred from trading in
the securities market and her demat account stands frozen. The Noticee
states that initiation of adjudication proceedings in the matter (although the
earlier debarment being still in force) is a "double jeopardy". She further
submits that she had traded in many scrips during and prior to the relevant
period and LGS was one of the scrips. The Noticee No. 9 admits that she is
Page17of32
the wife of Noticee No. 8 i.e. Shri Hemant Madhusudhan Sheth however,
denied having any business or professional connection with him and stated
that she takes independent trading decisions. The Noticee has denied having
made any monetary transactions with Noticee Nos. 6 and 7 (Shri Bhavesh
pabari and Shri Prem Mohanlal Parikh).

27. The Noticee No. 9 submitted that she is not connected with any of the
entities forming part of the Pabari-Parikh Group and had dealt in the shares
of LGS independently. Further, she confirmed that she had bought 3,20,368
shares and sold only 3,20,756 shares. However, she stated that the said
purchase and sale of shares accounted only for 1.57% and 1.58%
respectively of the total traded volume in LGS during the relevant period
which is very miniscule quantity to arrive at a conclusion that the said
transactions created artificial volumes in the scrip. The Noticee No. 9 has
admitted the fact that she had received 37,000 shares of LGS in an off
market transaction from Noticee No. 8 and were borrowed by her from
Noticee No. 8 to meet her pay in obligations but she denies having any
professional connection with Noticee No. 8. She submits that only 0.33% of
the market volume traded by her on the buy side was in the form of
synchronised trading and only 0.72% of the market volume traded by her on
the sell side was in the form of synchronised trading. The volume of
synchronised trades as alleged in the SCN i.e. 1.57% on the buy side and
1.58% on the sell side is a miniscule volume and cannot impact the
equilibrium of the scrip. Further, there are very few trades out of her total
trading wherein the time difference was less than 1 minute and she
submitted that majority of trading was ranging in the time difference of
Page18of32
more than 1 minute to more than 4 hours for the shares purchased by her
and from one minute to more than 42 minutes for the shares bought by her.

28. While trading within the group, Noticee No. 9 submitted that the trades
wherein she had sold shares to the persons belonging to the group
constituted only 0.46% of the total market volume of the scrip and the
trades wherein she had bought shares from the group entities constituted
slightly more than 1% of the total market volume traded in the scrip of
LGS. Further, one of the sale transaction for 10000 shares executed by
Noticee No. 9 through broker, Sunidhi Securities and Finance Limited had
matched with the buy transaction of Noticee No. 6 i.e. Shri Bhavesh Pabari.
The Noticee submitted that the said transaction cannot be said to have
created artificial volumes in the said scrip. With respect to the self trades
allegation, the Noticee No. 9 denied having entered into any self trades. She
stated that the orders were given to broker well in advance and the broker
by analysing the trading pattern in the scrip punched the orders in the
system. The Noticee states that the volume contributed by the so called self
trades was only 0.04% to the total market volume.

Noticee No. 12:
29. The Noticee No. 12 vide his reply dated October 21, 2013 denies being
connected/ related with Noticee No. 8 by way of having same address and
telephone numbers. Further, the Noticee submitted that he has not dealt in
any off market transactions in the scrip of LGS and had traded
independently. The Noticee states that the synchronised trades which have
alleged in the SCN are miniscule in quantity. Further, with regard to self
trades, the Noticee No. 12 stated that the same were done unintentionally
Page19of32
and were done to adjust his financial position with one of his brokers. Vide
letter dated August 11, 2014, the Noticee No. 12 submitted his detailed
reply in which he reiterated the submissions made by him in his earlier
reply. The Noticee inter-alia submitted that he is not staying with Noticee
No. 8 i.e. Shr Hemant Madhusudan Sheth and also is not sharing a common
telephone number. The Noticee further stated that he has not entered into
any fund or off market transactions with Noticee No. 6 i.e. Shri Bhavesh
Pabari.

Noticee No. 13:
30. Vide letter dated August 11, 2014 the Noticee No. 13 submitted his reply in
the matter. He submitted that he is in a business of buying and selling gold
and silver readymade ornaments and that he does his business from his
office. The decision of trading and investment is completely taken
independently by the Noticee and is not influenced by any other person.
The Noticee denies being part of the Pabari-Parikh Group. The Noticee
states that all the trades were executed by him through one broker viz.
Globe Capital Market Limited and were delivery based and therefore, there
is no question of the said trades being synchronised or circular in nature.
The Noticee also denies the off market transactions alleged to have entered
by him in the SCN. He submitted that he had bought and sold 13,000 shares
of LGS during the relevant period on the market and had traded in his own
account through the above mentioned broker. The Noticee states that none
of his trades have been found to have been self or synchronised in nature
and therefore, the charge of executing manipulative trades against him
cannot stand.

Page20of32

Noticee No. 14:
31. The Noticee No. 14 submitted his reply in the matter vide letter dated
August 11, 2014. The Noticee stated that he is a doctor by profession and
Noticee No. 1 (Bharat Shantilal Thakkar), being one of his patients, had
advised him to deal in capital markets. Noticee No. 14 and 1 were clients of
the broker Angel Share Broking but the Noticee submits that the investment
decisions were independent. The Noticee No. 14 denies being a part of the
alleged Pabari-Parikh Group. The Noticee submitted that he had received
500 shares of LGS in off market transaction from Noticee No. 1 against
which consideration was paid by Noticee No. 14 to Noticee No. 1. The
details of cheque payments done have been listed by the Noticee. During
the relevant period, the Noticee No. 14 states that he had bought and sold
14,800 shares of LGS which were 0.07% of the market volume. In the SCN
it has been alleged that out of the buy volume of 12,000 shares, 2000 shares
were matched on May 22, 2009 with one of the group entities which the
Noticee submits is a negligible volume. The Noticee states that he has done
all trading in the scrip of LGS on delivery basis and were not self or
synchronised in nature and therefore, the charge of creating artificial
volume in the scrip against him cannot stand.

Noticee No. 15:
32. The Noticee No. 15 vide his letters dated August 08, 2014 and August 21,
2014 submitted that he is into jobbing and arbitrage trading activities.
Further, the Noticee submitted that as no query was raised by his stock
broker or the exchange for the transactions executed by him in LGS shares,
he had carried on trading in the shares in the routine manner. Additionally,
Page21of32
the Noticee states that there are no investor complainants against the
Noticee for executing the said transactions in the shares of LGS. As regards
volume created in the shares of LGS during the investigation period, the
Noticee No. 15 submitted that he had bought 90750 shares (0.45%) and sold
50000 shares (0.02%) of LGS and that the said quantity was insignificant if
compared to the total volume traded in the said scrip. As regards his
connection with the Pabari Parikh Group, the Noticee while denying the
connection with the group entities submitted that he had paid/ received
consideration for the execution of off market dealings with Noticee Nos. 2
and 8 i.e. Shri Bipin Kumar Thaker and Shri Hemant Madhusudhan Sheth
and had no further connection with the group.

33. As regards the allegation of synchronized trades, the Noticee submitted that
the said trades were coincidental as the Noticee was not aware of the
counter party broker or client, also that the same did not have any impact on
the market equilibrium. As regards the allegation of self-trades, the Noticee
submitted that none of the trades executed by him have been listed out in
Annexure to the SCN which were self trades. Therefore, the Noticee No. 15
states that all his transactions were genuine and bonafide, as they had
neither caused any harm/damage to anyone nor had any impact on the
market equilibrium.

Noticee No. 17:
34. Noticee No. 17 submitted its reply vide letter dated November 18, 2013.
The Noticee submitted that it is a stock broker and had traded in the scrip of
LGS in the normal and ordinary course of the stock broking business. The
trades were executed in the then existing clients account on receipt of their
Page22of32
instructions and authorization. The Noticee submitted that it had no

knowledge of any pattern or method of placing orders and that the clients
were inter connected with each other. As on date, the Noticee submitted that
it is not dealing for the stated clients and have improved their monitoring,
control and surveillance systems to ensure that no such activities are carried
out by its clients through any of its terminals. The Noticee further vide letter
dated September 02, 2014 stated that the transactions mentioned in the SCN
were carried out through SEBI registered sub broker Mr. Chirag R J ariwala
affiliated with the Noticee since March 2008.

35. Further, vide the said letter the Noticee requested for an opportunity of
inspection of documents in the matter. However, I note that SCN was
issued on October 08, 2013 i.e. almost a year back and vide letter dated
October 29, 2013 the Noticee had sought for 3 weeks time to submit its
reply. Further, vide letter dated November 18, 2013 the Noticee submitted
its preliminary reply in the matter but did not request for any specific
documents to be provided. I also note that an opportunity of personal
hearing was granted to the Noticee on August 11, 2014 wherein the
Authorised Representative appeared for the Noticee and reiterated its earlier
submissions without requesting for any specific documents or inspection
thereof. A request for inspection being made vide letter dated September
02, 2014 is nothing but a delaying tactic adopted by the said Noticee to
prolong the present proceedings. Therefore, I find that all the relevant
documents relied upon were already provided to the Noticee along with the
SCN (in a CD) and I don't find any merit in the request for inspection of
documents in the matter at this stage i.e. after the conclusion of personal
hearing.
Page23of32
FINDINGS:
36. I find from the SCN and the material available on record that during the
relevant period, the Noticee Nos. 1 to 16 along with one more entity, who
were all connected to each other and referred to as the Pabari-Parikh Group
entities in the investigation report, had traded significantly in the shares of
LGS i.e. purchased 1,02,42,859 shares constituting 50.35% and sold
88,25,263 shares constituting 43.38% , respectively, of the total traded
volume in the scrip. I find that the relationship table as mentioned in para 16
above clearly shows that the said Noticees were connected to each other
either by way of having similar addresses / telephone numbers, relatives,
business associates and/or having fund movements between themselves.
Further, the relationship of the Noticee Nos. 1 to 16 is further established by
way of off market transactions between them as mentioned in para 17
above. I note that the Noticee Nos. 1 to 16 had traded for 71,94,984 shares
(i.e. 35.37% of the market volume) accounting for 70.24 % of the total
purchase of the group entities and 81.53% of the total sale of the said group
within the said Pabari-Parikh Group entities and constituted 35.37% of the
total market volume traded in the scrip of LGS on the exchange platform.
Out of the 71,94,984 shares traded within the group entities, the buy and sell
orders for 33,92,951 shares, constituting 16.68% of the market volume,
were placed within one minute time difference. Further, I find that
33,92,951 shares constituted 33.13% of the total purchase of group entities
and 38.45% of the total sale of the said Group entities. The quantity of
shares and the pattern of trading indulged into by the Noticee Nos. 1 to 16
within the group further substantiate the fact that they all had a meeting of
minds and traded in the scrip of LGS in collusion with each other.
Therefore, I do not find any merit in the submissions made by the Noticees
Page24of32
that they had no relationship with each other and had traded in the scrip of
LGS independently and in the ordinary course of business.

37. I further find that the Noticee Nos. 1 to 12 had indulged in certain
synchronised trades in the shares of LGS thereby, creating false and
misleading appearance of trading in the scrip. I note that out of 33,92,951
shares traded by the Noticee Nos. 1 to 16, for 5,98,895 shares, which
accounted for 2.94% of the total market volume, the buy and sell orders
were placed in synchronised manner. 5,98,895 shares constituted for 5.85%
of the total purchases made by Pabari-Parikh Group entities and for 6.79%
of the total sales done by the said Group entities. On perusal of the details of
synchronised trades as given in para 19 above and the order and trade log, I
find that the Noticee Nos. 1 to 12 did indulge in manipulative activities in
the said scrip and traded in a synchronised manner within the group without
any intention of change in beneficial ownership of shares and I don't find
merit in the contentions made by the Noticees.

38. I find that during the relevant period the shares of LGS were traded on 301
trading days. Out of 301 trading days, the group entities including the
Noticee Nos. 1 to 16 had traded among themselves on 145 days, i.e. 48% of
the total number of days the scrip. The said group entities had by trading
among themselves contributed to daily market volume of the scrip in the
range from 0.90% on March 08, 2010 to 95.07% on April 09, 2010. Further,
out of the 145 days, I find that on 68 trading days, the Noticee Nos. 1 to 16
by trading amongst themselves had contributed for more than 50% to the
total traded volumes in the scrip.

Page25of32
39. Also, I find that out of 145 trading days on which the Pabari-Parikh Group
entities had entered into trades in the scrip of LGS, on 125 trading days both
the buy and sell orders were placed within time difference of one minute.
By executing trades in the said manner, the Pabari-Parikh Group entities,
including the Noticee Nos. 1 to 16, had collectively contributed to daily
market volume of the scrip in the range from 0.30% on August 31, 2009 to
88.88% on February 15, 2010. Further, out of 125 trading days, on 11
trading days the Pabari-Parikh Group entities, including the Noticee Nos. 1
to 16, had contributed more than 50% to the total market volume by placing
both the buy and sell order within one minute time difference. On further
analysis, out of 125 trading days, on 41 trading days the trades executed by
the Pabari-Parikh Group entities, including the Noticee Nos. 1 to 16, were
synchronised trades by which they had contributed to total market volume
of the scrip in the range from 0.2% on November 20, 2009 to 56.11% on
J anuary 14, 2010.

40. In view of the above, I do not find any merit in the contention of the
Noticees that the Noticees had entered into trades individually and
synchronised trades indulged into by the Noticees were insignificant /
miniscule in volume if compared to the total volumes traded in the scrip of
LGS. I find that the manipulative trading practices indulged in by the
Noticees cannot be viewed independently and have to be viewed
collectively as the overall impact of the synchronised trading done by the
Noticee Nos. 1 to 16 on the market in the scrip of LGS was quiet
significant. Further, I also find that such pattern of trading cannot be
executed without prior meeting of minds and prior understanding between
the Noticee Nos. 1 to 16.
Page26of32

41. I find from paras 20 and 21 above that Noticee Nos. 1 to 12 had even
entered into certain trades which were self trades in nature i.e. totally
fictitious trades wherein the entity appears on both the buy and sell side of
the trade. The said Noticees had executed a total of 246 self trades for a
quantity of 7,94,609 shares thereby, inflated the volumes in the scrip by
3.91%. The Noticee Nos. 1 to 12 had executed the said fictitious trades
through multiple brokers. However, the Noticee No. 17 was the broker who
had executed significant number of self trades i.e. 28 self trades for 18,745
shares for the Noticee Nos. 1, 2, 3, 5, 6, 8 and 11. I do not find any merit in
the submissions of the Noticee No. 17 that the said trades were executed on
behalf of the clients without any knowledge of manipulation and were only
done upon the instructions of the clients. I find that the number of occasions
on which the Noticee No. 17 appeared as the broker and counter-party
broker in the fictitious trades during the period under investigation was
significant and cannot be said to be an innocent act. Therefore, I find that by
executing the self trades, Noticee Nos. 1 to 12 had further created a false
market and gave a misleading trading appearance in the scrip and Noticee
No. 17 had not acted in accordance with the code of conduct as prescribed
under the Broker Regulations.

42. I note that certain Noticees have in their submissions stated that they have
been restrained from trading in the securities market vide SEBI order dated
February 02, 2011 confirmed on J uly 08, 2011 and the said debarment order
is still in force. Further, I also note that the Noticee No. 9 in her submissions
has contended that the present adjudication proceedings are double jeopardy
as SEBI has already vide its order, debarred the Noticee from trading in the
Page27of32
market for the same violations. At this juncture, I rely on judgement of the
Hon'ble High Court of Bombay in the case of SEBI Vs. Cabot International
Capital Corporation (2004) wherein it was observed that "the adjudication for
imposition of penalty by Adjudication Officer, after due inquiry, is neither a
criminal nor a quasi criminal proceeding. The penalty leviable under this Chapter
or under these sections, is penalty in cases of default or failure of statutory
obligation or in other words, breach of civil obligation. The provisions and
scheme of penalty under SEBI Act and the regulations, there is not element of
criminal offence or punishment as contemplated under criminal proceedings." In
view of this, i do not find merit in the contention of the Noticee no. 9.

43. From the foregoing, I find that the Noticee Nos. 1 to 16 by trading amongst
themselves had indulged in synchronised trades on numerous occasions,
resulting in no change of beneficial ownership thereby, created artificial
volume in the scrip of LGS which gave a false and misleading appearance
of trading in the said scrip. Further, I also conclude that the Noticee Nos. 1
to 12 had entered into self trades and inflated the volumes in the market
thereby, giving a false and misleading appearance of trading in the scrip of
LGS. I find from para no. 4.5.17 of the investigation report that the buy
order rate in respect of the Noticees was close to the best available sell
orders and as such the price rise on account of the said trades cannot be
attributed to the Noticees and the counter party clients (sale side) are not
from the Pabari- Parikh group. In view of the above, the Noticee Nos. 1 to
16 cannot be held guilty of violating the provisions of Regulation 4(2)(e) of
the PFUTP Regulations. Therefore, I conclude that the Noticee Nos. 1 to 16
have violated the provisions of Regulation 3(a), (b), (c), (d), 4(1) and
4(2)(a), (b) & (g) of the PFUTP Regulations thus, liable for monetary
penalty as prescribed under Section 15HA of the Act which reads as under:
Page28of32
Penalty for fraudulent and unfair trade practices

15HA. If any person indulges in fraudulent and unfair trade practices
relating to securities, he shall be liable to a penalty of twenty-five crore
rupees or three times the amount of profits made out of such practices,
whichever is higher.

44. I note that the code of conduct prescribed under the Broker Regulations
mandates that a stock broker shall maintain high standards of integrity,
promptitude and fairness and shall act with due skill, care and diligence in
the conduct of his business. The code further mandates that the Broker shall
not, inter alia, indulge in manipulative transactions with a view to distort the
market equilibrium. Therefore, I conclude that the Noticee No. 17 by
executing fictitious trades, in the nature of self and synchronised trades, on
behalf of its clients has violated the provisions as mentioned under Clause
A(1), (2) & (3) of the Code of Conduct as specified under schedule II
prescribed under Regulation 7 of the Broker Regulations thus, liable for
monetary penalty as prescribed under Section 15HB of the Act which reads
as under:
Penalty for contravention where no separate penalty has been provided
15HB. Whoever fails to comply with any provision of this Act, the rules or
the regulations made or directions issued by the Board thereunder for
which no separate penalty has been provided, shall be liable to a penalty
which may extend to one crore rupees.

45. Here, it is important to refer to the observation of the Honble Supreme
Court of India in the matter of SEBI Vs. Shri Ram Mutual Fund [2006] 68
SCL 216(SC) wherein it was held that:
Page29of32
In our considered opinion, penalty is attracted as soon as the

contravention of the statutory obligation as contemplated by the Act and the
Regulations is established and hence the intention of the parties committing
such violation becomes wholly irrelevant.

46. While determining the quantum of penalty under Sections 15HA and 15HB,
it is important to consider the factors stipulated in section 15J of SEBI Act,
which reads as under:-
15J - Factors to be taken into account by the adjudicating officer
While adjudging quantum of penalty under section 15-I, the adjudicating
officer shall have due regard to the following factors, namely:-
(a) the amount of disproportionate gain or unfair advantage, wherever
quantifiable, made as a result of the default;
(b) the amount of loss caused to an investor or group of investors as a result
of the default;
(c) the repetitive nature of the default.

47. I observe that from the material available on record, it is not possible to
quantify any gain or unfair advantage accrued to the Noticees or the extent
of loss suffered by the investors as a result of the default of the Noticees.
However, I find that the defaults were repetitive in nature. Further, the
Noticees traded in the scrip in a manner meant to create artificial volumes
and liquidity which is an important criterion capable of misleading the
investors while making an investment decision. In fact, liquidity/volumes in
particular scrip raise the issue of demand in the securities market. The
greater the liquidity, the higher is the investors attraction towards investing
in that scrip. Hence, anyone could have been carried away by the unusual
Page30of32
fluctuations in the volumes and induced into investing in the said scrip.
Besides, this kind of activity seriously affects the normal price discovery
mechanism of the securities market. People who indulge in manipulative,
fraudulent and deceptive transactions should be suitably penalized for the
said acts of omissions and commissions.

ORDER

48. In view of the above, after considering all the facts and circumstances of the
case and exercising the powers conferred upon me under Section 15-I (2) of
the SEBI Act read with Rule 5 of the Adjudication Rules, I conclude that
the proceedings against Noticee No. 5 i.e. Shri Kishor Chauhan stand
abated. Further, I hereby impose the following monetary penalties on the
other Noticees:

Sr.
No.
Name of the Noticee Penal
provisions as
per the SEBI
Act, 1992
Penalty Amount
(in `)
1. Shri Bharat Shantilal
Thakkar (Noticee No. 1)
15HA 5,00,000/-
(Rupees Five Lakh Only)
2. Shri Bipin J ayant Thaker
(Noticee No. 2)
15HA 5,00,000/-
3. Shri Bharat G Vaghela
(Noticee No. 3)
15HA 5,00,000/-
4. Shri Chirag Rajnikant
J ariwala (Noticee No. 4)
15HA 5,00,000/-
5. Shri Bhavesh Pabari
(Noticee No. 6)
15HA 5,00,000/-
6. Shri Prem Mohanlal
Parikh (Noticee No. 7)
15HA 5,00,000/-
Page31of32
7. Shri Hemant Madhusudan

Sheth (Noticee No. 8)
15HA 5,00,000/-
8. Ms Mala Hemant Sheth
(Noticee No. 9)
15HA 5,00,000/-
9. Shri Vivek Kishanpal
Samant (Noticee No. 10)
15HA 5,00,000/-
10. Shri Ankit Sanchaniya
(Noticee No. 11)
15HA 5,00,000/-
11. Shri Gaurang Ajit Seth
(Noticee No. 12)
15HA 5,00,000/-
12. Shri Ketan Babulal Shah
(Noticee No. 13)
15HA 5,00,000/-
13. Shri Vasudev Ramchandra
Kamat (Noticee No. 14)
15HA 5,00,000/-
14. Shri J igar Praful Ghoghari
(Noticee No. 15)
15HA 5,00,000/-
15. Shri Vipul Hiralal Shah
(Noticee No. 16)
15HA 5,00,000/-
16. Arcadia Share & Stock
Brokers P. Ltd
(Noticee No. 17)
15HB 2,00,000/-
(Rupees Two Lakh Only)
TOTAL 77,00,000/-
(Rupees Seventy Seven
Lakh Only)

49. In my view, the penalties imposed on the Noticees are commensurate with the
defaults committed by them.

50. The penalty amounts as mentioned above shall be paid by the Noticees through
duly crossed demand drafts drawn in favour of SEBI Penalties Remittable to
Government of India and payable at Mumbai, within 45 days of receipt of this
order. The said demand drafts should be forwarded to the Division Chief, IVD-
Page32of32
9, Securities and Exchange Board of India, SEBI Bhavan, Plot No. C4-A, G
Block, Bandra Kurla Complex, Bandra (E), Mumbai 400 051.

51. In terms of Rule 6 of the Rules, copies of this order are sent to the Noticees
and also to the Securities and Exchange Board of India.

Date: September 23, 2014 D. SURA REDDY
Place: Mumbai ADJUDICATING OFFICER

Adjudication Order Against 17 Entities in The Matter of LGS Global Limited

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Adjudication Order Against 17 Entities in The Matter of LGS Global Limited

Uploaded by

Copyright:

Available Formats

Page1of32

BEFORE THE ADJUDICATING OFFICER

1. Securities and Exchange Board of India (hereinafter referred to as SEBI),

Noticee No. 1 to 16 and collectively referred to as the Noticees), connected

proceedings initiated against Noticee No. 5 stand abated. However, I shall

(3)Manipulation: A stock-broker shall not indulge in manipulative, fraudulent or

instructions and authorization. The Noticee submitted that it had no

Penalty for fraudulent and unfair trade practices

In our considered opinion, penalty is attracted as soon as the

7. Shri Hemant Madhusudan

You might also like