Interim Order in The Matter of Radford Global Ltd.

WTM/RKA /ISD /161 /2014
SECURITIES AND EXCHANGE BOARD OF INDIA

ORDER
UNDER SECTION 11(1), 11(4) AND 11B OF THE SEBI ACT, 1992 AND SECTION 12A
OF THE SECURITIES CONTRACTS (REGULATION) ACT, 1956 - IN THE MATTER
OF RADFORD GLOBAL LIMITED AND OTHERS
1. Pursuant to preliminary examination by Bombay Stock Exchange Limited ("BSE") in the
dealings in the shares of Radford Global Limited {hereinafter referred to as "Radford"},
Securities and Exchange Board of India ("SEBI") undertook a preliminary inquiry in the dealings
in the shares of Radford for the period January 28, 2013 to March 24, 2014 {hereinafter referred
to as "the examination period"}.
2. On January 28, 2013, pursuant to a stock split, the face value of each share of 10/- was reduced
to 2/- per share. Post stock-split, during the period January 29, 2013 to July 23, 2013 ("Patch
I"), the price of the scrip of Radford opened at 49.20, rose to a high of 86.00 and closed at
74.95. During the period July 24, 2013 to March 24, 2014 ("Patch II"), the price of the scrip
continuously fell from 74.10 to 4.89. An illustration of price/volume movement in the scrip
of Radford during the examination period is given below:
No.of Shares
Close Price
2000000
1800000
1600000
1400000
1200000
1000000
800000
600000
400000
200000
0
90
80
70
60
50
40
30
20
10
0
*It was noticed that during the period February 27, 2012 to January 28, 2013("Pre-Patch I") the price of the shares
of Radford was at 3.20, rose to a high of 241.35 and closed at 241.35.
----------------------------------------------------------------------------------------------------------------------------------------------------Order in the matter of Radford Global Ltd.

Page 1 of 27
Brought to you by http://StockViz.biz
3. The preliminary examination revealed that there was a pattern in which the shares of Radford
were being traded. The modus operandi adopted by the traders in the scrip is as under :
i. Firstly, shares were allotted on preferential basis in Pre-Patch I to entities connected/related
directly or indirectly to Radford.
ii. Then, just prior to the expiry of lock-in of shares issued on preferential basis, Radford
announced a stock-split to make a passage for preferential allottees to exit on expiry of the
lock-in since the stock split would reduce the per share price and increase liquidity.
iii. After the expiry of lock-in, it was noted that after the stock split, the preferential allottees
sold the shares to entities connected/related, directly or indirectly, to Radford
Group/Suspected Entities, thereby raking in huge profits.
iv. It was also noted that the said price movement was not backed by fundamentals of the
company and its financials.
4. During the beginning of Pre-Patch I, on February 16, 2012, Radford had allotted 91,00,000
equity shares of 10/- each at a premium of 5/- on preferential basis to 48 entities aggregating
to 13.65 cr. (list provided in Annexure A). Out of these 48 entities, 4 entities viz. Brij Bhushan
Singal, Neeraj Singal, Ritu Singal and Uma Singal are connected to the Radford and 19,00,000
shares (20.87% of total number of shares allotted) were allotted to these four entities. The shares
allotted on preferential basis to aforesaid allottees were locked-in for a period of 1 year in
compliance with Securities and Exchange Board of India (Issue of Capital and Disclosure
Requirements) Regulations, 2009. Thus, these shares held by the said 48 allottees pursuant to
preferential allotment and split were not tradable in this lock in period.
5. On analysing the financial statements of Radford, the following was observed:Table: I - Financial year-wise particulars of Radford
FY 2011-12
FY 2012-13
FY 2013-14
Total Number of paid

up Shares (Face Value)
1,40,62,300(10)
7,03,11,500(2)
7,03,11,500(2)
Total Revenue
Profit after tax
3.04 crore
0.06 crore
22.28 crore
0.46 crore
11.04 crore
0.18 crore
Earning per share
0.01
0.07
0.03
6. From Table I, it is observed that the total number of paid up shares of Radford, after taking into
account the stock-split dated January 28, 2013, increased by 5 times to 70,311,500. From the
Annual Reports of Radford for FY 2011-12 and FY 2012-2013, it was observed that it is in the
business of Staffing Services, Textile and Real Estate and it had earned a profit of 6,17,264/during 2011-12 and 45,87,092/- during FY 2012-13. From the Annual Report of Radford for
Page 2 of 27
the FY 2012-2013 it is observed that for the FY ended 2012 the EPS was 0.01/- and for the
FY ended March 31, 2013 EPS was 0.07/-. It was further noted that during the Pre-Patch I
there was no material corporate announcement made by Radford which could support such
price rise in its scrip. It is observed from the above facts that the price rise of 7442% during PrePatch I was not justified and aberrant. Also the movement was extremely aberrant vis-a-vis the
movement of the stock market as the Sensex only moved from 17,645 to 20,103.
7. The sharp price rise in the scrip as discussed above was not supported by fundamentals of
Radford or any other external factor. The price in the scrip increased prior to the expiry of the
lock-in period on the shares held by the aforesaid allottees pursuant to preferential allotment and
split. After the expiry of the lock-in period, the price and volume in the scrip increased
substantially. Considering such pattern, the trading in the scrip in three patches as mentioned
above was analyzed. The analysis of the trading during the patches was carried out with a focus
on the following: The trading frequency;
The volume generated;
Contribution to price rise;
Buying behavior as observed from Last Traded Price ("LTP") data.
8. On analysis of trading activity in the Scrip, it was observed that certain entities was primarily
involved in pushing the price up during the lock in period, which is Pre-Patch I, by contributing
to positive LTP through first trades with negligible volumes. Another group of entities were
acting as buyers in Patch-I in order to provide exit to preferential allottees and in the process
creating artificial volume which has been dealt with in detail subsequently.
9. During Pre-Patch I, the scrip opened at 3.20 (pre-split price) on February 27, 2012 and rose to
a high of 241.35 and closed at 241.35 on January 28, 2013. During this period, the scrip was
traded with an average volume of 98 shares per day and total volume of 11,950 shares in 121
trading days with an average of 1.6 trades per day. It was observed that price of the scrip was
influenced by certain entities primarily through first trades during this period. It was noticed that
these entities by putting 1 or 2 trades per day with negligible/ very less quantity of buy orders
contributed significantly to the price rise. From LTP analysis, it is observed that price of the
scrip increased from 3.20 to 241.35 mainly through first trades in 121 instances.
10. It was observed that in Pre-Patch I, out of a total of 121 instances of trades establishing new
high price in the scrip, certain entities established new high price on 91 instances (75.21% to
total instances). The contribution of these entities in establishing new high price was 204.3/----------------------------------------------------------------------------------------------------------------------------------------------------Order in the matter of Radford Global Ltd.
Page 3 of 27
out of total price rise of 246.7/-, which constitutes 82.81% of the total new high prices. The
details of contribution to price rise by these entities during Pre-Patch I are as under:
Table II : Details of entities and their contribution to price rise in Pre-Patch I
Sr.
No.
Clnt Name
Clnt Pan
Taran Kumar
Rungta
ASVPR5947G
Prem Lata Nahar
AFAPN8764M
3
4
5
Manjulaben
Sukhdev Pandya
Rajat Share Broking
Pvt Ltd
Rajesh Pravinkumar
Jasani
ALVPP7764J
AAACR2695B
ACWPJ4705B
Bharat Bagri Bagri
AADHB8488A
Jayesh Narendra
Kesharia
AAEHJ1610D
Total
Trading Member
Name
Shilpa Stock Broker

Pvt. Ltd.
Sanghavi Brothers
Brokerage Ltd.
Shilpa Stock Broker
Pvt.Ltd.
Monarch Research &
Brokerage Pvt.Ltd.
Bcb Brokerage
Pvt.Ltd.
Bharti Thakkar India
Securities Pvt.Ltd.
No.
of I
nsta
nces
% to
Total
Insta
nces
Pos
LTP
Contri
of the
Client
as a
buyer
14
11.57
45.21
246.7
18.33
25
20.66
43.3
246.7
17.55
15
12.4
32
246.7
12.97
4.96
25.5
246.7
10.34
5.79
24.85
246.7
10.07
16
13.22
17.86
246.7
7.24
6.61
15.58
246.7
6.32
91
75.21
204.3
246.7
82.81
Tot
Pos
Contri
In Sec
Pos
Contr
i (in
%)
11. It was also observed that most of these aforementioned entities had also traded and were
instrumental in contributing to the price rise of other stocks. It was further observed that Taran
Kumar Rungta, Prem Lata Nahar and Rajat Share Broking Pvt. Ltd are related /connected to
Shilpa Stock Broker Pvt. Ltd and Bharat Bagri Bagri is related to BCB Brokerage Pvt. Ltd. through
whom they have traded. Ms. Prem Lata Nahar is the Mother of Rakesh Nahar who is the
owner/director of Shilpa Stock Broker Pvt. Ltd. and Bharat Bagri is the Promoter/ director of
BCB Brokerage Pvt. Ltd and share common address with BCB Brokerage Pvt. Ltd.
12. The selection of scrips for trading, the trading pattern and connectivity with brokers cast doubt
on the intent of these entities while trading in the securities market. The sheer number of scrips
with such dubious price-rise track record in which the said entities and their connected brokers
are involved also cast doubts on their conduct in the securities market.
13. On analysis of trading activity during Patch I, certain related/connected entities ("Radford
Group") to Radford were found to be net buyers to the preferential allottees and thereby created
Page 4 of 27
artificial demand for the supply of shares from preferential allottees. Further, it was also noticed
that a group of entities connected/related ("Suspected Entities") to each other, by virtue of
common address;/e-mail id. were trading in the shares of Radford amongst themselves. During
the Patch I, significant increase in the trading volume was observed and it appears that most of
the entities were acting as counterparty to the preferential allottees. Also on further examination
direct/ indirect relationship were established among these entities through Know Your Client
(KYC) details , their bank statements, off-market transactions amongst themselves, and
information available on the Ministry of Corporate Affairs (MCA) website. List of such entities
are annexed as Annexure - B and hereinafter referred to as the "Radford Group & Suspected
Entities".
14. It is observed that during Patch I, the preferential allottees were net sellers and entities forming
part of the Radford Group & Suspected Entities were net buyers, a snapshot of which is given
below:Table III - Exit provided by Radford Group & Suspected Entities to allottees
Preferential
Allottees
Radford Group
& Suspected
Entities
Shares
purchased
% of
from
preferential
preferential shares Sold
allottees
Shares
sold
% of
Total
allotted
shares
4,15,99,539
91.43%
2,76,84,200
(refer table
IV)
67.77%
Total
shares
bought in
the Patch I
by
% of Net
Buy
4,08,51,126
70.01%
(refer table
IV)
15. It is observed from Table III that most of the trades were taking place between the preferential
allottees and the entities of Radford Group & Suspected Entities . During this period, the allottees
were found to be selling and in the process gaining a huge profit/gain. It was observed that
Radford Group & Suspected Entities contributed 70.01% to the net buy trade during this patch. The
details of counter parties for sale transactions by preferential allottees is given below:

Page 5 of 27
Table - IV: Details of counter parties for sale transactions
Sr.
No.
Client Name
1
2
Radford Group
Amrusha Mercantile
1
Private Limited
Spice Merchants Private
2
Limited
Shelter Sales Agency
Private Limited Shelter
3
Sales Agency Private
Limited Shelter Sales
Agency Private Limited
Udbal Mercantile Private
4
Limited
Devakantha Trading
5
Private Limited
Winall Vinimay Private
6
Limited Ltd
7
Pine Animation Limited
Limestone Properties
8
Private Limited
Runicha Merchants
9
Private Limited
Dhanleela Investments
10
& Trading Company
Limited
Apex Commotrade
11
Private Limited Ltd
Shivkhori Construction
12
Private Limited
Signet Vinimay Private
13
Limited
Anjali Suppliers Private
14
Limited
Sanklap Vincom Private
15
Limited
16
Rangan Vincom Private
Clnt Pan
Net Buy
in Patch I
Vol of
Net
Buy in
Patch I
Shares
purchase
d from
preferenti
al allottes
during
post split
period
% of shares
bought
from
preferential
allottes to
the Net
Buy in
Patch I
7=6/4*100
AALCA0340D
3317965
5.69
2281121
68.75
AAPCS7492G
3287475
5.63
2422355
73.68
AASCS1797F
3122146
5.35
2312395
74.06
AABCU2648C
2767601
4.74
1588720
57.40
AADCD7044B
2475491
4.24
1705206
68.88
AAACW8004B
2144989
3.68
1764206
82.25
AAECM0267A
1858368
3.18
1081586
58.20
AACCL0133G
1764054
3.02
1357040
76.93
AAECR0580M
1584913
2.72
1325164
83.61
AAACR1770P
1464988
2.51
680586
46.46
AAJCA4459K
1223735
2.10
1033114
84.42
AAPCS7850L
926220
1.59
896440
96.78
AAMCS1712Q
903711
1.55
913195
101.05
AAJCA1784D
893000
1.53
747275
83.68
AAMCS1711P
892600
1.53
613910
68.78
AAGCR1715E
725705
1.24
720970
99.35

Page 6 of 27
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
Limited
Pyramid Trading And
Finance Ltd
Divyadrishti Merchants
Pvt Ltd
Divya Drishti Traders
Pvt Ltd
Ladios Trading Private
Limited
Skm Travels Private
Limited
Avlokan Dealcom
Private Limited
Topwell Properties
Private Limited
Esquire Enclave Private
Limited
Natural Housing Private
Limited
Radison Properties
Private Limited
Ridhi Vincom Pvt Ltd
Dhanraksha Vincom
Pvt Ltd
Kingfisher Properties
Private Limited
Vibgyor Financial
Servicepvt Ltd
Blue Circle Services
Limited
Amrit Sales Promotion
Pvt Limited
Burlington Finance
Limited
Bazigar Trading Private
Limited
Katyani Commodities
Private Limited
Manimudra Vincom
Private Limited
Devatma Distributors
Private Limited
Symphony Merchant Pvt
Ltd
Scope Vyapar Pvt. Ltd.
Total (I)
AAACP2548R
647675
1.11
518992
80.13
AABCD8147K
537000
0.92
499448
93.01
AABCD8146J
532000
0.91
450691
84.72
AACCL3868N
507160
0.87
473093
93.28
AAICS0688K
494050
0.85
443724
89.81
AALCA1583G
389706
0.67
368706
94.61
AADCT8403C
250000
0.43
160600
64.24
AACCE7065J
225000
0.39
87233
38.77
AADCN6251G
200000
0.34
183926
91.96
AAFCR2818B
160125
0.27
114517
71.52
AAECR9858C
115000
0.20
115000
100.00
AADCD6028P
113390
0.19
112390
99.12
AAECK3394G
95000
0.16
92400
97.26
AAACV8378B
82000
0.14
37840
46.15
AAACB2131L
64073
0.11
60323
94.15
AACCA3220D
47000
0.08
47000
100.00
AABCB2575P
34500
0.06
30000
86.96
AABCB3052B
34500
0.06
32347
93.76
AAECK6244R
25000
0.04
70000
280.00
AADCM4316K
23500
0.04
23200
98.72
AADCD7140G
11950
0.02
11950
100.00
AADCS5411K
5000
0.01
5000
100.00
0
33946590
0.01
58.18
11000
25392663
0.00
74.80
AAICS6023N

Page 7 of 27
Suspected Entities
Jayant Security &
1
Financeltd
2
Trimurthi Finvest Ltd
3
Purvi Finvest Limited
East West Finvest India
4
Limited
East West Finvest India
5
Limited
Total (II)
AAACJ4848G
AAACT6383N
AABCP6564C
3430961
1051222
1077750
5.88
1.80
1.85
AAACE6834D
1123353
1.92
AADCE1236G
221250
6904536
0.38
11.83
40851126
70.01
Grand Total (I+II)
1535303
44.75
329978
129253
31.39
11.99
224803
20.01
72200
32.63
2291537
33.19
27684200
67.77
16. It is observed that 46 allottees made a collective profit of 313.01 Crore on their total
investment of 12.99 crore, a substantial return of approximately 2309 % on their investment in
a period of 18 months (including the lock in period). It is evident from the above analysis of
trading in Patch I that the entities of Radford Group & Suspected Entities provided a hugely
profitable exit to the allottees, who also were related directly/indirectly to Radford. The
profit/gain earned by the allottees during Patch I is given below:Table V: Details of the trades carried out by allottees and profit calculation
SrNo
Client
Name
Achal
Chand
Balar
Abhishek
Achalcha
nd Balar
PAN
Qty
Allotted
Qty Post
Stock
Split (Jan
29, 2013)
Price
after
Stock
Split
Qty
Bought
in Off
Market
Qty
Sold in
Off
Market
Total
Qty in
Hand
Sum of
SOLD
QTY
Sell
Rate
Profit Earned
()
Bala
nce
Qty
ABAPB8
617M
150000
750000
500000
250000
189060
80.36
14625025
6094
0
AATPB8
811B
250000
250000
166000
85.22
13648846
8400
0
Piyush
Kumar
Balar
AEMPB6
394Q
250000
250000
140000
83.39
11254028
1100
00
AfsarZaid
i
AADPZ8
571G
100000
500000
500000
500000
80.04
38522857
Amresh
Anantrai
Mody
AACPM4
024E
100000
500000
450000
50000
50000
79.85
3842500
Hasumati
Anantrai
Mody
AJSPM79
35P
450000
450000
450000
83.85
36381293
Anil Rajat
Agarwal
& Sons
(Huf)
AAFHA0
709M
60000
300000
300000
300000
69.11
19831633

Page 8 of 27
Qty Post
Stock
Split (Jan
29, 2013)
Price
after
Stock
Split
Qty
Bought
in Off
Market
Qty
Sold in
Off
Market
250000
1250000
1250000
1250000
79.18
95222911
150000
750000
750000
750000
79.34
57254421
200000
1000000
9001
1009001
1009001
83.22
80945955
AEFPS62
98M
580000
2900000
2900000
2900000
82.12
229451547
ACDPT3
428N
100000
500000
500000
500000
81.3
39148937
AADPM
9919M
200000
1000000
1000000
1000000
55.79
52788678
250000
1250000
1250000
1250000
79.2
95246103
200000
1000000
1000000
1000000
71.91
68913912
AHEPG0
025A
200000
1000000
1000000
1000000
76.72
73720095
ADPPK9
874N
200000
1000000
1000000
1000000
77.8
74800649
AAJPV47
54H
100000
500000
500000
500000
82.99
39994974
AABPJ28
35R
100000
500000
500000
500000
82.64
39819781
AABPR9
949J
100000
500000
500000
500000
81.16
39080552
ABWPT8
000C
100000
500000
500000
500000
81.39
39195997
AHPPD4
223L
200000
1000000
9001
990999
990999
70.65
67041531
AAAPL9
611J
100000
500000
500000
500000
58.83
27916282
AFFPP52
07G
100000
500000
500000
500000
79.31
38156782
AKJPB85
72F
100000
500000
500000
500000
72.34
34669719
Mohan
Mittal
APFPM0
496Q
150000
750000
750000
750000
79.86
57648728
Mohit
Aggarwal
Mukesh
Mittal
ADSPA9
301K
AJGPM2
125D
150000
750000
750000
750000
76.29
54964382
150000
750000
750000
750000
80.1
57826737
26
Naresh
Nemchan
d Shah
ACRPS01
82J
400000
2000000
2000000
2000000
78.78
151568641
27
Neeraj
Singal
ANRPS7
986B
580000
2900000
2900000
2900000
79.61
222156517
SrNo
5
6
7
8
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Client
Name
Ashok
Jiwrajka
Babita
Mittal
Bimal
Desai
Brij
Bhushan
Singal
Dalsukh
Ujamshi
Trevadia
Dilip
Chotalal
Morzaria
Dilip
Jiwrajka
GM
Lingaraju
GM
Prasanna
Kumar
G S Anith
Kumar
Harikisha
nS
Virmani
Hitesh
Jain
Hukamsi
ngh
Bhawarsi
nghji
Rajpurohi
t
Jyoti Anil
Trevadia
Jyotsna
Jitendra
Desai
Kalpita
Suresh
Luniya
Kamal
Indur
Punwani
Mayuri
Darshan
Bhanusha
li
PAN
AACPJ36
10K
AAIPG4
573G
AAKPD3
160A
AAGPJ87
56J
AEYPM5
850Q
Qty
Allotted
Total
Qty in
Hand
Sum of
SOLD
QTY
Sell
Rate
Profit Earned
()

Page 9 of 27
Bala
nce
Qty
SrNo
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
Qty Post
Stock
Split (Jan
29, 2013)
Price
after
Stock
Split
Qty
Bought
in Off
Market
Qty
Sold in
Off
Market
200000
1000000
1000000
1000000
78.55
75549009
ACGPA7
438L
200000
1000000
1000000
1000000
82.47
79471984
AABTP7
516K
200000
1000000
1064874
1064874
79.01
76033232
ACSPA4
725A
200000
1000000
1000000
500000
78.47
37735000
5000
00
AAIHP6
229C
200000
1000000
1000000
1000000
82.6
79600930
ACPPJ98
53R
100000
500000
500000
500000
82.61
39805257
150000
750000
750000
750000
79.96
57719482
150000
750000
750000
750000
81.27
58703897
515000
2575000
2575000
2575000
82.77
205404070
150000
750000
750000
750000
80.11
57833909
100000
500000
500000
500000
82.4
39700599
150000
750000
750000
750000
75.32
54238750
250000
1250000
1250000
1250000
79.2
95249153
ACAFS8
650G
250000
1250000
1250000
239604
78.75
18149101
1010
396
AFAPT5
888A
100000
500000
500000
500000
80.07
38535769
AOQPA9
034E
150000
750000
750000
750000
79
57001648
AAEPM5
924H
100000
500000
500000
500000
46.16
21577500
ANRPS7
987A
225000
1125000
1125000
1125000
78.6
85053164
AAPPT1
825P
200000
1000000
1000000
1000000
80.15
77154413
8660000
43300000
959001
959001
43300000
41599539
313,01,56,898
1765
336
Client
Name
PAN
Nishit
Agarwal
Beneficiar
y Trust
AABTN3
350K
Pinky
Agarwal
Pratik
Agarwal
Beneficiar
y Trust
Praveen
Kumar
Agarwal
Praveen
Kumar
Agarwal
Huf
Rajendra
Mangilal
Jain
Renu
Aggarwal
Renu
Mittal
Ritu
Singal
Santosh
Aggarwal
Shailesh
Mangilal
Jain
Shilpa
Aggarwal
Surendra
Jiwrajka
Sushant
Investme
nts
Tanvi
Bhavik
Trevadia
Tarun
Aggarwal
Ujwala
Namdev
Mane
Uma
Songal
Yogesh
Popatlal
Thakkar
AAEPA1
694C
AGMPM
1488Q
ABHPS3
711M
ABAPA4
548E
AAAPJ67
65F
AEXPA1
230M
AACPJ43
16L
Total
Qty
Allotted
Total
Qty in
Hand
Sum of
SOLD
QTY
Sell
Rate
Profit Earned
()
17. The transactions wherein the entities of Radford Group & Suspected Entities bought most of the
shares sold by the allottees cannot be just a coincidence particularly when sellers by virtue of
being allotees and prima facie connected / have nexus with Radford and its promoters/ directors
and buyers are the entities connected with Radford and its promoters /directors. From the
Page 10 of 27
Bala
nce
Qty
analysis presented for Pre-Patch I, it is observed that the shares of Radford were not in demand
by the general investors of the market and saw very low volume on most of the trading days and
hence could not have commanded the price as observed in Patch I. In any market, a sudden
supply, if not matched by similar demand, leads to price fall. Considering the same, any rational
investor would not have dumped a large number of shares without facing the risk of a significant
price fall until and unless he was sure of the demand side absorbing the supply. In this peculiar
case, the entities of Radford Group & Suspected Entities created the demand against the supply
from the preferential allotters. In the whole process, the principle of price discovery was kept
aside and the market lost its purpose. It is evident from the above analysis that the Radford Group
& Suspected Entities provided a hugely profitable exit to the allottees. This could be only possible
if the allottees, Radford Group & Suspected Entities and Radford and its promoter/ directors were
hand in glove with each other. The said finding is also corroborated by the fact that in few
instances/ cases, it is observed that the buyers are related /connected entities of preferential
allottees.
18. From the facts stated above, it can be safely assumed that the entire modus operandi of allotting
preference shares at a premium, announcing a stock split and then bringing in connected entities
to provide exit was a scheme devised to rake in ill-gotten gains.
19. In Patch II, the price of the shares of Radford has decreased from 74.10 to 4.89, i.e. a fall of
approximately 93.4%. Also the volumes have again decreased by 67% of the volume of Patch I.
On analysis of the top 20 sellers during the period, it was noted that 9 entities of the Radford
Group & Suspected Entities have sold approximately 37% of the net traded volume. Also on
analysis of the negative LTP contribution, it was noted that the top 20 entities had contributed
72% of the price fall of which only 13% was contributed by Radford Group & Suspected Entities . It
indicates that a sizeable quantum of gullible investors had started trading in the shares of
Radford and were disposing at any possible price.
20. From the analysis of the trading across Patches, it can be comfortably stated that the modus
operandi of allotting shares on preferential basis at a premium, pumping the share price artificially
and then dumping the price so that the same cycle could be repeated, demonstrates the mala fide
of the Radford Group & Suspected Entities . Also the mechanism is being presumably used to
deceive the authorities by laundering black money and raking in tax-free profits.
21. It was noted that the price movement of the shares are negligible Post examination period till
the date of this order.

Page 11 of 27
22. From the above examination and factors as described in Annexure B, I note that the allottees,
Radford and Radford Group & Suspected Entities are connected to each other. In this regard, I note
that the Hon'ble SAT has, in many cases such as Classic Credit Ltd. vs. SEBI (SAT Appeal no.
68/2003, Order dated December 8, 2006), Classic Credit Ltd. vs. SEBI (SAT Appeal no. 76/ 2003,
Order dated January 9, 2007) and Veronica Financial Services Ltd. vs. SEBI (SAT Order dated
August 24, 2012), held that connection/relations can be established on the basis of factors
including the common addresses, common directors/ shareholders, etc.
23. It is pertinent to mention that the key to the scheme of operations employed by Radford Group &
Suspected Entities prima facie lies in the preferential allotment of shares made by Radford. Due to a
lock-in of one year on shares any gains made on the sale of such shares makes them eligible for
long term capital gains ("LTCG"). From the observations of the preliminary inquiry it is inter alia
noted that :a) the fund brought in by way of preferential allotment was utilised for purposes other
than those disclosed;
b) even when substantial number of shares i.e. 91 lakh shares (455 lakh shares after split)
were locked-in and non transferable / tradable, price of the scrip increased substantially
to the extent of 7442% with a very small chunk of volume / purchases by certain
entities;
c) After the expiry of the lock-in period (i.e. in Patch I), the average volume increased
astronomically to the extent of 505066% (5050 times). Such increase in volume was
mainly on account of matched trading amongst Radford Group & Suspected Entities and
allottees.
d) 46 out of the 48 preferential allottees sold 91.43% shares allotted to them by Radford at
the price increased on account of the aforesaid manipulative trading in Pre-Patch I.
24. From the above facts and circumstances it can reasonably be inferred that the preferential
allottees acting in concert with Radford Group & Suspected Entities have misused the stock
exchange system to generate fictitious LTCG. It is pertinent to note that LTCG is tax exempt.
25. In the facts and circumstances of this case, I am of the view that preferential allotment was used
as a tool for implementation of the dubious plan, device and artifice of Radford Group & Suspected
Entities and preferential allottees. One could argue that in order to make LTCG, the preferential
allottees in question could have bought in secondary market and waited for a year before selling
the shares. In the instant case, probably the preferential allotment route was preferred over
secondary market route because the share capital of Radford prior to preferential allotment was
very small, i.e., 1,40,62,300 shares (Face Value: 10) to accommodate the required fictitious
Page 12 of 27
LTCG of 313 crore approximately. As such the capital expansion through preferential
allotment and stock split provided much bigger source to the persons involved in terms of
volume and price manipulation to facilitate the whole operation.
26. Since prior to the trading in its scrip during the Examination Period, Radford did not have any
significant financial standing in the securities market, in my view, the only way it could have
increased its share value is by way of market manipulation. In this case, it is noted that the traded
volume and price of the scrip increased substantially only after Radford Group & Suspected Entities
and allottees started trading in the scrip. The average volume increased by 5,05,066 % (5050
times) during the Patch I, i.e., from 98 shares per day to 4,95,063 shares per day and the price
increased by 74.8% during the same period, i.e., from 49.2 to 86. Radford Group & Suspected
Entities were trading in the scrip above the LTP and their trades created artificial volumes and
manipulated the price of the scrip during the examination period. It is further noted that on the
days when Radford Group & Suspected Entities were not trading, the trading volumes in the scrip
were very low and the substantial increase in traded volumes as observed in this case was mainly
due to their trading. I further note that Radford Group & Suspected Entities and allottees traded
amongst themselves as substantiated by their matching contribution to net buy and net sell in
Patch I. There was no change in the beneficial ownership of the substantial number of traded
shares as the buyers and sellers both were part of the common group and were acting in
league/concert to provide LTCG benefits to the allottees. In view of the above, I prima facie find
that Radford Group & Suspected Entities and allottees used securities market system to artificially
increase volume and price of the scrip for making illegal gains to and to convert ill-gotten gains
into genuine one.
27. I am of the considered view that the scheme, plan, device and artifice employed in this case,
apart from being a possible case of money laundering or tax evasion which could be seen by the
concerned law enforcement agencies separately, is prima facie also a fraud in the securities market
inasmuch as it involves manipulative transactions in securities and misuse of the securities
market. The manipulation in the traded volume and price of the scrip by a group of connected
entities has the potential to induce gullible and genuine investors to trade in the scrip and harm
them. As such the acts and omissions of Radford Group & Suspected Entities and allottees are
fraudulent as defined under regulation 2(1)(c) of the SEBI (Prohibition of Fraudulent and Unfair
Trade Practices relating to Securities Market) Regulations, 2003 (PFUTP Regulations) and are
in contravention of the provisions of regulations 3(a), (b), (c) and (d) and 4(1), 4(2)(a), (b), (e)
and (g) thereof and section 12A(a), (b) and (c) of the SEBI Act, 1992. The said regulations are
reproduced hereunder:-

Page 13 of 27
SEBI ACT
Prohibition of manipulative and deceptive devices, insider trading and substantial
acquisition of securities or control.
"12A. No person shall directly or indirectly
(a) use or employ, in connection with the issue, purchase or sale of any securities listed or proposed to be
listed on a recognized stock exchange, any manipulative or deceptive device or contrivance in contravention of
the provisions of this Act or the rules or the regulations made thereunder;
(b) employ any device, scheme or artifice to defraud in connection with issue or dealing in securities which are
listed or proposed to be listed on a recognised stock exchange;
(c) engage in any act, practice, course of business which operates or would operate as fraud or deceit upon
any person, in connection with the issue, dealing in securities which are listed or proposed to be listed on a
recognised stock exchange, in contravention of the provisions of this Act or the rules or the regulations made
thereunder;"
PFUTP REGULATIONS, 2003

"Prohibition of certain dealings in securities
3. 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;
(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;

Page 14 of 27
(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 security;
(f) .
(g) entering into a transaction in securities without intention of performing it or without intention of change of
ownership of such security; "
28. I note that the directors of Radford during the relevant time (i.e. Prakash Bhawarlal Biyani,
Manish Nareshchandra Shah, Rajesh Kumar Maheshwari and Nitin Shivratan Murarjka), being
in control of the day to day affairs of Radford, had the knowledge of its acts and omissions. They
were also under an obligation to ensure that acts and transactions of Radford were not in
violation of any of the applicable provisions of SEBI Regulations or other applicable laws. I,
therefore, prima facie find that these directors were responsible for Radford 's acts and omissions
in this case.
29. I am of the opinion that a detailed investigation of the entire scheme employed in this case is
necessary to find out the role of any other entity therein including LTP contributors, Suspected
entities, connection amongst the concerned entities and the ultimate owners of funds used for
manipulating the price of the scrip. Therefore, while SEBI would investigate into the probable
violations of the securities laws, the matter may also be referred to other law enforcement
agencies such as Income Tax Department, Enforcement Directorate and Financial Intelligence
Unit for necessary action at their end as may be deemed appropriate by them.
30. SEBI strives to safeguard the interests of a genuine investor in the Indian securities market. The
acts of artificially increasing the price of scrip mislead investors and the fundamental tenets of
market integrity get violated with impunity due for such acts. Under the facts and circumstances
of this case, I prima facie find that the acts and omissions of Radford Group & Suspected Entities and
allottees as described above is inimical to the interests of participants in the securities market.
Therefore, allowing the entities that are prima facie found to be involved in such fraudulent, unfair
and manipulative transactions to continue to operate in the market would shake the confidence
of the investors in the securities market.
31. Considering these facts and the indulgence of a listed company in such a fraudulent scheme,
plan, device and artifice as prima facie found in this case, I am convinced that this is a fit case
where, pending investigation, effective and expeditious preventive and remedial action is
Page 15 of 27
required to be taken by way of ad interim ex -parte in order to protect the interests of investors and
preserve the safety and integrity of the market.
32. In view of the foregoing, in order to protect the interest of the investors and the integrity of the
securities market, I, in exercise of the powers conferred upon me in terms of section 19 read
with section 11(1), section 11 (4) and section 11B of the SEBI Act, 1992, pending
inquiry/investigation and passing of final order in the matter, hereby restrain the following
persons/entities from accessing the securities market and buying, selling or dealing in securities,
either directly or indirectly, in any manner, till further directions:Sr. No. Client Name
Client PAN
Company
1
Radford Global Ltd.
AABCM5771E
Directors of Radford Global Ltd.

2
3
4
5
Prakash Bhawarlal Biyani

Manish Nareshchandra Shah
Rajesh Kumar Maheshwari
Nitin Shivratan Murarka
AJNPB0702E
AELPS8560A
ACJPM4653L
AMBPM9321M
Promoters of Radford Global Ltd.

6
Radford InvestmentServicesPvtLtd
AACCG9982A
Director of Radford Investment Services Pvt. Ltd.

7
8
Roshan Dwarkani
Suresh Kumar Saini
ATXPD7040B
BCXPS0818J
Preferential Allottees
9
10
11
12
13
14
15
16
17
18
19
AachalchandBalar
PiyushKumarBalar
AbhishekKumarBalar
AfsarZaidi
AmreshA.Mody
HasumatiA.Mody
AnilRajatAgarwal&Sons.Huf.
AshokBJiwrajka
BabitaMittal
BimalJDesasi
BrijBhushanSingal
ABAPB8617M
AEMPB6394Q
AATPB8811B
AADPZ8571G
AACPM4024E
AJSPM7935P
AAFHA0709M
AACPJ3610K
AAIPG4573G
AAKPD3160A
AEFPS6298M

Page 16 of 27
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
DalsukhUjamshiTrevadia
DilipBJiwrajka
DilipChotalalMorzaria
GMPrasannaKumar
GSAnithKumar
HariKishanSuderlalVermani
HiteshMangilalJain
HukamsinghB.Rajpurohit
JyotiAnilTrevadia
JyotsnaJitendraDesai
KalpitaLuniya
KamalPunwani
LingarajuGM
MayuriDarshanBhanushali
MohanMittal
MohitAggarwal
MukeshMittal
NareshNemchandShah
NeerajSingal
NishitAgarwalBenTrust
PinkyAgarwal
PratikAgarwalBenTrust
PraveenKumarAgarwal
PraveenKumarAgarwalHuf
RajendraMangilalJain
RenuAggarwal
RenuMittal
RituSingal
SantoshAggarwal
ShaileshMangilalJain
ShilpaAggarwal
SmtUjwalaNamdevMane
SurendraBJiwrajka
SushantInvestments
TanviBhavikTrevadia
TarunAggarwal
UmaSingal
ACDPT3428N
AAGPJ8756J
AADPM9919M
AHEPG0025A
ADPPK9874N
AAJPV4754H
AABPJ2835R
AABPR9949J
ABWPT8000C
AHPPD4223L
AAAPL9611J
AFFPP5207G
AEYPM5850Q
AKJPB8572F
APFPM0496Q
ADSPA9301K
AJGPM2125D
ACRPS0182J
ANRPS7986B
AABTN3350K
ACGPA7438L
AABTP7516K
ACSPA4725A
AAIHP6229C
ACPPJ9853R
AAEPA1694C
AGMPM1488Q
ABHPS3711M
ABAPA4548E
AAAPJ6765F
AEXPA1230M
AAEPM5924H
AACPJ4316L
ACAFS8650G
AFAPT5888A
AOQPA9034E
ANRPS7987A
57
YogeshPopatlalThakkar
AAPPT1825P

Page 17 of 27
Radford Group
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
Amrit Sales Promotion Pvt Limited

Amrusha Mercantile Private Ltd
Anjali Suppliers Private Limited
Apex Commotrade Private Limited
Avlokan Dealcom Private Limited
Bazigar Trading Private Limited
Blue Circle Services Limited
Burlington Finance Limited
Devakantha Trading Private Limited
Devatma Distributors Private Limited
Dhanleela Investments & Trading Company
Limited
Dhanraksha Vincom Pvt Ltd.
Divya Drishti Traders Pvt Ltd
Divyadrishti Merchants Pvt Ltd
Esquire Enclave Private Limited
Katyani Commodities Private Limited
Kingfisher Properties Private Limited
Ladios Trading Private Limited
Limestone Properties Private Limited
Manimudra Vincom Private Limited
Natural Housing Private Limited
Pine Animation Limited
Pyramid Trading And Finance Ltd
Radison Properties Private Limited
Rangan Vincom Private Limited
Ridhi Vincom Pvt Ltd
Runicha Merchants Private Limited
Sanklap Vincom P Ltd
Scope Vyapar Private Limited
Shelter Sales Agency Pvt Ltd #
Shivkhori Construction Private Limited
Signet Vinimay Private Limited
SKM Travels Private Limited
Spice Merchants Private Limited
Symphony Merchant Pvt Ltd
Topwell Properties Private Limited
Udbal Mercantile Private Limited
AACCA3220D
AALCA0340D
AAJCA1784D
AAJCA4459K
AALCA1583G
AABCB3052B
AAACB2131L
AABCB2575P
AADCD7044B
AADCD7140G
AAACR1770P
AADCD6028P
AABCD8146J
AABCD8147K
AACCE7065J
AAECK6244R
AAECK3394G
AACCL3868N
AACCL0133G
AADCM4316K
AADCN6251G
AAECM0267A
AAACP2548R
AAFCR2818B
AAGCR1715E
AAECR9858C
AAECR0580M
AAMCS1711P
AAICS6023N
AASCS1797F
AAPCS7850L
AAMCS1712Q
AAICS0688K
AAPCS7492G
AADCS5411K
AADCT8403C
AABCU2648C

Page 18 of 27
95
96
Vibgyor Financial Service Pvt Ltd

Winall Vinimay Private Limited
AAACV8378B
AAACW8004B
Suspected Entities
97
98
99
100
101
Jayant Security & Financeltd

Trimurthi Finvest Ltd
Purvi Finvest Limited
East West Finvest India Limited
East West Finvest India Limited
AAACJ4848G
AAACT6383N
AABCP6564C
AAACE6834D
AADCE1236G
Taran Kumar Rungta

Prem Lata Nahar
Manjulaben Sukhdev Pandya
Rajat Share Broking Pvt Ltd
Rajesh Pravinkumar Jasani
Bharat Bagri Bagri
Jayesh Narendra Kesharia
ASVPR5947G
AFAPN8764M
ALVPP7764J
AAACR2695B
ACWPJ4705B
AADHB8488A
AAEHJ1610D
Other
102
103
104
105
106
107
108
33. This order is without prejudice to the right of SEBI to take any other action that may be initiated
against the aforementioned entities in accordance with law.
34. This order shall come into force with immediate effect. The Stock exchanges and the
depositories are directed to ensure that all the above directions are strictly enforced.
35. The persons/entities against whom this Order is passed may file their objections, if any, within
twenty one days from the date of this order and, if they so desire, avail themselves of an
opportunity of personal hearing before the Securities and Exchange Board of India, on a date
and time to be fixed on a specific request, received from the said persons/entities.
DATE:DECEMBER 19, 2014

PLACE: MUMBAI
Sd/RAJEEV KUMAR AGARWAL

WHOLE TIME MEMBER

Page 19 of 27
Annexure A: List of Preferential Allottees as received from BSE

Sr.
No.
Name of the Allottee
Permanent
Account
Number (PAN)
No. of
shares
allotted
Qty Post Stock

Split (Jan 29,
2013)
ABAPB8617M/
AachalchandBalar/PiyushKumarBal
AEMPB6394Q/
ar/AbhishekKumarBalar
AATPB8811B
150000
750000
AfsarZaidi
AADPZ8571G
100000
500000
AmreshA.Mody/HasumatiA.Mody
AACPM4024E/
AJSPM7935P
100000
500000
4
5
AnilRajatAgarwal&Sons.Huf.
AshokBJiwrajka
AAFHA0709M
AACPJ3610K
60000
250000
300000
1250000
6
7
BabitaMittal
BimalJDesasi
AAIPG4573G
AAKPD3160A
150000
200000
750000
1000000
8
9
10
BrijBhushanSingal
DalsukhUjamshiTrevadia
DilipBJiwrajka
AEFPS6298M
ACDPT3428N
AAGPJ8756J
580000
100000
250000
2900000
500000
1250000
11
12
DilipChotalalMorzaria
GloryInvestmentServicesPvtLtd
AADPM9919M
AACCG9982A
200000
340000
1000000
1700000
13
14
15
GMPrasannaKumar
GSAnithKumar
HariKishanSuderlalVermani
AHEPG0025A
ADPPK9874N
AAJPV4754H
200000
200000
100000
1000000
1000000
500000
16
17
HiteshMangilalJain
HukamsinghB.Rajpurohit
AABPJ2835R
AABPR9949J
100000
100000
500000
500000
18
19
JyotiAnilTrevadia
JyotsnaJitendraDesai
ABWPT8000C
AHPPD4223L
100000
200000
500000
1000000
20
21
22
KalpitaLuniya
KamalPunwani
LingarajuGM
AAAPL9611J
AFFPP5207G
AEYPM5850Q
100000
100000
200000
500000
500000
1000000
23
24
MayuriDarshanBhanushali
MohanMittal
AKJPB8572F
APFPM0496Q
100000
150000
500000
750000
25
26
27
MohitAggarwal
MukeshMittal
NareshNemchandShah
ADSPA9301K
AJGPM2125D
ACRPS0182J
150000
150000
400000
750000
750000
2000000
28
NeerajSingal
ANRPS7986B
580000
2900000

Page 20 of 27
29
NishitAgarwalBenTrust
AABTN3350K
200000
1000000
30
31
32
PinkyAgarwal
PratikAgarwalBenTrust
PraveenKumarAgarwal
ACGPA7438L
AABTP7516K
ACSPA4725A
200000
200000
200000
1000000
1000000
1000000
33
34
PraveenKumarAgarwalHuf
RajendraMangilalJain
AAIHP6229C
ACPPJ9853R
200000
100000
1000000
500000
35
36
RamchandraSatre
RenuAggarwal
ACAPS9829D
AAEPA1694C
100000
150000
500000
750000
37
RenuMittal
AGMPM1488Q
150000
750000
38
39
RituSingal
SantoshAggarwal
ABHPS3711M
ABAPA4548E
515000
150000
2575000
750000
40
41
ShaileshMangilalJain
ShilpaAggarwal
AAAPJ6765F
AEXPA1230M
100000
150000
500000
750000
42
43
44
SmtUjwalaNamdevMane
SurendraBJiwrajka
SushantInvestments
AAEPM5924H
AACPJ4316L
ACAFS8650G
100000
250000
250000
500000
1250000
1250000
45
46
TanviBhavikTrevadia
TarunAggarwal
AFAPT5888A
AOQPA9034E
100000
150000
500000
750000
47
48
UmaSingal
YogeshPopatlalThakkar
ANRPS7987A
AAPPT1825P
225000
200000
1125000
1000000
9100000
45500000
Total

Page 21 of 27
Annexure B: Radford Group & Suspected Entities and the basis of connection /relationship
amongst them.
Based on the KYC and Bank Statement analysis, off market analysis, data available with the
exchange and MCA details, Radford Group & Suspected Entities were observed to be dealing in
the scrip during the period of examination. Their basis of connection and transaction details is given
below:
Sr
No
Client Name and

PAN
Member Name
and Code
Basis of Connection
Radford Group
5
6
On analyzing the bank statement submitted by the

trading member Gepl Capital Pvt. Ltd for its
client Dhanleela Investments & Trading Company
Limited, it was observed that the client has
received / transferred funds from / to the
company Radford Global Limited. It was also
observed that it has transferred funds to Neeraj
(AAACR1770P)
Singal, Brij Bhushan Singal and Ritu Singal
Pyramid Trading
trading member C.D Equisearch Pvt Ltd for its
And Finance Ltd
C.D.Equisearch
client Pyramid Trading and Finance Limited, it
Pvt.Ltd. (87)
was observed that the client has received /
(AAACP2548R)
transferred funds from / to the company Radford
Global Limited
trading member C.D Equisearch Pvt Ltd for its
Pine
Animation
client Pyramid Trading and Finance Limited, it
Limited
Mehta
Equities was observed that the client has transferred funds
Ltd. (122)
to the Pine Animation Limited. From the analysis
of bank statement of Pine Animation Limited, it
(AAECM0267A)
was observed that funds were transferred to one
Entity Blue Circle Services Ltd.
Amrit
Sales
From the analysis of bank statement of Amrit Sales
Promotion
Pvt Arch Finance Ltd.
Promotion Pvt. Ltd., it was observed that funds
Limited
(3257)
were received from Blue Circle Services Ltd.
(AACCA3220D)
Burlington Finance
Arch Finance Ltd.
Limited
As per bank statement of the client 'Amrit Sales
(3257)
(AABCB2575P)
Promotion Pvt Limited', it has received /
transferred funds from / to 'Burlington Finance
Symphony
Arch Finance Ltd.
Limited' and 'Symphony Merchant Pvt Ltd'.
Merchant Pvt Ltd
(3257)
(AADCS5411K)
Dhanleela
Investments
&
Trading Company
GEPL Capital Pvt.
Limited
Ltd. (724)

Page 22 of 27
10
11
12
13
14
15
The client 'Bazigar Trading Private Limited' and the

Bazigar
Trading
client 'Amrit Sales Promotion Pvt Limited' have
Arch Finance Ltd.
Private Limited
common phone number and email-id viz,
(3257)
'9831714151'
and
'apareek1@hotmail.com,
(AABCB3052B)
naloo.kol@gmail.com' respectively.
Manimudra
As per UCC database updated by the trading
Vincom
Private
member Arch Finance Ltd for its clients entity viz.
Limited
Arch Finance Ltd. Bazigar Trading Private Limited (S.No 41) and
(3257)
Manimudra Vincom Private Limited have same
address viz, 19 R.N. Mukherjee Lane, 2nd Floor,
(AADCM4316K)
Kolkata, West Bengal-700001
Blue
Circle
Mehta
Equities
Services Limited
Ltd. (122)
(AAACB2131L)
Devatma
The clients 'Blue Circle Services Limited', 'Devatma
The
Calcutta
Distributors
Distributors Private Limited' and 'Anjali Suppliers
Stock Exchange
Private Limited
Private Limited' has common email id viz,
Ltd. (990)
dhruvonarayan.jha@rediffmail.com'
(AADCD7140G)
Anjali
Suppliers Madhya Pradesh
Private Limited
Stock Exchange
Ltd. (991)
(AAJCA1784D)
Rangan Vincom The
Calcutta Rangan Vincom Private Limited' has transferred
Private Limited
Stock Exchange shares to 'Devatma Distributors Private Limited' in
Ltd. (990)
the off market.
(AAGCR1715E)
Katyani
As per the MCA website, Rangan Vincom Private
The
Calcutta
Commodities
Limited and Katyani Commodities Private
Stock Exchange
Private Limited
Limited have common address viz, 4, N.S Road,
Ltd. (990)
1st Floor, Kolkata, West Bengal-700001.
(AAECK6244R)
Ladios
Trading The
Calcutta
Private Limited
Stock Exchange Rangan Vincom Private Limited', 'Ladios Trading
Ltd. (990)
(AACCL3868N)
Private Limited', 'Avlokan Dealcom Private
Avlokan Dealcom The
Calcutta Limited' has common phone number viz,
Private Limited
Stock Exchange '9831432937'.
Ltd. (990)
(AALCA1583G)

Page 23 of 27
Kingfisher
Properties Private
Limited
Gateway Financial
Services
Ltd.
(3199)
16
(AAECK3394G)
Topwell Properties
Private Limited
21
Gateway Financial
Services
Ltd.
(3199)
(AADCT8403C)
17
18
19
Esquire Enclave
Private Limited
(AACCE7065J)
Radison Properties
Private Limited
(AAFCR2818B)
Shivkhori
Construction
Private Limited
Gateway Financial
Services
Ltd.
(3199)
Gateway Financial
Services
Ltd.
(3199)
Gateway Financial
Services
Ltd.
(3199)
On analyzing the bank statement of the client it was

observed that the client has received / transferred
funds from / to 'Esquire Enclave Private Limited,
Fairlink Housing Pvt Ltd. Further, from the bank
statement analysis, the client 'Kingfisher Properties
Pvt. Ltd.' has also transferred the funds to 'Signet
Vinimay Pvt Ltd' . On analyzing the bank statement
of the Fairlink Housing Pvt. Ltd., it was observed
that the client had received / transferred funds
from / to group entities viz, 'Kingfisher Properties
Private Limited', 'Divyadrishti Merchants Private
Limited', 'Divyadrishti Traders Pvt Ltd'. Further,
the client has also received / transferred funds to
its other connected / related entities viz, Topwell
Properties Pvt Ltd. On analyzing the bank
statement received from the trading member Korp
Securities Ltd for its client Fairlink Housing
Private Limited, it was observed that the said entity
has received funds from an entity viz, Venkatesh
Sales Pvt Ltd which as per the MCA website has
the common address as that of one of the director
viz, Dhruv Narayan Jha of the company Blue
Circle Services Limited viz, P-27, Princep Street,
3rd Floor, Kolkata, West Bengal 700072.
Further, as per MCA website the email address of
Venkatesh Sales Pvt Ltd and Blue Circle Services
Ltd
is
common
viz,
dhruvonarayan.jha@rediffmail.com.
On analyzing bank statement of the Topwell
Properties Private Limited, it was observed that
funds were received/transferred among Esquire
Enclave Private Limited, Radison Properties
Private Limited, Kingfisher Properties Private
Limited, Shivkhori Construction Pvt. Ltd. Natural
Housing Private Limited And Limestone Properties
Private Limited. Funds were also transferred to
Signet Vinimay Pvt. Ltd.and Sankalp Vincom Pvt.
Ltd.
The clients 'Kingfisher Properties Private Limited',
Esquire Enclave Private Limited, 'Radison
Properties Private Limited', 'Shivkhori Construction
Private Limited', 'Limestone Properties Private
Limited', 'Topwell Properties Private Limited' and
'Natural Housing Private Limited' has common
address, email id and common directors viz, 95A
C.R Avenue, 1st Floor, Kolkata, West Bengal
700073, roc2011@in.com and Vishal Sharma

Page 24 of 27
20
22
23
24
25
26
27
28
29
30
31
32
(AAPCS7850L)
Limestone
Properties Private
Limited
(AACCL0133G)
Natural Housing
Private Limited
(AADCN6251G)
and Chiranjit Mahanta.

Gateway Financial
Services
Ltd.
(3199)
Gateway Financial
Services
Ltd.
(3199)
Millennium Stock
Divyadrishti
Broking
Private
Merchants Pvt Ltd
Limited (6151)
Korp
Securities
(AABCD8147K)
Ltd. (6213)
Millennium Stock
Divya
Drishti
Broking
Private
Traders Pvt Ltd
Limited (6151)
Korp
Securities
(AABCD8146J)
Ltd. (6213)
Dhanraksha
Korp
Securities
Vincom Pvt Ltd.
Ltd. (6213)
(AADCD6028P)
Ridhi Vincom Pvt
Korp
Securities
Ltd
Ltd. (6213)
(AAECR9858C)
Runicha
The
Calcutta
Merchants Private
Stock Exchange
Limited
Ltd. (990)
(AAECR0580M)
Signet
Vinimay The
Calcutta
Private Limited
Stock Exchange
Ltd. (990)
(AAMCS1712Q)
Winall
Vinimay The
Calcutta
Private Limited
Stock Exchange
Ltd. (990)
(AAACW8004B)
Sanklap Vincom P The
Calcutta
Ltd
Stock Exchange
Ltd. (990)
(AAMCS1711P)
Spice Merchants The
Calcutta
Private Limited
Stock Exchange
Ltd. (990)
(AAPCS7492G)
Apex Commotrade
The
Calcutta
Private Limited
Stock Exchange
Ltd. (990)
(AAJCA4459K)
As per the KYC submitted by the trading member

'Korp Securities Ltd.' for its clients 'Divyadrishti
Merchants Pvt Ltd', 'Divya Drishti Traders Pvt
Ltd', 'Dhanraksha Vincom Pvt Ltd.' and 'Ridhi
Vincom Pvt Ltd', all the clients have common
address viz, '163 B, M.G Road, 3rd Floor, Kolkata
West Bengal 700007'.

'The Calcutta Stock Exchange Ltd' for its clients
'Runicha Merchants Private Limited', 'Signet
Vinimay Private Limited', 'Winall Vinimay Private
Limited' and 'Sanklap Vincom P Ltd' and as per the
MCA Website, all the clients have common address
viz, '23/1, Principal Khudiram Bose Road, Kolkata,
West Bengal 700006 and common directors viz,
Abhiset Basu and Pradip Dey.
'The Calcutta Stock Exchange Ltd' for its clients
'Runicha Merchants Private Limited', 'Signet
Vinimay Private Limited', 'Winall Vinimay Private
Limited', 'Spice Merchants Private Limited' and
'Apex Commotrade Private Limited Ltd', all clients
have common email id viz, limited_kol@yahoo.in
and common phone number viz, 9836488845

Page 25 of 27
33
Devakantha
Trading
Private
Vishesh
Capital
Limited #
Pvt.Ltd. (3272)
(AADCD7044B)
As per the bank statement submitted by the trading

member 'Vishesh Capital Pvt.Ltd.' for its client
'Devakantha Trading Pvt Ltd', it was observed that
the client has received / transferred fund from / to
'Spice Merchants Pvt Ltd'.
34
Anand Rathi Share

Shelter
Sales
& Stock Brokers
Agency Pvt Ltd #
Ltd. (949)
Progressive Share
(AASCS1797F)
Brokers Pvt.Ltd.
(967)
Comfort Securities
Ltd. (3186)

'Vishesh Capital Pvt.Ltd.' for its client 'Devakantha
Trading Pvt Ltd' and 'Anand Rathi Share & Stock
Brokers Ltd.' and 'Comfort Securities Ltd' for its
client 'Shelter Sales Agency Pvt Ltd', both the
clients have common phone number viz,
'8108780561'.

'Vishesh Capital Pvt.Ltd.' for its client 'Devakantha
Trading Pvt Ltd' and 'Sunteck Wealthmax Capital
Private Limited' and 'Vishesh Capital Pvt.Ltd.' for
its client 'Udbal Mercantile Private Limited', Rekha
Arvind Gaud and Kalavatidevi Pratap Narayan
Gaud who are directors of Devakantha Trading
Vishesh
Capital Private Limited and Udbal Mercantile Private
Limited respectively has common address viz,
Pvt.Ltd. (3272)
Safalya 806 A, Mahavir Nagar, Kandivali West,
Mumbai 400067.
Anand Rathi Share
& Stock Brokers
'Vishesh Capital Pvt.Ltd.' for its client 'Udbal
Ltd. (949)
Mercantile Private Limited' (S.No 16) and 'Anand
Progressive Share
Rathi Share & Stock Brokers Ltd.' and 'Comfort
Brokers Pvt.Ltd.
Securities Ltd' for its client 'Amrusha Mercantile
(967)
Private Ltd', both the clients has common phone
Comfort Securities
number viz, 8108780562.
Ltd. (3186)
Gateway Financial The company 'Winall Vinimay Private Limited
Services
Ltd. (S.No 9) and 'SKM Travels Private Limited' have
(3199)
common director viz, 'Abhiset Basu.
As per the bank statement submitted by the trading
Gateway Financial member The Calcutta Stock Exchange Ltd' for its
Services
Ltd. client 'Winall Vinimay Pvt Ltd', it was observed that
(3199)
the client has received / transferred fund from / to
Scope Vyappar Pvt Ltd'
The client Vibgyor Financial Service Pvt Ltd has
India Infoline Ltd
received shares in off market from Scope Vyapar
Private Limited.
Sunteck
Udbal Mercantile Wealthmax Capital
Private Limited #
Private
Limited
(3070)
35
(AABCU2648C)
Amrusha
Mercantile Private
Ltd #
36
37
38
(AALCA0340D)
SKM
Travels
Private Limited
(AAICS0688K)
Scope
Vyapar
Private Limited
(AAICS6023N)
39
Vibgyor Financial
Service Pvt Ltd
(AAACV8378B)
Suspected Entities
1
Trimurthi Finvest Exclusive

Limited
Securities

Ltd. 'Exclusive Securities Ltd.' for its clients 'Trimurthi

Page 26 of 27
(6369)
Finvest Limited' and 'Purvi Finvest Limited', both

the company have common address viz, '9, Bhoj
ATS
Share Nagar, Annpurna Road, Indore - 452009'
(AAACT6383N)
Brokers Pvt. Ltd.
(6481)
India
Infoline
Limited (179)
ATS
Share
Purvi
Finvest
Brokers Pvt. Ltd.
Limited
(6481)
Exclusive
(AABCP6564C)
Securities
Ltd.
(6369)
As per the MCA website and also as per the KYC
East West Finvest
submitted by the trading member 'Exclusive
Exclusive
India Limited
Securities Ltd.' for its clients 'Trimurthi Finvest
Securities
Ltd.
Limited' (S.No 1) and 'East West Finvest India
(6369)
(AAACE6834D/
Limited', both the companies have common
AADCE1236G)
director viz, 'Sharad Kumar Darak'.
Exclusive
Jayant Security &
Securities
Ltd. As per the MCA website 'Trimurthi Finvest
Finance Ltd
(6369)
Limited' (S.No 1) and 'Jayant Security & Finance
ATS
Share Ltd', both the companies have common email id
(AAACJ4848G)
Brokers Pvt. Ltd. viz, 'caashwinsethi@gmail.com'
(6481)
DATE:DECEMBER 19, 2014

PLACE: MUMBAI
Sd/RAJEEV KUMAR AGARWAL

WHOLE TIME MEMBER

Page 27 of 27

Interim Order in The Matter of Radford Global Ltd.

Uploaded by

Document Information

Original Description:

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

Interim Order in The Matter of Radford Global Ltd.

Uploaded by

Copyright:

Available Formats

WTM/RKA /ISD /161 /2014

SECURITIES AND EXCHANGE BOARD OF INDIA

----------------------------------------------------------------------------------------------------------------------------------------------------Order in the matter of Radford Global Ltd.

Total Number of paid

Earning per share

Prem Lata Nahar

Bharat Bagri Bagri

Shilpa Stock Broker

----------------------------------------------------------------------------------------------------------------------------------------------------Order in the matter of Radford Global Ltd.

Table - IV: Details of counter parties for sale transactions

----------------------------------------------------------------------------------------------------------------------------------------------------Order in the matter of Radford Global Ltd.

----------------------------------------------------------------------------------------------------------------------------------------------------Order in the matter of Radford Global Ltd.

Grand Total (I+II)

----------------------------------------------------------------------------------------------------------------------------------------------------Order in the matter of Radford Global Ltd.

----------------------------------------------------------------------------------------------------------------------------------------------------Order in the matter of Radford Global Ltd.

----------------------------------------------------------------------------------------------------------------------------------------------------Order in the matter of Radford Global Ltd.

----------------------------------------------------------------------------------------------------------------------------------------------------Order in the matter of Radford Global Ltd.

PFUTP REGULATIONS, 2003

4. Prohibition of manipulative, fraudulent and unfair trade practices

----------------------------------------------------------------------------------------------------------------------------------------------------Order in the matter of Radford Global Ltd.

Radford Global Ltd.

Directors of Radford Global Ltd.

Prakash Bhawarlal Biyani

Promoters of Radford Global Ltd.

Director of Radford Investment Services Pvt. Ltd.

----------------------------------------------------------------------------------------------------------------------------------------------------Order in the matter of Radford Global Ltd.

----------------------------------------------------------------------------------------------------------------------------------------------------Order in the matter of Radford Global Ltd.

Amrit Sales Promotion Pvt Limited

----------------------------------------------------------------------------------------------------------------------------------------------------Order in the matter of Radford Global Ltd.

Vibgyor Financial Service Pvt Ltd

Jayant Security & Financeltd

Taran Kumar Rungta

DATE:DECEMBER 19, 2014

Sd/RAJEEV KUMAR AGARWAL

----------------------------------------------------------------------------------------------------------------------------------------------------Order in the matter of Radford Global Ltd.

Annexure A: List of Preferential Allottees as received from BSE

Name of the Allottee

Qty Post Stock

----------------------------------------------------------------------------------------------------------------------------------------------------Order in the matter of Radford Global Ltd.

----------------------------------------------------------------------------------------------------------------------------------------------------Order in the matter of Radford Global Ltd.

Client Name and

On analyzing the bank statement submitted by the

----------------------------------------------------------------------------------------------------------------------------------------------------Order in the matter of Radford Global Ltd.

The client 'Bazigar Trading Private Limited' and the

----------------------------------------------------------------------------------------------------------------------------------------------------Order in the matter of Radford Global Ltd.

On analyzing the bank statement of the client it was

----------------------------------------------------------------------------------------------------------------------------------------------------Order in the matter of Radford Global Ltd.

and Chiranjit Mahanta.

As per the KYC submitted by the trading member

As per the KYC submitted by the trading member

----------------------------------------------------------------------------------------------------------------------------------------------------Order in the matter of Radford Global Ltd.

As per the bank statement submitted by the trading

Anand Rathi Share

As per the KYC submitted by the trading member

As per the KYC submitted by the trading member

Trimurthi Finvest Exclusive

As per the KYC submitted by the trading member

----------------------------------------------------------------------------------------------------------------------------------------------------Order in the matter of Radford Global Ltd.

Finvest Limited' and 'Purvi Finvest Limited', both

DATE:DECEMBER 19, 2014

Sd/RAJEEV KUMAR AGARWAL

----------------------------------------------------------------------------------------------------------------------------------------------------Order in the matter of Radford Global Ltd.