Securities and Exchange Board of India vs Rakhi Trading Private Ltd.

(c) and 4(1), (2)(a), (b) – Synchronized trading – Synchronization and reversal of trades, some in few seconds and majority, in any case on the same day, without any significant change in the value of underlying – As a result one party booking gains and the other party booking a loss – In the show cause notice, allegation was that the parties-traders were buying and selling securities in the derivatives segment in synchronized and reverse transactions at a price which did not reflect the value of the underlying – Assessing Officer held that there was intention of creating false or misleading appearance in the market and also that a manipulative/deceptive device was used for synchronization of trades and trades were fictitious in nature, amounting to violation of Regns 3(a), (b), (c) and 4(1), (2)(a), (b) of the PFUTP Regulations – Securities Appellate Tribunal (SAT) set aside the order of Assessing Officer holding that in the Futures and Options (F & O) segment, there is no concept of “change of beneficial ownership” since what is traded in this segment are contracts and not the underlying stock or index and it is only through cash settlement that the trade is concluded and no physical delivery of any asset is involved and in this view of the matter, synchronized and reversed trades in Nifty options in F & O segment can never manipulate the market which in the present context means the value of Nifty index in cash segment – It further held that since the trades were settled in cash through stock exchange mechanism, they are genuine and did not create a false and misleading appearance of trading in F & O segment – Appeal by SEBI – Held: Trading is always with aim to make profits – But if one party consistently makes loss and that too in preplanned and rapid reverse trades, it is not genuine and would amount to an unfair trade practice – In the instant case, through reverse trades, there was no genuine change of rights in the contract – SAT erred in its understanding of change in beneficial ownership in reverse trades – Even in derivatives, the ownership of the right is restored to the first party when the reverse trade occurs – The traders in question did not intend to transfer beneficial ownership – Rather than allowing the market forces to operate in their natural course, the traders repeatedly carried out the impugned transactions which deprived other market players from full participation – The repeated reversals and predetermined arrangement to book profits and losses respectively, made it clear that the parties were not trading in the normal sense and ordinary course – Resultantly, there has clearly been a restriction on the free and fair operation of market forces in the instant case – The stock market is not a platform for any fraudulent or unfair trade practice – The field is open to all the investors – By synchronization and rapid reverse trade, as was carried out by the traders in the instant case, the price discovery system itself was affected – The traders, thus, having engaged in a fraudulent and unfair trade practice while dealing in securities, are liable to be proceeded against for violation of Regns 3(a), 4(1) and 4(2)(a) of PFUTP Regulations. (Kurian Joseph, J.) SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003: Regns. 3(a), (b),

(c) and 4(1), (2)(a), (b) – Fictitious transactions creating illegal synchronization – Modus operandi – The question whether there was fictitious transactions creating illegal synchronization has to be gathered from the facts and circumstances and intention of the parties – Acting in concert is something about which it is difficult to obtain direct evidence – Proof of manipulation might depend upon inferences drawn from factual details – Such inferences could be gathered from pattern of trading data and the nature of the transactions etc. – ‘By manipulation and synchronization’, it is meant that two parties have pre-meditated; as such a drastic movement in price within few seconds could have been only through prior understanding between the parties concerned only to fulfill an unlawful objective through misuse of the stock exchange – That is, prior arrangement/prior understanding with each other wherein one will make profit and other will lose and thereby as soon as one party opens up its trade in the market, the other party will buy it – Though the trading is shown on the screen, but prior arrangement is very well possible behind the screen – This was done in the case in hand – Buy and sell orders were placed at a difference of few seconds/minutes, while ‘sell’ by respondent was at a high price and “buy” by the respondent was at a low price – The transactions wherein the ‘buy and sell’ orders entered almost simultaneously and the transactions matched in time and quantity with significant price variation and respondent consistently making profit but the other party consistently making loss – There was no possibility of such perfect matching of quantity, timing, prices etc. between the same parties unless there was prior meeting of minds or a specific understanding/arrangement between the parties – Applying the test laid down in Kishore R. Ajmera case to the instant case, by cumulative analysis of the reversal transactions, quantity, time and significant variation of prices, without major variation in the underlying price of the securities indicate that the respondent’s trades are not genuine and had only misleading appearance of trading in the securities market, without intending to transfer beneficial ownership. (Banumathi, J.)

Securities and Exchange Board of India (Stock Brokers and Sub-brokers) Regulations, 1992: Regns. 7A, (2), (3), (4) – Synchronization and reversal of trades by brokers on behalf of their clients, some in few seconds and majority, in any case on the same day, without any significant change in the value of underlying – As a result one party booking gains and the other party booking a loss – SAT held that merely because appellant acted as a broker would not mean that it knew about the nature of transaction and that there was no evidence of lack of due diligence while executing the impugned transactions which could make the brokers guilty of violating the code of conduct prescribed for the stock brokers – Held: There was no evidence of involvement of brokers so as to proceed against them for violation of Regn 7A of the Brokers Regulations and PFUTP Regulations – Merely because a broker facilitated a transaction, it cannot be said that there is violation of the Regulation – SEBI did not provide any material to suggest negligence or connivance on the part of the brokers – In the absence of any material provided by SEBI to prove the charges against the brokers, particularly regarding aiding and abetting fraudulent or unfair trade practices, the orders of SEBI against the brokers should be interfered with – Securities Contracts (Regulation) Act, 1956 – s.18A, 3(ac), 2(d). (Kurian Joseph, J.)

Securities and Exchange Board of India (Stock Brokers and Sub-brokers) Regulations, 1992: Regns. 7A, (2), (3), (4) – Fictitious transactions creating illegal synchronization – Allegation of SEBI was that the traders and brokers at NSE were buying and selling almost equal quantities of contracts within the day and that such buy/sell orders were synchronized – Held: Considering the reversal transactions, quantity, price and time and sale, parties being persistent in number of such trade transactions with huge price variations, it will be too naive to hold that the transactions are through screen-based trading and hence anonymous – Such conclusion would be over-looking the prior meeting of minds involving synchronization of buy and sell order and not negotiated deals as per the board’s circular – The impugned transactions are manipulative/deceptive device to create a desired loss and/or profit – Such synchronized trading is violative of transparent norms of trading in securities – If the findings of SAT are to be sustained, it would have serious repercussions undermining the integrity of the market and the impugned order of SAT is liable to be set aside – On this additional reasonings also, conclusion allowing the appeal preferred by SEBI against the traders is upheld – The conclusion dismissing the appeal preferred by the SEBI against the brokers is also upheld – SEBI Act, 1992 – ss.12A, 15HA. (Banumathi, J.) Stock Exchange: Need for comprehensive legal framework governing the securities market – As the market grows, ingenuous means of manipulation are also employed – In such a scenario, it is essential that SEBI keeps up with changing times and develops principles for good governance in the stock market which ensure free and fair trading – The observations made in Kishore R. Ajmera and Kanaiyalal Patel regarding need for more comprehensive legal framework governing the securities market, reiterated – SEBI Act, 1992. (Kurian Joseph, J.)

Stock Exchange: Circumstances under which synchronized trade become illegal – Held: A synchronized transaction will become illegal or violative of the Regulations if it is executed with a view to manipulate the market or if it results in circular trading or is dubious in nature and with a view to manipulate the price or volume of the scrip or with some ulterior purpose. (Banumathi, J.)

Stock Exchange: Manipulation of market – If the factum of manipulation is established, it will necessarily follow that the investors in the market have been induced to buy or sell and that no further proof in this regard is required – The market is so widespread that it may not be humanly possible for the Board to track the persons who were actually induced to buy or sell securities as a result of manipulation and the Board cannot be imposed with a burden which is impossible to be discharged. (Banumathi, J.) Stock Exchange: Prevention of market abuse – The smooth operation of the securities market and its healthy growth and development depends upon large extent on the quality and integrity of the market – Unfair trade practices affect the integrity and efficiency of the securities market and the confidence of the investors – Prevention of market abuse and preservation of market integrity are the hallmark of securities law. (Banumathi, J.) Stock Exchange: Role of SEBI – Object of SEBI Act – Held: The object of the SEBI Act is to protect the interest of the investors in securities and to promote the development and to regulate the securities market so as to promote orderly, healthy growth of securities market and to promote investor’s protection – In order to protect the interests of the investors and the integrity of the markets, as a regulator, SEBI has to make the market place efficient and clean, wherein all the participants play their role diligently and professionally within the four corners of the system, without there being any scope for market abuse – Where certain unscrupulous elements are trying to manipulate the market to serve their own interest, it becomes imperative on the part of SEBI to intervene and to curb further mischief and to take necessary action to maintain public confidence in the integrity of the securities market. (Banumathi, J.)

Evidence: In the quasi-judicial proceeding before SEBI, the standard of proof is preponderance of probability – Stock Exchange. (Banumathi, J.)

Words and phrases: Synchronize, Synchronized Trading – Meaning of, discussed.(Banumathi, J.)

Disposing of the appeals, the Court

HELD:

Per Kurian Joseph, J.

HELD: 1. Regulation 4(1) in clear and unmistakable terms provided that “no person shall indulge in a fraudulent or an unfair trade practices in securities” Having regard to the fact that the dealings in the stock exchange are governed by the principles of fair play and transparency, one does not have to labour much on the meaning of unfair trade practices in securities. Contextually and in simple words, it means a practice which does not conform to the fair and transparent principles of trades in the stock market. In the instant case, one party booked gains and the other party booked a loss. Nobody intentionally trades for loss. An intentional trading for loss per se, is not a genuine dealing in securities. The platform of the stock exchange has been used for a non-genuine trade. Trading is always with the aim to make profits. But if one party consistently makes loss and that too in preplanned and rapid reverse trades, it is not genuine; it is an unfair trade practice. Securities market, as the Securities Contracts (Regulation) Act, 1956 provides in the preamble, does not permit “undesirable transactions in securities”. The Act intends to prevent undesirable transactions in securities by regulating the business of dealing therein. Undesirable transactions would certainly include unfair practices in trade. The SEBI Act, 1992 was enacted to protect the interest of the investors in securities. Protection of interest of investors should necessarily include prevention of misuse of the market. Orchestrated trades are a misuse of the market mechanism. It is playing the market and it affects the market integrity. [Paras 34, 35] [976-D-E; 977-D-G] Ketan Parekh v. Securities and Exchange Board of India Appeal No.2 of 2004 before SAT – referred to .

2. Ordinarily, the trading would have taken place between anonymous parties and the price would have been determined by the market forces of demand and supply. In the instant case, the parties did not stop at synchronised trading. The facts go beyond that. The trade reversals in this case indicate that the parties did not intend to transfer beneficial ownership and through these orchestrated transactions, the intention of which was not regular trading, other investors have been excluded from participating in these trades. The fact that when the trade was not synchronizing, the traders placed it at unattractive prices is also a strong indication that the traders intended to play with the market. [Para 36] [977-H; 978-A-B]

3. The stand of SAT that the rationale of change of beneficial ownership does not arise in the derivatives segment is also not correct. No doubt, as in the case of trade in a scrip in the cash segment, there is no physical delivery of the asset. However, even in the derivative segment there is a change of rights in a contract. In the instant case, through reverse trades, there was no genuine change of rights in the contract. SAT has erred in its understanding of change in beneficial ownership in reverse trades. Even in derivatives, the ownership of the right is restored to the first party when the reverse trade occurs. In the instant case, it is clear that the traders in question did not intend to transfer beneficial ownership and therefore these trades are non genuine. Rather than allowing the market forces to operate in their natural course, the traders repeatedly carried out the impugned transactions which deprived other market players from full participation. The repeated reversals and predetermined arrangement to book profits and losses respectively, made it clear that the parties were not trading in the normal sense and ordinary course. Resultantly, there has clearly been a restriction on the free and fair operation of market forces in the instant case. [Paras 37, 38] [978-B-C; 979-A-C]

4. Regulation 2(1)(c) defines fraud. Under Regulation 2(1)(c)(2) a suggestion as to a fact which is not true while he does not believe it to be true is fraud. Under Regulation 2(1)(c)(7), a deceptive behaviour of one depriving another of informed consent or full participation is fraud. And under Regulation 2(1)(c)(8), a false statement without any reasonable ground for believing it to be true is also fraud. In a synchronised and reverse dealing in securities, with predetermined arrangement to book loss or gain between pre-arranged parties, all these vices are attracted. Regulation 3(a) expressly prohibits buying, selling or otherwise dealing in securities in a fraudulent manner. Under Regulation 4(2) dealing in securities shall be deemed to be fraudulent if the trader indulges in an act which creates a false or misleading appearance of trading in the securities market. It is a deeming provision. Such trading also involves an act amounting to manipulation of the price of the security in the sense that the price has been artificially and apparently prefixed. The price does not at all reflect the value of the underlying asset. It is also a transaction in securities entered into without any intention of performing it and without any intention of effecting a change of ownership of such securities, ownership being understood in the limited sense of the rights in the contract. [Paras 39, 40] [979-C-G]

5. According to SAT, only if there is market impact on account of sham transactions, could there be violation of the PFUTP Regulations. The proposition is not convincing. SAT missed the crucial factors affecting the market integrity, which may be direct or indirect. The stock market is not a platform for any fraudulent or unfair trade practice. The field is open to all the investors. By synchronization and rapid reverse trade, as has been carried out by the traders in the instant case, the price discovery system itself is affected. Except the parties who have pre-fixed the price nobody is in the position to participate in the trade. It also has an adverse impact on the fairness, integrity and transparency of the stock market. The traders thus having engaged in a fraudulent and unfair trade practice while dealing in securities, are hence liable to be proceeded against for violation of Regulations 3(a), 4(1) and 4(2)(a) of PFUTP Regulations. As far as brokers are concerned, there is hardly any evidence on their involvement so as to proceed against them for violation of Regulation 7A of the Brokers Regulations and PFUTP Regulations. Merely because a broker facilitated a transaction, it cannot be said that there is violation of the Regulation. SEBI has not provided any material to suggest negligence or connivance on the part of the brokers. In the absence of any material provided by SEBI to prove the charges against the brokers, particularly regarding aiding and abetting fraudulent or unfair trade practices, the orders of SEBI against the brokers should be interfered with. [Paras 41, 43, 44] [979-G-H; 980-A-B; 981-B; C, D-F]

6. There is need for more comprehensive legal framework governing the securities market. As the market grows, ingenuous means of manipulation are also employed. In such a scenario, it is essential that SEBI keeps up with changing times and develops principles for good governance in the stock market which ensure free and fair trading. [Para 45] [981-G]

Securities And Exchange Board of India v. Kishore R. Ajmera (2016) 6 SCC 368 : [2016] 1 SCR 1118 ;

Securities and Exchange Board of India and Ors. v. Shri Kanaiyalal Baldevbhai Patel and Ors. 2017 SCC Online SC 1148– relied on.

Per Banumathi, J. (Supplementing)

1. Synchronized Trading: As per the Oxford dictionary the word ‘synchronize’ means “cause to occur at the same time; be simultaneous”. A synchronized trade is one where the buyer and seller enter the quantity and price of the shares they wish to transact at substantially the same time. This could be done through the same broker (termed a cross deal) or through two different brokers. Synchronized trade is one wherein ‘buy and sell’ orders are placed simultaneously for the same quantity and price they wish to transact at substantially the same time. Synchronized trades are not illegal provided that they are executed on the screens of the exchange in the price and order matching mechanism of the exchanges just like any other normal trade. A synchronized transaction will become illegal or violative of the Regulations if it is executed with a view to manipulate the market or if it results in circular trading or is dubious in nature and with a view to manipulate the price or volume of the scrip or with some ulterior purpose. [Paras 13, 14, 16] [989-A-C; 990-D-E]

Ketan Parekh v. SEBI, Manu/SB/0229/2006 – referred to.

2. The question whether there was fictitious transactions creating illegal synchronization has to be gathered from the facts and circumstances and intention of the parties. Acting in concert is something about which it is difficult to obtain direct evidence. Proof of manipulation might depend upon inferences drawn from factual details. Such inferences could be gathered from pattern of trading data and the nature of the transactions etc. ‘By manipulation and synchronization’, it is meant that two parties have pre-meditated; as such a drastic movement in price within few seconds could have been only through prior understanding between the parties concerned only to fulfill an unlawful objective through misuse of the stock exchange. That is, prior arrangement/prior understanding with each other wherein one will make profit and other will lose and thereby as soon as one party opens up its trade in the market, the other party will buy it. Though the trading is shown on the screen, but prior arrangement is very well possible behind the screen. This is what has been done in the case in hand. Buy and sell orders were placed at a difference of few seconds/minutes, while ‘sell’ by respondent to Kasam Holding was at a high price and “buy” by the respondent from Kasam Holding Pvt. Ltd. was at a low price. The transactions wherein the ‘buy and sell’ orders entered almost simultaneously and the transactions matched in time and quantity with significant price variation and respondent consistently making profit but Kasam Holding Pvt. Ltd. consistently making loss. Number of reversal trades between the respondent and Kasam Holding Pvt. Ltd. and such reversal trade taking place repeatedly over a period of time only indicates that there was pre-arrangement between the parties before the trade was executed. The transactions involving only the same two parties within few seconds with huge difference in ‘buy and sell’ value, though there is no difference in the underlying security, can take place only with prior understanding between the two parties. The Board who is the regulator of the market, can always lift the veil of such transactions to show the non-genuineness of such transactions. [Paras 20, 21] [992-D-H; 993-A-B]

3. In the present case, every time one party is making profit and other party is facing loss. Further, there was proximity in the time of sell orders at a high price to the party-Kasam Holding Pvt. Ltd. and the same quantity being reversed by Kasam Holding Pvt. Ltd. to the same party-Rakhi Trading Pvt. Ltd. at a low price through the same set of brokers. During March, 2007 thirteen Nifty Option Contracts got matched between the same parties through the same brokers. There is no reason to understand as to why Kasam Holding has made the transactions repeatedly by incurring losses. It seems improbable that Kasam Holding which was facing loss in each transaction by trading with the respondent, was still eager to trade with the same repeatedly for about four days which is not in consonance with the market trend and human conduct; more so, when there has not been any major difference in the underlying price. It is thus difficult to accept that several such sell and buy orders between the respondent and Kasam Holding being within a gap of “1”, “2” or “3” or few seconds were by mere coincidence. It was too much of coincidence that there were number of transactions of ‘buy and sell orders’ between the same parties with same quantity of stock with significant variation in price. [Para 22] [993-C-F]

4. In the quasi-judicial proceeding before SEBI, the standard of proof is preponderance of probability. It was held in Kishore R. Ajmera case that it is the judicial duty to take note of the immediate and proximate facts and circumstances surrounding the events on which the charges/allegations are founded and to reach what would appear to the Court to be a reasonable conclusion therefrom. The test would always be that what inferential process that a reasonable/prudent man would adopt to arrive at a conclusion. There was no possibility of such perfect matching of quantity, timing, prices etc. between the same parties unless there was prior meeting of minds or a specific understanding/arrangement between the parties. Applying the test laid down in Kishore R. Ajmera case to the present case, by cumulative analysis of the reversal transactions between respondent and Kasam Holding, quantity, time and significant variation of prices, without major variation in the underlying price of the securities clearly indicate that the respondent’s trades are not genuine and had only misleading appearance of trading in the securities market, without intending to transfer beneficial ownership. [Paras 25, 26, 27] [996-D-H; 996-H; 998-F]

5. Contention of the appellant is that if the market starts moving or there is a change in the perception of the market and the anticipated future performance thereof, then the seller often gets very apprehensive and may even panic, anticipating a substantial loss and would want to square off his position to restrict a loss. There is no merit in this contention. Insofar as the impugned transactions are concerned, it is seen that the market of underlying shares had remained unmoved altogether, then there was no question of getting panic. When there were no other transactions in the market affecting the price of the underlying shares or F & O Segment and the price in both the segments had remained static, then there was no reasonable ground to get apprehensive and panic. Therefore, squaring off the position appears to adjust the financial results with a view to avoid the tax incidence through an unfair trade practice or for some ulterior purpose. [Para 28] [998-F-H]

6. The respondent has made the transactions repeatedly by incurring losses, particularly when there were no transactions made by any third party in the market. Abnormal difference between the prices at which the trades were executed without corresponding effect on the price of the underlying security, shows that the option in which the party traded was not in demand in the market. It is unusual that the trades were transacted with such huge profits when there was no change in the underlying prices. These trade transactions obviously only aimed at carrying out manipulative objective. Once the reversal transactions are shown to be non-genuine or shown to be fictitious creating a false or misleading appearance in the market for ulterior purpose and that the stock market was misused by such manipulative device, this is in clear violation of the provisions of PFUTP Regulations, 2003. Regulations 3(a), 4(1) and 4(2)(a) of PFUTP Regulations prohibit such manipulative trades, unfair trade practices. [Paras 32, 33] [999-F-H; 1000-A]

7. Regulation 3 deals with “Prohibition of certain dealings in securities”. Regulation 4 deals with “Prohibition of manipulative, fraudulent and unfair trade practices”. Regulation 4 starts as “Without prejudice to the provisions of Regulation 3....”. Regulation 4(2) is an inclusive provision. Regulation 4(2) stipulates that “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....”, instances pointed out thereon. Regulation 4(2)(a) deals with “...an act which creates false or misleading appearance of trading in the securities market”. An act to fall within Regulation 4(2)(a), it is not necessary that the transactions entered into by the party was with intention to manipulate the market and that the market was in fact manipulated. Market manipulation is a deliberate attempt to interfere with the free and fair operation of the market and create artificial, false or misleading appearances with respect to the price, market, product, security and currency. [Para 35] [1000-E-G]

8. Respondent-Rakhi Trading and Kasam Holding on facts are found to have been engaged in non-genuine transactions creating appearance of trading. If the factum of manipulation is established, it will necessarily follow that the investors in the market have been induced to buy or sell and that no further proof in this regard is required. The market is so widespread that it may not be humanly possible for the Board to track the persons who were actually induced to buy or sell securities as a result of manipulation and the Board cannot be imposed with a burden which is impossible to be discharged. [Para 36] [1000-H; 1001A]

9. Stock market is regulated mainly by SEBI and to some extent by the Departments of Economic Affairs and Company Affairs of Government of India. Market manipulation can occur in a variety of ways. Manipulations/unfair trade practices reduce the market efficacy. Section 11 of the SEBI Act, 1992 provides for the functions of the Board, as per which it shall be the duty of the Board to protect the interests of the investors in securities and to promote the development and to regulate the securities market by such measures as it thinks fit. Main function of SEBI in this regard is to make inquiry, investigation and to give directions, to promote the orderly and healthy growth of the securities market. With a view to curb unfair trade practices, market manipulation, price rigging and other frauds in securities market, SEBI is empowered to make inquiries and inspection. [Para 40] [1003-B-D]

10. Section 12A of the SEBI Act, 1992 read with Regulations 3 and 4 of the PFUTP Regulations, 2003 are essentially intended to preserve ‘market integrity’ and to prevent ‘market abuse’. The object of the SEBI Act is to protect the interest of the investors in securities and to promote the development and to regulate the securities market so as to promote orderly, healthy growth of securities market and to promote investor’s protection. The capital market regulator, SEBI has a significant role to play in safeguarding the interest of investors and to ensure strict compliance of all the relevant SEBI rules and regulations targeting at safeguarding the interest of small investors. As supervisory functionary/ regulating body, SEBI has the duty and obligation to protect ordinary genuine investors and SEBI is empowered to do so under the SEBI Act, 1992 so as to make security market a secure and safe place to carry on the business in securities. At the same time, under the guise of supervisory intervention, SEBI cannot affect the development of the market or market oriented creativity. Intense supervision might distort the path of securities market development; but SEBI cannot be a silent spectator to unfair trade practices/manipulative market for some ulterior purpose like tax evasion etc. To find the right balance between market forces and Regulatory body’s intervention, SEBI has to deal sternly with those who indulge in manipulative trading and deceptive devices to misuse the market and at the same time ensuring the development of the market. Considering the reversal transactions, quantity, price and time and sale, parties being persistent in number of such trade transactions with huge price variations, it will be too naïve to hold that the transactions are through screen-based trading and hence anonymous. Such conclusion would be over-looking the prior meeting of minds involving synchronization of buy and sell order and not negotiated deals as per the board’s circular. The impugned transactions are manipulative/deceptive device to create a desired loss and/or profit. Such synchronized trading is violative of transparent norms of trading in securities. If the findings of SAT are to be sustained, it would have serious repercussions undermining the integrity of the market and the impugned order of SAT is liable to be set aside. [Paras 41, 42, 43, 46] [1003-D-E; 1005-B-C, E-G; 1006-E-G]

Ketan Parekh v. SEBI (Appeal No. 2 of 2004) ; Ketan Parekh v. SEBI, Manu/SB/0229/2006 ; Securities and Exchange Board of India v. Kishore R. Ajmera (2016)

6 SCC 368 : [2016] 1 SCR 1118 ; Nirmal Bang

Exchange Board of India MANU/SB/0206/2003 ; SEBI v. Accord Capital Markets Ltd. MANU/SB/0136/2007 ; Narayanan v. Adjudicating Officer, Securities and Exchange Board of India (2013) 12 SCC 152 ; Viram Investment Pvt. Ltd. and Ors. v. Securities and Exchange Board of India MANU/SB/0046/2005 – referred to.