{ "metadata": { "analysis_of_arguments": "The regulator asserted that multiple entities and individuals devised a scheme to inflate share prices by disseminating promotional videos and carrying out prearranged trades to draw in unwary investors. According to SEBI, frequent communications, synchronized orders, and shared resources confirmed the existence of orchestrated market manipulation. The Noticees largely denied any illicit coordination, contending that their trades were routine or based on independent decisions, that they lacked complete access to evidence, or that they did not fully grasp the nature of the transactions. Some emphasized limited market knowledge, while others cited alleged procedural deficiencies. However, SEBI relied on seized documents, electronics, and trading analyses to argue that a deliberate plan was executed.", "bench": [], "case_number": [], "cases_referred": [ "Writ Petition (L) 14100 of 2025 (Before High Court of Bombay)", "SCA 11702 of 2023 (Before High Court of Gujarat)", "SCA 11463 of 2023 (Before High Court of Gujarat)", "Appeal by Noticees 60-62 before the Hon\u2019ble Securities Appellate Tribunal", "Adjudicating Officer, SEBI vs Bhavesh Pabari (2019) SCC Online SC 294" ], "chunkwise_data": { "chunk_1": { "analysis_of_arguments": "The regulatory authority contends that promoter-group members, along with other connected entities, executed a plan to artificially inflate the scrip\u2019s price through misleading media content and structured trading. The implicated parties appear to deny wrongdoing or contend insufficient evidence ties their activities to any purported market manipulation.", "cases_referred": [], "facts": "Sadhna Broadcast Limited (SBL), incorporated in 1994 and listed on BSE in January 2018, became the subject of complaints alleging share price manipulation and dissemination of misleading content via YouTube videos. SEBI conducted searches at several Noticees\u2019 premises, uncovering possible connections between net sellers in SBL\u2019s shares and creators of these videos. An interim order was passed, and subsequently, a show cause notice was issued to 64 entities based on a detailed investigation into alleged artificial inflation of share prices and offloading of shares at higher rates.", "final_status": "Not indicated in this excerpt", "formatted_summary": "In this segment of the final order, SEBI investigates allegations that multiple entities manipulated the share price of Sadhna Broadcast Limited by disseminating misleading YouTube videos and conducting structured trades. Following complaints, a search and seizure operation uncovered evidence connecting promoters and other individuals to the alleged scheme. A show cause notice was issued to the named respondents, accusing them of artificially inflating the price and volume of SBL\u2019s shares, then disposing of those shares at higher prices to unwary investors. The document sets out the factual background, the suspected manipulation tactics, and the procedural steps leading to the issuance of notices.", "held": "Not indicated in this excerpt", "latin_principles": {}, "legal_issues": "Whether certain individuals and entities engaged in a coordinated scheme to manipulate the price and trading volume of SBL\u2019s shares, including the role of misleading promotional videos in influencing public investors, constitutes the key legal dispute in this matter.", "statutes": { "Securities and Exchange Board of India Act, 1992": "FINAL ORDER Under Sections 11(1), 11(4) and 11B of the Securities and Exchange Board of India Act, 1992 in respect of the Noticees. Sadhna Broadcast Limited was incorporated in 1994 and listed on BSE in January 2018. SEBI received complaints regarding alleged price manipulation and misleading YouTube videos. Searches were conducted at certain premises, revealing connected sellers in SBL\u2019s shares. A show cause notice was consequently issued, citing Sections 11(1), 11(4), 11(4A), 11B(1), and 11B(2) of the SEBI Act, 1992, for alleged violations involving artificially inflating the scrip\u2019s price and offloading shares at elevated rates." } }, "chunk_10": { "analysis_of_arguments": "Regulatory authorities contend that the connected entities deliberately generated volume spikes and price increases using online promotions, enabling promoters to offload shares at artificially high prices. The individuals and entities alleged to be connected deny any coordinated manipulation, claiming that trading decisions were independent and not intended to influence market prices.", "cases_referred": [], "facts": "The dispute concerns alleged price and volume manipulation in the shares of Sadhna Broadcast Limited over several distinct periods from September to November 2022. During these phases, the stock price was observed to rise sharply at times and then decline, often coinciding with YouTube video promotions. Certain entities connected to Manish Mishra and others were said to have engaged in significant trading, creating artificial liquidity that allowed the company\u2019s promoters to sell their shares at higher prices. A Show Cause Notice (SCN) was issued, and an investigation followed, culminating in a Final Order addressing the conduct of the connected entities and promoters.", "final_status": "The matter was concluded by issuance of a Final Order in these proceedings.", "formatted_summary": "The Final Order addresses an investigation into suspicious trading patterns of Sadhna Broadcast Limited\u2019s shares. Key findings highlight the coordinated trading by connected entities, triggers for unusual price and volume movements, and the role of YouTube promotions in influencing the market. The investigation concludes that promoters and linked individuals engaged in offloading shares at inflated prices, indicating deliberate market manipulation.", "held": "The Final Order finds that certain connected individuals and promoters engaged in deceptive practices, resulting in artificial price and volume movements in the company\u2019s shares. The ruling emphasizes the need for heightened scrutiny of such manipulative trading activities for future enforcement actions.", "latin_principles": {}, "legal_issues": "Whether repeated share trading and promotional activity constituted market manipulation and whether the involved parties unlawfully coordinated trading volumes and prices to facilitate the promoters\u2019 exit at inflated rates.", "statutes": {} }, "chunk_11": { "analysis_of_arguments": "The regulator contends that the promoters, through intermediaries, orchestrated misleading promotional materials and coordinated trades to push up prices and then sell their holdings for profit. The parties implicated appear to communicate and exchange funds in a manner suggesting deliberate collusion. The snippet does not present any defense arguments from the parties involved.", "cases_referred": [], "facts": "During the period under investigation, the share price of Sadhna Broadcast Limited (SBL) rose sharply, allegedly driven by coordinated trades and promotional videos. Proceedings revealed connections between certain promoters, intermediaries, and individuals who offloaded shares at elevated prices. WhatsApp messages and bank transfers suggest that Manish Mishra, through promotional videos, boosted trading activity, while promoter-related entities sold their shares. An interim order was issued, and SEBI conducted search-and-seizure operations to collect evidence, including WhatsApp chats and financial transaction records. These findings form the background leading to this final order.", "final_status": "No final status is mentioned in the provided text.", "formatted_summary": "The text outlines alleged share price manipulation at Sadhna Broadcast Limited through orchestrated trades and misleading promotional videos. It describes how certain individuals, including promoters, may have coordinated efforts to inflate the share price for personal gain, leading SEBI to conduct searches and issue an interim order based on collected evidence.", "held": "No conclusive decision or directive is provided in the snippet, as it primarily details investigative findings and indicates further examination of the allegations against the Noticees.", "latin_principles": {}, "legal_issues": "Whether the identified transactions and promotional activities amounted to manipulative or fraudulent practices aimed at inflating the company\u2019s share price, and whether the involved parties engaged in coordinated conduct to artificially bolster the stock\u2019s liquidity and value.", "statutes": {} }, "chunk_12": { "analysis_of_arguments": "Subhash Agarwal claimed he was unaware of Manish Mishra\u2019s alleged role and had not traded in SBL\u2019s shares. He maintained he only knew Manish Mishra socially. The authorities, however, contended that the WhatsApp messages and diary entries demonstrated Subhash Agarwal\u2019s direct coordination in the manipulative scheme.", "cases_referred": [], "facts": "Subhash Agarwal and Manish Mishra were found exchanging WhatsApp messages relating to coordinated selling of shares in Sadhna Broadcast Limited (SBL). A search and seizure by SEBI unearthed a diary with records indicating receipt of payments for certain trades. Manish Mishra operated YouTube channels promoting SBL, after which promoter group entities sold shares. Subhash Agarwal denied involvement, but the evidence revealed his active role in planning sales, coordinating trades, and sharing beneficial ownership data. The proceedings culminated in this final order following SEBI\u2019s investigation into suspected share price manipulation.", "final_status": "Decided in this final order", "formatted_summary": "The text details the investigation and final findings by SEBI into share price manipulation of Sadhna Broadcast Limited, highlighting the coordinated actions of promoters and Manish Mishra, and establishing Subhash Agarwal\u2019s key role despite his denials.", "held": "The authority concluded that Subhash Agarwal and Manish Mishra acted in concert to manipulate SBL\u2019s share price. Subhash Agarwal\u2019s denial of involvement was rejected based on chat records and material evidence, reinforcing that he played a critical role in executing the scheme.", "latin_principles": {}, "legal_issues": "Whether Subhash Agarwal and Manish Mishra engaged in manipulative activities to inflate the share price of SBL and if the promoters\u2019 coordinated actions amounted to fraudulent conduct under securities regulations.", "statutes": {} }, "chunk_13": { "analysis_of_arguments": "The promoters argued they were unaware of Manish Mishra\u2019s involvement and that they filed complaints after discovering suspicious videos promoting the company\u2019s shares. However, evidence of messages, email instructions, and seized diaries indicates that Manish Mishra regularly directed the quantity and timing of share sales, challenging the promoters\u2019 claims of no connection.", "cases_referred": [], "facts": "During the investigation period, shares of Sadhna Broadcast Limited were allegedly sold by the promoter group and connected entities shortly after promotional videos were uploaded by Manish Mishra. Communications indicate that Manish Mishra instructed Subhash Agarwal, who in turn relayed these sell orders to various individuals, including Gaurav Gupta. Diaries seized during a search-and-seizure operation corroborate these instructions. Noticees 1 to 4 initially denied having any affiliation with Manish Mishra, yet evidence from WhatsApp chats and email correspondence suggests otherwise. The matter reached this final order stage following an investigation into these coordinated trading activities.", "final_status": "No final status is indicated within the excerpt.", "formatted_summary": "This portion of the order details how certain promoters of Sadhna Broadcast Limited, along with associated individuals, allegedly engaged in coordinated share sales under Manish Mishra\u2019s direction. The transactions occurred shortly after promotional videos were released, suggesting a planned strategy to profit from anticipated market interest. Evidence from seized materials and digital communications undermines the promoters\u2019 claims of having no ties to Manish Mishra and supports the conclusion that they acted together to manipulate trading in the scrip.", "held": "It is concluded that there is sufficient evidence of collaboration between the promoters and Manish Mishra in orchestrating share trades. The authority also notes that other promoters and their associates may have been similarly involved, and the inquiry continues.", "latin_principles": {}, "legal_issues": "Whether the promoters and related entities acted in concert with Manish Mishra to influence the price and trading volume of Sadhna Broadcast Limited\u2019s shares, particularly through strategic sales following promotional uploads.", "statutes": {} }, "chunk_14": { "analysis_of_arguments": "The authorities assert that the individuals managed trades in multiple accounts and manipulated the market for Sadhna Broadcast Limited\u2019s shares. The parties in question appear to maintain that the transactions were legitimate, albeit facilitated through shared resources and communication channels.", "cases_referred": [], "facts": "A group chat was created by certain individuals, including promoters and employees of Sadhna Broadcast Limited, to coordinate the placement and execution of sell orders from multiple promoter-linked demat accounts. Bank statements were exchanged, and OTPs were shared to conduct trades, while funds moved between various entities. An investigation was carried out, culminating in these findings during the final order stage, revealing active control over multiple accounts used for coordinated trading activity.", "final_status": "This matter is addressed in a final order, indicating it has been disposed of at this stage.", "formatted_summary": "In this final order regarding Sadhna Broadcast Limited, the investigation uncovered evidence of coordinated trading through group chats, shared OTPs, and interlinked bank transactions among multiple individuals and entities associated with the company. The conduct revealed active control over various demat accounts for sell-order placements, with notable fund flows indicating a cohesive plan to manipulate share prices.", "held": "The deciding authority found that the noticees exercised active control over trading and were involved in coordinated efforts to influence the price of Sadhna Broadcast Limited\u2019s shares. This decision underscores the importance of transparent market conduct and may serve as a precedent for future inquiries into similar trading activities.", "latin_principles": {}, "legal_issues": "Whether the coordinated trading and fund transfers among promoters, employees, and associated entities amounted to price manipulation or other prohibited practices, and whether these actions demonstrated active collusion in securities transactions.", "statutes": {} }, "chunk_15": { "analysis_of_arguments": "Several Noticees contended their trades were placed independently and denied acting on instructions from the promoters. Others argued they played no significant part or were unaware of any scheme. The investigating authority maintained that the Noticees\u2019 trades, communications, and fund transfers demonstrated coordination with the promoters to artificially inflate SBL\u2019s share price.", "cases_referred": [], "facts": "The dispute arises from an investigation into alleged manipulative trading in the shares of Sadhna Broadcast Limited (SBL). Authorities identified coordinated trades among a group of individuals and entities, supported by evidence of significant fund transfers to promoter-linked companies and communications referencing structured trades. Show cause notices were issued, and each Noticee responded, asserting various defenses. The matter proceeded to a final order after analysis of bank statements, trading records, and WhatsApp chats, culminating in findings regarding the role and involvement of each Noticee.", "final_status": "The matter was disposed of through a final order.", "formatted_summary": "In this final order, the authority examined trading records, fund transfers, and WhatsApp chats suggesting a coordinated scheme to raise SBL\u2019s share price. Several individuals transferred proceeds to entities tied to SBL promoters, demonstrating links among the parties. While most Noticees were found to have participated knowingly in the scheme, one secretarial auditor was given the benefit of the doubt. The order ultimately concludes the matter, holding that the conduct of the Noticees constituted market manipulation.", "held": "It was held that most of the Noticees acted in concert with SBL\u2019s promoters to manipulate share prices through structured trades and fund transfers. One Noticee was granted the benefit of the doubt and was not issued adverse directions. The order underscores the importance of preventing market manipulation and clarifies liability for individuals found to be coordinating trades.", "latin_principles": {}, "legal_issues": "Whether the Noticees were part of a coordinated scheme designed to manipulate the price of SBL shares and whether their trading activities and fund transfers amounted to market manipulation.", "statutes": {} }, "chunk_16": { "analysis_of_arguments": "The Noticees contended they had purchased the shares before the investigation period and denied any collusion with SBL\u2019s promoters. They also argued that they were part of social clubs alongside SBL\u2019s promoters without any ulterior financial motive. The regulators, however, maintained that WhatsApp exchanges and trading patterns demonstrated intentional coordination among the various accounts to manipulate share trading activity.", "cases_referred": [], "facts": "Several individuals associated with Sadhna Broadcast Limited (SBL) were observed placing and matching structured trades in SBL\u2019s shares during the investigation period. WhatsApp communications indicated coordination between certain Noticees and the company\u2019s promoters to execute sales from multiple shareholder accounts. Prior to this stage, the regulator seized documents linking the promoters and key persons, revealing that multiple accounts were allegedly controlled by two individuals who had no direct shareholdings, yet orchestrated sales of SBL shares. These findings became part of the final order\u2019s considerations.", "final_status": "The matter was disposed by issuing a final order.", "formatted_summary": "In this section of the final order, the regulator detailed how certain Noticees engaged in orchestrated trades in Sadhna Broadcast Limited\u2019s shares through multiple accounts controlled by individuals connected with the company\u2019s promoters. WhatsApp communications and seized documents showed that sales were arranged and executed as part of a larger manipulative strategy, leading to the conclusion that the Noticees were integral to the scheme.", "held": "It was held that the Noticees participated in a manipulative scheme facilitated by SBL\u2019s promoters, thereby contributing to irregular trading activity. This finding serves as a precedent reinforcing the scrutiny of coordinated share transactions among connected entities.", "latin_principles": {}, "legal_issues": "Whether the Noticees\u2019 actions amounted to a manipulative trading scheme in coordination with SBL\u2019s promoters and if executing trades from accounts not owned by the coordinators constituted market manipulation.", "statutes": {} }, "chunk_17": { "analysis_of_arguments": "The authority appears to contend that Peeyush and Lokesh orchestrated share sales without holding shares in their own names. The individuals\u2019 perspective or defense is not elaborated in this excerpt, but the conversations indicate their role in coordinating trades through associated accounts.", "cases_referred": [], "facts": "In this portion of the final order concerning Sadhna Broadcast Limited, communications between individuals (including Peeyush and Lokesh) reveal that they were coordinating the sale of the company\u2019s shares through accounts allegedly controlled by them or others. The messages date from April and May 2022, indicating specific times and trades executed in the scrip of SBL. The excerpt recounts details of trades placed and quantities sold, suggesting a pattern of stock transactions executed around the same periods. It does not describe prior court or tribunal rulings in this excerpt.", "final_status": "No final status indicated in this excerpt.", "formatted_summary": "The excerpt details specific WhatsApp exchanges and records of trades made in Sadhna Broadcast Limited, focusing on how certain individuals coordinated share sales through multiple accounts. The evidence arises from communications and trade logs showing the dates, times, and quantities of shares sold.", "held": "No determination is provided in this excerpt regarding the outcome or implications for future cases.", "latin_principles": {}, "legal_issues": "Whether the individuals involved engaged in manipulative or prohibited trading practices in selling shares of Sadhna Broadcast Limited by using accounts of other shareholders.", "statutes": {} }, "chunk_18": { "analysis_of_arguments": "The noticees collectively contended that their share disposals were part of normal transactions, pointing out their longstanding ownership of SBL shares. The investigating authority argued these transactions formed a deliberate plan to inflate trading volume and manipulate the market. It was further asserted that certain accounts were under the effective control of parties orchestrating a broader strategy.", "cases_referred": [], "facts": "Multiple individuals connected with Sadhna Broadcast Limited (SBL) placed or facilitated share trades according to instructions relayed through WhatsApp chats. Certain accounts were used or operated by two individuals, Peeyush and Lokesh, who directed the sale of large quantities of SBL shares. The shares were sold in specific quantities around May and July 2022. Some of the account holders stated they had owned shares of SBL for several years. Investigative findings indicated that the trades were coordinated by key persons controlling various accounts. Prior to this final order, the matter progressed through an investigation and issuance of a show cause notice (SCN).", "final_status": "Disposed through a final order with findings of coordinated market manipulation.", "formatted_summary": "This section of the final order details coordinated share sales in Sadhna Broadcast Limited. Several accounts were operated at the direction of two key individuals who instructed the timing and quantity of trades. The participants argued they owned shares for a long period and were merely selling in the normal course. However, the order finds that these coordinated actions helped drive a manipulated trading pattern, identifying the noticees as part of a broader scheme to influence the share price and volumes in SBL.", "held": "It was held that multiple noticees had acted in concert to manipulate SBL\u0027s share price by operating or allowing the operation of several accounts. The decision underscores that longstanding shareholding does not preclude finding a person part of a larger manipulative scheme, setting a precedent that coordinated trading activity can establish liability.", "latin_principles": {}, "legal_issues": "Whether the coordinated sales of SBL shares constituted a manipulative scheme and whether certain individuals were operating multiple accounts to influence SBL\u0027s share price and trading volume.", "statutes": { "PFUTP Regulations": "183. In view of the above, I hold that Peeyush Agrawal (Noticee 25 ) and Lokesh Shah (Noticee 26) were part of the scheme to manipulate the price of the scrip of SBL and towards this end they were operating the accounts of Noticees 27 to 38. The shares of SBL held in the accounts of Noticees 27 to 38 were sold in a manner to support the manipulative scheme orchestrated by the promoters of SBL in collusion with Manish Mishra. Noticees 27 to 38, by allowing their accounts to be used in this manner, have violated the provisions of the PFUTP Regulations, as alleged in the SCN ." } }, "chunk_19": { "analysis_of_arguments": "The authority contended that the Noticees coordinated with each other to offload or purchase shares at artificially high prices. Evidence of connections, such as frequent phone calls and WhatsApp chats, was cited to show collusion. The Noticees generally denied involvement, maintaining that their trading activity was independent and not intended to inflate share prices.", "cases_referred": [], "facts": "The proceeding arose from alleged manipulative trading activities in the shares of Sadhna Broadcast Limited (SBL). Investigations revealed that certain individuals, including Noticees 22, 23, 24, and others connected to Manish Mishra and Subhash Agarwal, traded SBL shares at inflated or structured prices. Authorities examined call data records, WhatsApp messages, and trading patterns. The Noticees were alleged to have offloaded or purchased shares in a coordinated manner. The matter proceeded through issuance of a show cause notice (SCN), submission of replies by the Noticees, and analysis of their trading patterns prior to this Final Order.", "final_status": "Disposed through a final order", "formatted_summary": "This section of the Final Order addresses alleged collusive trading in Sadhna Broadcast Limited\u2019s shares. It describes evidence of coordination among various Noticees, including detailed phone and WhatsApp communications indicating offloading and structured buying at prices above prevailing market levels. The order rejects the Noticees\u2019 claims of non-involvement, concluding that the trading was orchestrated as part of a larger manipulative scheme.", "held": "It was concluded that the Noticees, acting under instructions or in coordination with key individuals, were part of a larger scheme to manipulate the price of SBL\u2019s shares. The finding applies to all implicated Noticees and underscores the authority\u2019s view that such collusive trading practices undermine fair market conduct.", "latin_principles": {}, "legal_issues": "Whether the Noticees engaged in a scheme to manipulate SBL\u2019s share price by executing structured trades and whether their connections and communications constituted concerted action in breach of securities market regulations.", "statutes": {} }, "chunk_2": { "analysis_of_arguments": "The regulator contends that certain individuals and connected entities collaborated to publish misleading information, artificially raise trading volumes, and profit from inflated share prices. The responding Noticees, through their replies and court petitions, generally deny any wrongdoing and dispute the existence of a coordinated scheme, challenging the inferences drawn from transactional patterns and linkages.", "cases_referred": [ "Writ Petition (L) 14100 of 2025 (Before High Court of Bombay)", "SCA 11702 of 2023 (Before High Court of Gujarat)", "SCA 11463 of 2023 (Before High Court of Gujarat)" ], "facts": "The present dispute arises from allegations of price manipulation in the scrip of Sadhna Broadcast Limited (SBL) during the period from March 8, 2022 to November 30, 2022. A show cause notice was issued to 64 entities following an investigation by SEBI, which highlighted purported coordinated efforts to artificially inflate the stock price and offload shares at elevated levels. An Interim Order dated March 2, 2023 was passed against 31 entities, and a search-and-seizure operation also took place. Various Noticees either filed replies, appeared at scheduled hearings, or sought relief through writ petitions in different High Courts.", "final_status": "No final disposition is mentioned in the excerpt provided.", "formatted_summary": "SEBI investigated the trading activities of Sadhna Broadcast Limited, noting significant price and volume fluctuations in the stock. A show cause notice was issued to 64 entities for allegedly orchestrating false promotions via YouTube videos and engaging in coordinated trading. The investigation identified separate categories of participants, including those disseminating misleading messages, connected sellers, volume creators, and intermediaries. Subsequently, an Interim Order was passed and multiple Noticees either attended hearings before SEBI or filed petitions in various High Courts, challenging the investigation or seeking relief. No final adjudicatory outcome is stated in the provided text.", "held": "No details regarding the final decision by the adjudicating authority or court are provided in the excerpt.", "latin_principles": {}, "legal_issues": "Whether the alleged actions of orchestrating misleading publicity through YouTube videos, structured market trades, and coordinated share offloading amount to fraudulent and unfair trade practices; and whether the involved Noticees acted in concert to manipulate the market during the investigation period.", "statutes": { "PFUTP Regulations, 2003": "8. The SCN also detailed the linkages between the various entities based on common KYC attributes, call data records, fund transfers, common addresses, familial relationships, and trading behaviour. It was alleged that the 64 Noticees acted in concert and were part of a common fraudulent scheme in contravention of the provisions of the SEBI Act, 1992 and the SEBI (Prohibition of Fraudulent and Unfair Trade Practices Relating to Securities Market) Regulations, 2003 (\u201cPFUTP Regulations, 2003\u201d).", "SEBI Act, 1992": "5. SEBI conducted a detailed investigation into the alleged manipulation in the scrip of SBL for the period from March 8, 2022 to November 30, 2022 (Investigation Period /IP). Based on the findings of the investigation, a show cause notice (SCN) was issued to 64 entities calling upon them to show cause as to why suitable directions under Sections 11(1), 11(4), 11(4A), 11B(1) and 11B(2) of the SEBI Act, 1992 should not be issued against them for the violations alleged therein." } }, "chunk_20": { "analysis_of_arguments": "Some Noticees argued that they were not connected and that the trades were independent under normal market practices. The authority contended that recurring patterns in instructions, shared addresses, overlapping bank transactions, and simultaneous buy-sell orders evidenced a concerted scheme to inflate SBL\u2019s share price.", "cases_referred": [], "facts": "Multiple individuals, including Jatin Shah and his children, as well as associates such as Manish Mishra and their connected entities, were found trading in the shares of Sadhna Broadcast Limited (SBL). WhatsApp messages revealed that certain parties were instructed to buy or sell SBL shares at specific prices, and bank accounts were allegedly used to channel payments. A Show Cause Notice (SCN) was issued based on trading data and communications indicating that trades were structured and coordinated. Procedurally, the investigation culminated in this final order, after which it was determined whether each Noticee was connected to the alleged scheme.", "final_status": "disposed", "formatted_summary": "In this portion of the final order, the investigation outlines the roles of various individuals linked to suspected manipulative trades in the SBL scrip. Evidence of coordinated instructions, matched trades, and associated bank transfers supported the conclusion that most Noticees participated in a price inflation scheme, though one was found unconnected.", "held": "Most Noticees were found to be acting in concert with Manish Mishra and Jatin Shah to manipulate the share price of SBL, while one Noticee was not found liable due to insufficient evidence. This determination underscores that those coordinating trades for artificial price inflation are liable under the findings of the final order.", "latin_principles": {}, "legal_issues": "Whether the identified individuals engaged in coordinated and manipulative trading practices aimed at artificially inflating the share price of SBL, and whether certain parties were correctly deemed part of the larger scheme based on their trading patterns and communications.", "statutes": {} }, "chunk_21": { "analysis_of_arguments": "Authorities suggest that certain trades, chat communications, and fund transfers illustrate a deliberate plan to raise share prices. The respondents appear to argue that their trades reflect legitimate trading decisions and deny any coordinated manipulation.", "cases_referred": [], "facts": "During the relevant period, certain individuals, including Manish Mishra, were alleged to have manipulated the share price of Sadhna Broadcast Limited (SBL). WhatsApp conversations and fund transfers among the involved parties suggested coordinated activities designed to influence stock prices. The case also involved trades by individuals such as Purav and Aahuti, who conducted transactions in scrips recommended by Manish Mishra. The Show Cause Notice (SCN) highlighted repeated patterns of purchasing and selling, along with specific communication that indicated an intentional effort to raise share prices artificially. These activities came under scrutiny during the Investigation Period, culminating in issuance of a final order exploring their respective roles.", "final_status": "No final disposition is indicated in the excerpt.", "formatted_summary": "The excerpt describes alleged manipulative trading in shares of Sadhna Broadcast Limited. Individuals including Manish Mishra, Purav, and Aahuti were investigated for suspected coordinated activities. WhatsApp exchanges, trading patterns, and financial transactions form the basis of the allegations. Although part of a final order, the excerpt does not specify the ultimate decision or outcome.", "held": "This excerpt does not contain the court\u2019s conclusive holding; the matter remains addressed in the larger final order.", "latin_principles": {}, "legal_issues": "Whether the parties named were engaged in manipulative and coordinated trading activities to influence the share price of Sadhna Broadcast Limited.", "statutes": {} }, "chunk_22": { "analysis_of_arguments": "The authorities assert that the trades were orchestrated to inflate the stock price for personal gain. Certain Noticees appear to contend that they acted on advice or under instructions without knowledge of any manipulative intent.", "cases_referred": [], "facts": "Investigations revealed that Aahuti Rasik Mistry placed a buy order in the shares of Sadhna Broadcast Limited (SBL) at a rate higher than the prior day\u2019s closing price, allegedly on the instructions of Manish Mishra. Connected parties, including promoters and associates, placed matching sell orders shortly thereafter. Evidence from WhatsApp chats indicated a coordinated plan to raise SBL\u2019s share price through these transactions in May 2022. Further inquiries showed that Arshad Hussain Warsi, Maria Goretti Warsi, and Iqbal Hussain Warsi also traded in scrips associated with Manish Mishra. SEBI recorded statements from several individuals and issued show-cause notices, culminating in this final order.", "final_status": "Not explicitly stated in the provided excerpt.", "formatted_summary": "In the final order concerning Sadhna Broadcast Limited, evidence shows that trades were placed at prices exceeding the previous closing rate under Manish Mishra\u2019s direction, with numerous connected persons matching these buy orders. WhatsApp exchanges revealed the coordination, and additional individuals linked to Manish Mishra engaged in similar trading in SBL and other scrips. The order concludes that Aahuti Mistry and others acted with knowledge of the plan to inflate SBL\u2019s share price.", "held": "It was held that Aahuti Mistry was aware of and participated in a manipulative scheme organized by Manish Mishra. The individuals named were found to have engaged in or facilitated suspicious trading activities pointing to concerted price manipulation.", "latin_principles": {}, "legal_issues": "Whether the coordinated buy and sell orders among the Noticees amounted to a scheme to artificially manipulate the share price of SBL.", "statutes": {} }, "chunk_23": { "analysis_of_arguments": "The Noticees contend they were unaware of the stock market\u2019s intricacies and that Manish Mishra orchestrated the trades without fully informing them of the potential consequences. On the other hand, the evidence suggests coordinated trading and direct instructions, indicating a deliberate role in creating artificial market activity.", "cases_referred": [], "facts": "Several individuals, including Arshad Warsi, Iqbal Hussain Warsi, and others, were involved in trading shares of Sadhna Broadcast Ltd (SBL) during mid-2022. WhatsApp chats show that Manish Mishra provided instructions and facilitated funds to purchase or sell these shares in a manner suggesting coordinated or structured trades. Some Noticees claimed ignorance, stating they were new to the stock market, but evidence revealed that they actively participated in transactions potentially intended to manipulate SBL\u2019s share price. Prior to this final order, Noticee 59 submitted a settlement application, resulting in a separate settlement order.", "final_status": "The proceedings have been disposed of through this final order, with partial settlement for one of the Noticees.", "formatted_summary": "In this final order involving Sadhna Broadcast Ltd, the evidence showed multiple Noticees received trading instructions from Manish Mishra and carried out a series of coordinated transactions in SBL\u2019s shares. Despite their assertion of limited market knowledge, their actions appeared to support a pump and dump plan. Certain Noticees settled separately under SEBI\u2019s settlement regulations, while others faced liability for their roles in facilitating the scheme.", "held": "The authority determined that the Noticees facilitated and abetted a manipulative scheme in SBL\u2019s shares, undermining market integrity. Their claims of naivety were not accepted in light of the clear evidence of structured trades and instructions. The decision underscores that active participation in such transactions, even under alleged ignorance, attracts liability and signals strict regulatory scrutiny of market manipulation.", "latin_principles": {}, "legal_issues": "Whether the Noticees engaged in manipulative trading by executing structured trades in SBL\u2019s shares and whether their claimed lack of market knowledge absolves them of responsibility for participation in a potential pump and dump scheme.", "statutes": { "Securities and Exchange Board of India (Settlement Proceedings) Regulations 2018": "241. Ravindra Dahyabhai Patel (Noticee 59) submitted a settlement application under Securities and Exchange Board of India (Settlement Proceedings) Regulations 2018, and the proceedings initiated against Ravindra Dahyabhai Patel vide SCN dated January 9, 2024 were disposed of vide settlement order dated February 27, 2025. It is noted that in terms of Regulation 27 (2) of the Settlement Regulations, a settlement order issued by SEBI does not automatically conclude or affect other potential proceedings against Noticees related to the individual." } }, "chunk_24": { "analysis_of_arguments": "Some Noticees claimed they merely followed instructions from Manish Mishra or family members and had no intent to manipulate. Noticee 64 argued that his trades reflected a momentum-based strategy and lacked any connection to other Noticees or the alleged scheme. The regulator contended that consistent and coordinated buying at specific prices artificially inflated SBL\u2019s share price and volume.", "cases_referred": [], "facts": "In a proceeding initiated by SEBI concerning alleged price manipulation in the shares of Sadhna Broadcast Limited, it was found that Manish Mishra directed trades through several individuals, including the family members of Noticee 59. Large purchase orders were placed on specific days, contributing significantly to daily trade volumes and increasing the share price. Noticee 59 submitted a settlement application, resulting in disposal of proceedings against him. Noticee 64 placed buy orders at daily upper limits but was found unconnected to the broader scheme. The SCN dated January 9, 2024, culminated in these final orders on liability and disgorgement.", "final_status": "Proceedings against Noticee 59 were disposed of by settlement, and no adverse directions were issued against Noticee 64.", "formatted_summary": "This section details alleged manipulative trading in SBL\u2019s shares orchestrated by Manish Mishra, involving multiple Noticees who contributed significantly to daily trading volumes. Noticee 59 settled the proceedings, and Noticee 64 was found unconnected to the broader scheme, prompting no adverse directions against him. The order addresses liability, disgorgement, and settlement outcomes for the involved parties.", "held": "The authority concluded certain Noticees engaged in manipulative trades under Manish Mishra\u2019s instructions, while Noticee 64 was given the benefit of the doubt due to lack of any demonstrable link to the scheme. No separate disgorgement orders were passed against Noticees 56-58, and settlement for Noticee 59 accounted for profits from related accounts.", "latin_principles": {}, "legal_issues": "Whether the trading activities undertaken by certain Noticees were manipulative in nature, breaching securities regulations, and whether certain individuals aided or abetted the alleged pump-and-dump strategy.", "statutes": { "Securities and Exchange Board of India (Settlement Proceedings) Regulations 2018": "241. Ravindra Dahyabhai Patel (Noticee 59) submitted a settlement application under Securities and Exchange Board of India (Settlement Proceedings) Regulations 2018, and the proceedings initiated against Ravindra Dahyabhai Patel vide SCN dated January 9, 2024 were disposed of vide settlement order dated February 27, 2025. It is noted that in terms of Regulation 27 (2) of the Settlement Regulations, a settlement order issued by SEBI does not automatically conclude or affect other potential proceedings against Noticees related to the individual." } }, "chunk_25": { "analysis_of_arguments": "The regulator maintains that the Noticees orchestrated or facilitated a scheme to artificially inflate the share price, thereby obtaining profits through deceptive practices. Several Noticees contended that they had minimal or no involvement, lacked direct connections with the central figures, or claimed that losses should offset their gains. The regulator rejected the offsetting argument, emphasizing that such losses could not be used to mitigate liability arising from wrongful conduct.", "cases_referred": [ "Adjudicating Officer, SEBI vs Bhavesh Pabari (2019) SCC Online SC 294" ], "facts": "The dispute arises from alleged manipulative trading activities in the shares of Sadhna Broadcast Limited during the investigation period. Multiple individuals and entities (Noticees) were identified as having executed trades that purportedly inflated the share price, contributing to a \u0027pump and dump\u0027 operation. The regulator computed ill-gotten gains based on the trading patterns and found certain Noticees jointly and severally liable for disgorgement. Some Noticees\u2014such as Noticee 64\u2014were granted the benefit of doubt due to a lack of evidence linking them to the central manipulators. Prior to this final order, a show cause notice was issued and responses were evaluated to determine the extent of each party\u2019s involvement.", "final_status": "A final order was issued addressing liability, disgorgement, and penalties.", "formatted_summary": "In this final order concerning potential market manipulation of Sadhna Broadcast Limited\u2019s shares, various Noticees were accused of orchestrating or facilitating a \u2018pump and dump\u2019 operation. The regulator identified principal figures who allegedly planned and executed the scheme, thereby earning ill-gotten gains. Several individuals were found jointly and severally liable for disgorgement of profits, while certain others, including Noticee 64, were given the benefit of doubt due to insufficient evidence. The order elaborates on the calculation of illicit profits, discusses joint liability, and addresses claims for loss offsets, ultimately reinforcing the prohibition on unfair trading practices.", "held": "It was held that the principal operators had planned and executed the manipulation, rendering them jointly and severally liable to disgorge unlawful gains. Noticee 64 was spared adverse directions due to insufficient evidence of involvement. The decision underscores the requirement that ill-gotten profits from unfair trading be returned, reinforcing the regulator\u2019s stance against market manipulation.", "latin_principles": {}, "legal_issues": "The key legal questions center on whether the Noticees engaged in manipulative trading in violation of regulatory provisions, whether various individuals and entities can be held jointly and severally liable for any ill-gotten gains, and whether offsetting of purported losses is permissible under the applicable framework.", "statutes": { "PFUTP Regulations, 2003": "258. The conduct of all the Noticees, other than Noticees 14, 48 , 59 and 64 , in manipulating the share price of SBL is in violation of the provisions of Sections 12A(a), (b) and (c) of the SEBI Act, 1992 read with Regu lations 3(a), (b), ( c), (d), 4(1) and 4(2)(a), (d) and (e) of the PFUTP Regulations, 2003. Additionally, Noticee 52 has violated the prov isions of Regulations 4(2) (k) and (r) of the PFUTP Regulations, 2003.", "SEBI Act, 1992": "258. The conduct of all the Noticees, other than Noticees 14, 48 , 59 and 64 , in manipulating the share price of SBL is in violation of the provisions of Sections 12A(a), (b) and (c) of the SEBI Act, 1992 read with Regu lations 3(a), (b), ( c), (d), 4(1) and 4(2)(a), (d) and (e) of the PFUTP Regulations, 2003. Additionally, Noticee 52 has violated the prov isions of Regulations 4(2) (k) and (r) of the PFUTP Regulations, 2003.", "Securities and Exchange Board of India (Procedure for Holding Inquiry and Imposing Penalties) Rules, 1995": "259. The SCN has also contemplated directions under Sections 11(4A) and 11B(2) of the SEBI Act read with Rule 4 of Securities and Exchange Board of India (Procedure for Holding Inquiry and Imposing Penalties) Rules, 1995 (\u201cAdjudication Rules, 1995 \u201d) imposing monetary penalty as stated in Section 15HA of the SEBI Act in respect of all the Noticees." } }, "chunk_26": { "analysis_of_arguments": "Regulatory authorities contend that the promoters and connected entities colluded to inflate share prices, disseminating misleading information to lure retail investors. The promoters and other noticees either denied any fraudulent intent or minimized their involvement, asserting that any trading or promotional activities were legitimate and did not amount to manipulation. SEBI, however, concluded that the cumulative effect of collusive trading and misleading videos demonstrated a coordinated pump-and-dump operation.", "cases_referred": [ "Adjudicating Officer, SEBI v. Bhavesh Pabari (2019) SCC Online SC 294" ], "facts": "During the relevant period, the promoters of Sadhna Broadcast Limited planned and executed a scheme to artificially inflate the company\u2019s share price through structured trades and misleading promotional content posted on social media. As the artificially raised price attracted unsuspecting retail investors, the promoters offloaded large portions of their holdings at significant profit. The Securities and Exchange Board of India (SEBI) initiated proceedings, culminating in this final order imposing penalties and market restrictions on those found responsible. Prior to this stage, SEBI investigated the matter, issued show-cause notices, and has now passed the present order determining liability and sanctions.", "final_status": "Disposed with directions and imposition of penalties.", "formatted_summary": "This order addresses a coordinated pump-and-dump scheme executed by the promoters and several collaborators at Sadhna Broadcast Limited (later renamed). Through artificially inflating the share price and distributing misleading promotional content, the participants offloaded significant holdings to retail buyers. SEBI found these acts to violate the PFUTP Regulations and the SEBI Act, imposing bans on market access, disgorgement, and monetary penalties. The order highlights the growing concern over social media-based stock promotions and reaffirms SEBI\u2019s intent to penalize such manipulative practices in protection of market integrity.", "held": "SEBI held that the noticees, including the company\u2019s promoters, orchestrated a systematic scheme to inflate share prices and offload shares at artificially high values. The order imposes disgorgement of unlawful gains, monetary penalties, and trading bans, reflecting a strict stance against market manipulation. It underscores the high level of regulatory scrutiny that will continue to be applied to fraudulent market practices.", "latin_principles": {}, "legal_issues": "1) Whether the noticees engaged in manipulative and fraudulent practices under securities laws. 2) Whether misleading social media videos and structured trades violated prohibitions on unfair trade practices. 3) The extent to which individual participants, including promoters and collaborators, bear liability for the resulting market disruption.", "statutes": { "Adjudication Rules, 1995": "Paragraph 278 (same text as referenced under the SEBI Act, 1992, because it also cites Rule 5 of the Adjudication Rules, 1995):\n\n\"278. In view of the aforesaid findings and having regard to the facts and circumstances of the matter, I, in exercise of the powers conferred upon me under Section 19 read with Sections 11(1), 11(4), 11(4A) and 11B read with Section 15I of the SEBI Act and Rule 5 of the Adjudication Rules, 1995, hereby direct as under: \n\na. Noticees 1, 2, 21, 25, 26, 39 and 52 are restrained from accessing the securities market and further prohibited from buying, selling or otherwise dealing in securities, directly or indirectly, or being associated with the securities market in any manner, whatsoever, for a period of five (5) years from the date of this Order. \n\nb. Noticees 3, 4-7, 9-13, 15-20, 22-24, 27-38, 40-47, 49-51, 53-58 and 60-63 are restrained from accessing the securities market and further prohibited from buying, selling or otherwise dealing in securities, directly or indirectly, or being associated with the securities market in any manner, whatsoever, for a period of one (1) year from the date of this Order. \n\nc. Noticees shall disgorge the amounts mentioned against their respective names in the Table under Para 255 above, along with simple interest at the rate of 12% per annum, calculated from the end of the Investigation Period till the date of actual payment. \n\nd. The amount mentioned in paragraph 278(c) shall be remitted by the aforementioned Noticees to the Investor Protection and Education Fund (IPEF) referred to in Section 11(5) of the SEBI Act, within 45 (forty\u2013five) days from the date of receipt of this Order. An intimation regarding the payment of said disgorgement amount directed to be paid herein, shall be sent to \u201cThe Division Chief, ISD-SEC 5, SEBI, SEBI Bhavan II, Plot no. C-7, \u2018G\u2019 Block, Bandra Kurla Complex, Bandra (E), Mumbai \u2013400 051\u201d. \n\ne. The following Noticees are hereby imposed with a monetary penalty under Section 15HA of the SEBI Act, as indicated in the Table below: \nNoticee No. | Name of the Noticee | Penalty\n1. | Gaurav Gupta | 2,00,00,000\n2. | Rakesh Kumar Gupta | 2,00,00,000\n3. | Shreya Gupta | 25,00,000\n4. | Saurabh Gupta | 25,00,000\n5. | Arpan Gupta | 10,00,000\n6. | Sadhna Bio Oils Pvt. Ltd. | 25,00,000\n7. | Virtual Business Solution Pvt. Ltd. | 25,00,000\n8. | Varun Media Pvt Ltd | No penalty\n9. | Naman Broadcastings And Telecommunications Pvt Ltd | 25,00,000\"\n", "Insolvency and Bankruptcy Code (IBC)": "Paragraph 277:\n\n\"277. In view of the pending CIRP proceedings against Varun Media Pvt. Ltd. (Noticee 8) and prevailing moratorium under Section 14 of the IBC, monetary penalty is not being imposed on Noticee 8 at this stage and the proceedings against the Company will be decided/ disposed of through a separate order by SEBI. However, direction for disgorgement shall be applicable against the said Noticee.\"", "Prohibition of Fraudulent and Unfair Trade Practices (PFUTP) Regulations, 2003": "Paragraph 275:\n\n\"275. Such conduct strikes at the very heart of market integrity. It not only violates the provisions of the PFUTP Regulations, 2003, but also undermines investor trust in the fairness and transparency of the securities market.\"", "Securities and Exchange Board of India Act, 1992": "Paragraph 101:\n\n\"Explanation. \u2014For the removal of doubts, it is clarified that the power to adjudge the quantum of penalty under sections 15A to 15E, clauses (b) and (c) of section 15F, 15G, 15H and 15HA shall be and shall always be deemed to have been exercised under the provisions of this section.\u201d\n\nParagraph 263:\n\n\"263. Additionally, reference is made to the case of Adjudicating Officer, SEBI V. Bhavesh Pabari, 2 whereby the Supreme Court had held, \u201c\u2026if the penalty provisions are to be understood as not admitting of any exception or discretion and the penalty as prescribed in Section 15\u00adA to Section 15\u00adHA of the SEBI Act is to be mandatorily imposed in case of default/failure, Section 15\u00adJ of the SEBI Act would stand obliterated and eclipsed. Hence, the question referred. Sections 15\u00adA(a) to 15\u00adHA have to be read along with Section 15\u00adJ in a manner to avoid any inconsistency or repugnancy.\u201d\"\n\nParagraph 278:\n\n\"278. In view of the aforesaid findings and having regard to the facts and circumstances of the matter, I, in exercise of the powers conferred upon me under Section 19 read with Sections 11(1), 11(4), 11(4A) and 11B read with Section 15I of the SEBI Act and Rule 5 of the Adjudication Rules, 1995, hereby direct as under: \n\na. Noticees 1, 2, 21, 25, 26, 39 and 52 are restrained from accessing the securities market and further prohibited from buying, selling or otherwise dealing in securities, directly or indirectly, or being associated with the securities market in any manner, whatsoever, for a period of five (5) years from the date of this Order. \n\nb. Noticees 3, 4-7, 9-13, 15-20, 22-24, 27-38, 40-47, 49-51, 53-58 and 60-63 are restrained from accessing the securities market and further prohibited from buying, selling or otherwise dealing in securities, directly or indirectly, or being associated with the securities market in any manner, whatsoever, for a period of one (1) year from the date of this Order. \n\nc. Noticees shall disgorge the amounts mentioned against their respective names in the Table under Para 255 above, along with simple interest at the rate of 12% per annum, calculated from the end of the Investigation Period till the date of actual payment. \n\nd. The amount mentioned in paragraph 278(c) shall be remitted by the aforementioned Noticees to the Investor Protection and Education Fund (IPEF) referred to in Section 11(5) of the SEBI Act, within 45 (forty\u2013five) days from the date of receipt of this Order. An intimation regarding the payment of said disgorgement amount directed to be paid herein, shall be sent to \u201cThe Division Chief, ISD-SEC 5, SEBI, SEBI Bhavan II, Plot no. C-7, \u2018G\u2019 Block, Bandra Kurla Complex, Bandra (E), Mumbai \u2013400 051\u201d. \n\ne. The following Noticees are hereby imposed with a monetary penalty under Section 15HA of the SEBI Act, as indicated in the Table below: \nNoticee No. | Name of the Noticee | Penalty\n1. | Gaurav Gupta | 2,00,00,000\n2. | Rakesh Kumar Gupta | 2,00,00,000\n3. | Shreya Gupta | 25,00,000\n4. | Saurabh Gupta | 25,00,000\n5. | Arpan Gupta | 10,00,000\n6. | Sadhna Bio Oils Pvt. Ltd. | 25,00,000\n7. | Virtual Business Solution Pvt. Ltd. | 25,00,000\n8. | Varun Media Pvt Ltd | No penalty\n9. | Naman Broadcastings And Telecommunications Pvt Ltd | 25,00,000\"\n" } }, "chunk_27": { "analysis_of_arguments": "The regulator maintained that various Noticees participated in improper market practices, justifying imposition of disgorgement and penalties. The concerned Noticees, in different ways, claimed absence of any wrongdoing, contending that their activities complied with the relevant norms.", "cases_referred": [], "facts": "Multiple Noticees associated with Sadhna Broadcast Limited were investigated for alleged activities in the securities market. Following the inquiry, the Securities and Exchange Board of India issued this Final Order. The Noticees were directed to disgorge specific amounts and, in many instances, were each subjected to a monetary penalty. A few Noticees were found not liable for penalty. This Order concludes the proceedings, mandating that payments be made within specified deadlines and outlining the steps for compliance.", "final_status": "Disposed through the issuance of this final order, imposing penalties and restrictions.", "formatted_summary": "This final section of the SEBI Order imposes penalties, disgorgement of certain sums with interest, and a market access ban for one year on many of the named Noticees, while some are exempted from monetary penalty. The Order details the amounts owed, the payment procedures, and relevant deadlines.", "held": "All Noticees found guilty of the alleged violations have been restrained from accessing the securities market for one year. They are required to disgorge specified amounts with interest and, in most instances, to pay separate monetary penalties. Some Noticees were spared penalties but remain bound by the Order\u2019s directions. This demonstrates the regulator\u2019s firm stance on enforcing market discipline.", "latin_principles": {}, "legal_issues": "Whether the Noticees engaged in conduct warranting disgorgement, monetary penalties, and trading prohibitions in the securities market, and whether their actions contravened the regulatory framework governing market integrity.", "statutes": { "SEBI Act (Section 11(5))": "(d) The amount mentioned in paragraph 278(c) shall be remitted by the aforementioned Noticees to the Investor Protection and Education Fund (IPEF) referred to in Section 11(5) of the SEBI Act, within 45 (forty\u2013five) days from the date of receipt of this Order. An intimation regarding the payment of said disgorgement amount directed to be paid herein, shall be sent to \u0027The Division Chief, ISD-SEC 5, SEBI, SEBI Bhavan II, Plot no. C-7, \u0027G\u0027 Block, Bandra Kurla Complex, Bandra (E), Mumbai \u2013400 051\u0027.", "SEBI Act (Section 15HA)": "e. The following Noticees are hereby imposed with a monetary penalty under Section 15HA of the SEBI Act, as indicated in the Table below: Noticee No. Name of the Noticee Penalty 1. Gaurav Gupta 2,00,00,000 2. Rakesh Kumar Gupta 2,00,00,000 3. Shreya Gupta 25,00,000 4. Saurabh Gupta 25,00,000 5. Arpan Gupta 10,00,000 6. Sadhna Bio Oils Pvt. Ltd. 25,00,000 7. Virtual Business Solution Pvt. Ltd. 25,00,000 8. Varun Media Pvt Ltd No penalty 9. Naman Broadcastings And Telecommunications Pvt Ltd 25,00,000" } }, "chunk_28": { "analysis_of_arguments": "No arguments from either side are presented in the provided text.", "cases_referred": [], "facts": "The final order was issued in the matter of Sadhna Broadcast Limited, requiring the order to be served on all Noticees, recognized stock exchanges, depositories, registrar and share transfer agents, and banks to ensure compliance. The order is dated May 29, 2025, and was passed by the Whole Time Member of the Securities and Exchange Board of India in Mumbai.", "final_status": "The matter stands disposed.", "formatted_summary": "This brief final order, dated May 29, 2025, in the matter of Sadhna Broadcast Limited, requires service of the directive on all noticees and relevant financial entities to ensure compliance, concluding the proceedings before the Securities and Exchange Board of India.", "held": "The order directs all relevant parties to ensure compliance, concluding the proceedings.", "latin_principles": {}, "legal_issues": "No specific legal issues are discussed in the provided text.", "statutes": {} }, "chunk_3": { "analysis_of_arguments": "Several Noticees argued that they were not given adequate documents or cross-examination rights and questioned the legitimacy of electronic records seized during the investigation. SEBI countered that all relevant documents not containing third-party or sensitive information were provided and that statements were used only in a limited context. SEBI maintained the electronic records were admissible, having been seized under due authority with a valid certificate.", "cases_referred": [ "14100 of 2025 \u2013 Before High Court of Bombay", "SCA 11702 of 2023 \u2013 Before High Court of Gujarat", "SCA 11463 of 2023 \u2013 Before High Court of Gujarat", "Appeal by Noticees 60-62 before the Hon\u2019ble Securities Appellate Tribunal" ], "facts": "This matter pertains to alleged market manipulation involving Sadhna Broadcast Limited (SBL). Various Noticees were served with a Show Cause Notice (SCN) after SEBI\u2019s investigation revealed potential pump-and-dump activities in SBL\u2019s stock, allegedly amplified by YouTube videos. Certain Noticees filed replies; others did not. A few Noticees approached the Gujarat and Bombay High Courts for relief, but no stay was granted on the final order. The Securities Appellate Tribunal also directed SEBI to conclude the proceedings by May 31, 2025. The final order is now issued, based on replies and evidence on record.", "final_status": "Disposed through a final order issued by SEBI.", "formatted_summary": "In a final order regarding Sadhna Broadcast Limited, SEBI examined allegations of a pump-and-dump operation, partly executed through YouTube videos. Certain Noticees either provided partial replies or filed writ petitions, but no judicial stay prevented SEBI\u2019s proceedings. Procedural objections on document inspection, cross-examination, and electronic evidence were rejected. The order ultimately addresses liability for market manipulation, highlighting proper seizure and admissibility of electronic records under the SEBI and Indian Evidence Acts.", "held": "Preliminary objections regarding non-furnishing of documents, cross-examination, and electronic evidence admissibility were rejected and the matter proceeded on merits. The order addresses the alleged involvement of Noticees in the pump-and-dump scheme and holds them accountable based on the available record, setting an approach for similar future market manipulation concerns.", "latin_principles": {}, "legal_issues": "Whether the Noticees engaged in manipulative trading practices and dissemination of misleading information; whether procedural objections on inspection, cross-examination, and admissibility of electronic evidence affect the proceedings; and whether the absence of a stay order allows SEBI to finalize the action.", "statutes": { "Indian Evidence Act 1872": "13.5. Electronic Records \u2013 It is observed that certain Noticees vide their replies contested the admissibility of electronic records seized during the Search -and-Seizure operations . In thi s regard , I note that SEBI appointed an Investigating Authorit y under section 11C of the SEBI Act, 1992 to carry out an investigation in the matter. Subsequently, after obtaining due permission of the Competent Court, a Search -and-Seizure operation was carried out . The said order of the Competent Court granted authorisation to the Investigating Authori ty to search and seize evidence including electronic data stored in electronic devices. Further, wherever required, a certificate under Section 65B of the Indian Evidence Act 1872 was duly obtained to ensure the admissibility of electronic records.", "SEBI Act, 1992": "13.5. Electronic Records \u2013 It is observed that certain Noticees vide their replies contested the admissibility of electronic records seized during the Search -and-Seizure operations . In thi s regard , I note that SEBI appointed an Investigating Authorit y under section 11C of the SEBI Act, 1992 to carry out an investigation in the matter. Subsequently, after obtaining due permission of the Competent Court, a Search -and-Seizure operation was carried out . The said order of the Competent Court granted authorisation to the Investigating Authori ty to search and seize evidence including electronic data stored in electronic devices. Further, wherever required, a certificate under Section 65B of the Indian Evidence Act 1872 was duly obtained to ensure the admissibility of electronic records." } }, "chunk_4": { "analysis_of_arguments": "The primary contention is that the videos were deliberately made private or deleted after attracting large viewership, suggesting intent to manipulate share prices. The purported creator of these channels counters that they run multiple YouTube platforms and that the content, while promotional, may not have been expressly intended to mislead viewers.", "cases_referred": [], "facts": "The share price of Sadhna Broadcast Limited (SBL) rose in tandem with YouTube videos promoting the scrip, which allegedly contained false and misleading information. An SCN was issued stating that Manish Mishra and certain connected persons uploaded these videos across multiple channels, leading to widespread viewership and a subsequent investigation by SEBI. During search-and-seizure operations, SEBI identified Mishra as the operator of five YouTube channels that promoted SBL with misleading claims. The evidence includes subscriber details, phone records, and laptop data seized from Mishra\u2019s premises.", "final_status": "Not specified in the excerpt", "formatted_summary": "The document discusses how YouTube videos were used to promote Sadhna Broadcast Limited\u2019s shares, allegedly with misleading statements to influence stock prices. SEBI\u2019s investigation traced these activities to Manish Mishra, who managed multiple channels and was linked to phone numbers, email accounts, and device records showing control over the videos. The material concludes that these actions were designed to manipulate the share price of SBL.", "held": "It is found that the YouTube videos contained false and misleading claims aimed at artificially inflating the share price of SBL, and Manish Mishra was identified as the individual operating the channels in question.", "latin_principles": {}, "legal_issues": "Whether the conduct of creating and uploading promotional YouTube videos with misleading statements about the scrip of SBL constitutes manipulative activities and who can be held responsible for these acts.", "statutes": {} }, "chunk_5": { "analysis_of_arguments": "The primary contention is that Manish Mishra and Vivek Chauhan collaborated to produce and distribute promotional videos regarding SBL, potentially influencing public opinion or share prices. Their defense appears to revolve around the nature and purpose of these videos, as well as their actual intent.", "cases_referred": [], "facts": "A search and seizure operation was conducted by SEBI at the premises of Manish Mishra, during which various devices were seized. Analysis of these devices revealed that Manish Mishra operated multiple YouTube channels\u2014Moneywise, The Advisor, India Bullish, Profit Yatra, and Midcap Calls\u2014that published videos promoting Sadhna Broadcast Limited (SBL). WhatsApp chats indicated that Vivek Chauhan assisted in creating and uploading these promotional videos and managing related advertising. These videos amassed significant viewership and formed the basis for the present action reflected in the final order.", "final_status": "Disposed through a final order.", "formatted_summary": "This segment of the final order outlines the investigation into the operation of multiple YouTube channels by Manish Mishra that posted widely viewed promotional content for Sadhna Broadcast Limited. WhatsApp communications suggest coordination between Manish Mishra and Vivek Chauhan in producing and advertising these videos. A certificate under section 65B of the Indian Evidence Act, 1872, was obtained to substantiate the authenticity of the electronic evidence.", "held": "From the excerpt, the authority concluded that Manish Mishra operated multiple channels promoting SBL. However, the final determinations or sanctions imposed on the parties are not explicitly stated in this portion.", "latin_principles": {}, "legal_issues": "The central issues concern whether the creation and circulation of potentially misleading videos promoting SBL constituted manipulative conduct and if the parties involved engaged in practices that could have misled or influenced public investors.", "statutes": { "The Indian Evidence Act, 1872": "32. As stated earlier, during the Search-and-Seizure operations conducted by SEBI on the premises of Manish Mishra, his mobile devices and computers were seized. The data from the said devices were cloned and analyzed. It is noted from the records that certificate under section 65B of the Indian Evidence Act, 1872, was duly obtained in respect of the data cloned from the said devices." } }, "chunk_6": { "analysis_of_arguments": "The investigating authority contends that the parties involved uploaded misleading stock promotion videos and executed suspicious trades to boost SBL\u2019s share price. The respondents\u2019 positions are not detailed in this excerpt, though the cited chats and financial transactions imply awareness of manipulative market practices.", "cases_referred": [], "facts": "Several individuals, including Manish Mishra and Vivek Chauhan, allegedly created and promoted YouTube videos about Sadhna Broadcast Limited (SBL) using third-party identity documents. Substantial funds were transferred to Google AdSense from the accounts of Manish Mishra and others, suggesting a coordinated effort to influence SBL\u2019s share price. The company\u2019s stock had relatively low trading volumes but experienced suspicious upward price movement. WhatsApp chats and bank records were collected as evidence, indicating that these individuals acted in concert with others, including certain promoters of SBL, to manipulate the market. No information on earlier legal proceedings or court decisions is provided within this excerpt.", "final_status": "No final decision is provided in the excerpt.", "formatted_summary": "The document details how certain individuals were involved in uploading deceptive promotional videos for SBL, transferring funds to Google AdSense, and coordinating transactions to manipulate the company\u2019s share price. Various WhatsApp chats, bank transfers, and evidence of collaboration between promoters and alleged perpetrators are recorded, but no final judgment is presented in the provided text.", "held": "No court determination or conclusion is included in the excerpt.", "latin_principles": {}, "legal_issues": "Whether the alleged YouTube promotions and structured trades by specific individuals violated securities regulations by artificially inflating the share price of SBL.", "statutes": {} }, "chunk_7": { "analysis_of_arguments": "Regulators assert that the rapid increase in share volume and price stemmed from manipulative practices among interconnected parties. The implicated parties contend that the transactions resulted from normal trading activity. The focus is on whether the concentrated ordering and matching of trades point to artificial price inflation.", "cases_referred": [], "facts": "On February 25, 2022, a WhatsApp exchange between Subhash Agarwal and Manish Mishra outlined proposed terms for selling shares of Sadhna Broadcast Limited (SBL). Shortly afterward, beginning March 8, 2022, trading volumes and the share price of SBL rose sharply. Entities allegedly connected with the company\u2019s promoters and other individuals executed numerous coordinated or \u2018structured\u2019 trades, sometimes matching orders precisely in both timing and price. These activities prompted regulatory scrutiny and led to the issuance of a show cause notice by the Securities and Exchange Board of India (SEBI). The excerpt reflects the final stage of these proceedings, detailing how various parties were involved in these transactions.", "final_status": "No final disposition stated in the excerpt.", "formatted_summary": "This section details the sharp rise in trading activity of Sadhna Broadcast Limited starting from early March 2022, following a WhatsApp discussion of proposed share sale terms. Multiple parties alleged to be connected carried out coordinated transactions, trading significant volumes and appearing to influence the share\u2019s price movement. SEBI\u2019s investigation led to a show cause notice questioning the legitimacy of these trades, culminating in a final order examining the extent of potential market manipulation.", "held": "No specific ruling is indicated in the provided portion of the document.", "latin_principles": {}, "legal_issues": "Whether certain trading patterns among connected entities constituted market manipulation and whether these coordinated trades violated securities regulations.", "statutes": {} }, "chunk_8": { "analysis_of_arguments": "The excerpt primarily sets out the regulatory perspective that certain connected individuals conducted trades to raise the stock price. There is no detailed rebuttal provided from the involved parties in the excerpt, but the SCN alleges that the trades induced unsuspecting investors to buy the shares at higher prices.", "cases_referred": [], "facts": "The excerpt describes how certain entities connected to Sadhna Broadcast Limited executed large and structured trades that allegedly inflated the share price. It outlines a chronological breakdown of trading patches, explains how some individuals were involved in significant buy and sell transactions, and notes the substantial increase in both price and volume of the scrip, coinciding with YouTube video uploads recommending purchase of the shares. The Show Cause Notice (SCN) highlighted these structured trades and associated parties. The price later fell sharply, suggesting that retail investors were left exposed after the connected entities offloaded shares at elevated prices.", "final_status": "Not provided in the excerpt.", "formatted_summary": "This portion of the final order analyzes trading data for Sadhna Broadcast Limited across three time periods (Patch 1, Patch 2, and Patch 3), highlighting entities allegedly acting in concert and using YouTube promotional videos to drive up trading interest and share price before offloading shares. The text notes a sharp price rise followed by a steep drop, with the SCN alleging manipulative conduct that harmed retail investors.", "held": "Not provided in the excerpt.", "latin_principles": {}, "legal_issues": "Whether the practices detailed constitute manipulative or fraudulent trading activity and if there was an unlawful scheme to artificially inflate and then offload shares, causing losses to the public.", "statutes": {} }, "chunk_9": { "analysis_of_arguments": "The text does not provide detailed arguments by the parties. It principally sets out the trading patterns, volume data, and promotional conduct attributed to the connected entities, indicating a suspected scheme to inflate and offload shares at higher prices.", "cases_referred": [], "facts": "This segment of the final order reviews trading activity and share price movements in the scrip of Sadhna Broadcast Limited across specified time periods (referred to as Patch 2 through Patch 5). During these phases, a group of interconnected entities collectively bought and sold significant volumes of shares, allegedly causing spikes and subsequent crashes in the share price. Promotional videos endorsing the scrip were uploaded on YouTube, which appeared to draw in retail investors. High-volume offloading by the connected entities then occurred at elevated prices, leaving many public investors vulnerable. The data presented records the dates, trading volumes, and price fluctuations, reflecting the sequence of trading that led to suspicion of manipulative practices. No specific lower court decisions or appeals are referenced in this excerpt.", "final_status": "No final status described in the provided excerpt.", "formatted_summary": "In this section of the final order concerning Sadhna Broadcast Limited, the document details how certain connected entities allegedly orchestrated large-volume share transactions and posted promotional YouTube videos to influence the stock\u0027s price and attract retail investors. This resulted in multiple phases of price surges followed by crashes as the stock was systematically offloaded at higher prices. The data tables outline the key players, their trading volumes, and the overall market impact during different time intervals.", "held": "No specific holding or outcome is stated in the excerpt. It merely illustrates the alleged trading patterns and their effect on the market and investors.", "latin_principles": {}, "legal_issues": "Whether the connected entities manipulated the scrip\u2019s market price and volume through concerted trading and promotional activities, inducing public investors to purchase shares at inflated prices.", "statutes": {} } }, "counsels": [], "delivered_date": null, "facts": "Sadhna Broadcast Limited (SBL), incorporated in 1994 and listed on the BSE in January 2018, became the subject of multiple complaints alleging share price manipulation through misleading promotional videos on YouTube. From March 8, 2022 to November 30, 2022, the Securities and Exchange Board of India (SEBI) conducted an in-depth investigation, identifying promoters and connected entities who allegedly coordinated trades to inflate the scrip\u2019s price and offload shares at higher rates. SEBI issued an interim order on March 2, 2023, followed by a show cause notice sent to 64 entities. Search-and-seizure operations revealed evidence including YouTube channel content, WhatsApp chats, and bank records that pointed to a pump-and-dump arrangement. Several Noticees appeared at scheduled hearings or sought relief via writ petitions in various High Courts, but no court-ordered stay prevented SEBI from finalizing the proceedings. The Securities Appellate Tribunal directed SEBI to conclude the investigation by May 31, 2025. A final order dated May 29, 2025 was ultimately passed, detailing the roles of various Noticees, finding that certain connected parties orchestrated structured trades and disseminated misleading YouTube videos to attract retail investors, then disposed of their holdings at artificially inflated prices.", "final_status": "Disposed by a final order dated May 29, 2025, imposing disgorgement, penalties, and restrictions on certain Noticees.", "first_party": [], "grouped_statutes": { "Indian Evidence Act, 1872": [ "13.5. Electronic Records \u2013 It is observed that certain Noticees vide their replies contested the admissibility of electronic records seized during the Search -and-Seizure operations . In this regard , I note that SEBI appointed an Investigating Authority under section 11C of the SEBI Act, 1992 to carry out an investigation in the matter. Subsequently, after obtaining due permission of the Competent Court, a Search -and-Seizure operation was carried out . The said order of the Competent Court granted authorisation to the Investigating Authority to search and seize evidence including electronic data stored in electronic devices. Further, wherever required, a certificate under Section 65B of the Indian Evidence Act 1872 was duly obtained to ensure the admissibility of electronic records.", "32. As stated earlier, during the Search-and-Seizure operations conducted by SEBI on the premises of Manish Mishra, his mobile devices and computers were seized. The data from the said devices were cloned and analyzed. It is noted from the records that certificate under section 65B of the Indian Evidence Act, 1872, was duly obtained in respect of the data cloned from the said devices." ], "Insolvency and Bankruptcy Code (IBC)": [ "Paragraph 277:\n\n\"277. In view of the pending CIRP proceedings against Varun Media Pvt. Ltd. (Noticee 8) and prevailing moratorium under Section 14 of the IBC, monetary penalty is not being imposed on Noticee 8 at this stage and the proceedings against the Company will be decided/ disposed of through a separate order by SEBI. However, direction for disgorgement shall be applicable against the said Noticee.\"" ], "PFUTP Regulations, 2003": [ "8. The SCN also detailed the linkages between the various entities based on common KYC attributes, call data records, fund transfers, common addresses, familial relationships, and trading behaviour. It was alleged that the 64 Noticees acted in concert and were part of a common fraudulent scheme in contravention of the provisions of the SEBI Act, 1992 and the SEBI (Prohibition of Fraudulent and Unfair Trade Practices Relating to Securities Market) Regulations, 2003 (\u201cPFUTP Regulations, 2003\u201d).", "183. In view of the above, I hold that Peeyush Agrawal (Noticee 25 ) and Lokesh Shah (Noticee 26) were part of the scheme to manipulate the price of the scrip of SBL and towards this end they were operating the accounts of Noticees 27 to 38. The shares of SBL held in the accounts of Noticees 27 to 38 were sold in a manner to support the manipulative scheme orchestrated by the promoters of SBL in collusion with Manish Mishra. Noticees 27 to 38, by allowing their accounts to be used in this manner, have violated the provisions of the PFUTP Regulations, as alleged in the SCN .", "258. The conduct of all the Noticees, other than Noticees 14, 48 , 59 and 64 , in manipulating the share price of SBL is in violation of the provisions of Sections 12A(a), (b) and (c) of the SEBI Act, 1992 read with Regulations 3(a), (b), (c), (d), 4(1) and 4(2)(a), (d) and (e) of the PFUTP Regulations, 2003. Additionally, Noticee 52 has violated the provisions of Regulations 4(2) (k) and (r) of the PFUTP Regulations, 2003.", "Paragraph 275:\n\n\"275. Such conduct strikes at the very heart of market integrity. It not only violates the provisions of the PFUTP Regulations, 2003, but also undermines investor trust in the fairness and transparency of the securities market.\"" ], "Securities and Exchange Board of India (Procedure for Holding Inquiry and Imposing Penalties) Rules, 1995": [ "259. The SCN has also contemplated directions under Sections 11(4A) and 11B(2) of the SEBI Act read with Rule 4 of Securities and Exchange Board of India (Procedure for Holding Inquiry and Imposing Penalties) Rules, 1995 (\u201cAdjudication Rules, 1995 \u201d) imposing monetary penalty as stated in Section 15HA of the SEBI Act in respect of all the Noticees.", "Paragraph 278 (same text as referenced under the SEBI Act, 1992, because it also cites Rule 5 of the Adjudication Rules, 1995):\n\n\"278. In view of the aforesaid findings and having regard to the facts and circumstances of the matter, I, in exercise of the powers conferred upon me under Section 19 read with Sections 11(1), 11(4), 11(4A) and 11B read with Section 15I of the SEBI Act and Rule 5 of the Adjudication Rules, 1995, hereby direct as under: \n\na. Noticees 1, 2, 21, 25, 26, 39 and 52 are restrained from accessing the securities market and further prohibited from buying, selling or otherwise dealing in securities, directly or indirectly, or being associated with the securities market in any manner, whatsoever, for a period of five (5) years from the date of this Order. \n\nb. Noticees 3, 4-7, 9-13, 15-20, 22-24, 27-38, 40-47, 49-51, 53-58 and 60-63 are restrained from accessing the securities market and further prohibited from buying, selling or otherwise dealing in securities, directly or indirectly, or being associated with the securities market in any manner, whatsoever, for a period of one (1) year from the date of this Order. \n\nc. Noticees shall disgorge the amounts mentioned against their respective names in the Table under Para 255 above, along with simple interest at the rate of 12% per annum, calculated from the end of the Investigation Period till the date of actual payment. \n\nd. The amount mentioned in paragraph 278(c) shall be remitted by the aforementioned Noticees to the Investor Protection and Education Fund (IPEF) referred to in Section 11(5) of the SEBI Act, within 45 (forty\u2013five) days from the date of receipt of this Order. An intimation regarding the payment of said disgorgement amount directed to be paid herein, shall be sent to \u201cThe Division Chief, ISD-SEC 5, SEBI, SEBI Bhavan II, Plot no. C-7, \u2018G\u2019 Block, Bandra Kurla Complex, Bandra (E), Mumbai \u2013400 051\u201d. \n\ne. The following Noticees are hereby imposed with a monetary penalty under Section 15HA of the SEBI Act, as indicated in the Table below: \nNoticee No. | Name of the Noticee | Penalty\n1. | Gaurav Gupta | 2,00,00,000\n2. | Rakesh Kumar Gupta | 2,00,00,000\n3. | Shreya Gupta | 25,00,000\n4. | Saurabh Gupta | 25,00,000\n5. | Arpan Gupta | 10,00,000\n6. | Sadhna Bio Oils Pvt. Ltd. | 25,00,000\n7. | Virtual Business Solution Pvt. Ltd. | 25,00,000\n8. | Varun Media Pvt Ltd | No penalty\n9. | Naman Broadcastings And Telecommunications Pvt Ltd | 25,00,000\"\n" ], "Securities and Exchange Board of India (Settlement Proceedings) Regulations 2018": [ "241. Ravindra Dahyabhai Patel (Noticee 59) submitted a settlement application under Securities and Exchange Board of India (Settlement Proceedings) Regulations 2018, and the proceedings initiated against Ravindra Dahyabhai Patel vide SCN dated January 9, 2024 were disposed of vide settlement order dated February 27, 2025. It is noted that in terms of Regulation 27 (2) of the Settlement Regulations, a settlement order issued by SEBI does not automatically conclude or affect other potential proceedings against Noticees related to the individual.", "241. Ravindra Dahyabhai Patel (Noticee 59) submitted a settlement application under Securities and Exchange Board of India (Settlement Proceedings) Regulations 2018, and the proceedings initiated against Ravindra Dahyabhai Patel vide SCN dated January 9, 2024 were disposed of vide settlement order dated February 27, 2025. It is noted that in terms of Regulation 27 (2) of the Settlement Regulations, a settlement order issued by SEBI does not automatically conclude or affect other potential proceedings against Noticees related to the individual." ], "Securities and Exchange Board of India Act, 1992": [ "FINAL ORDER Under Sections 11(1), 11(4) and 11B of the Securities and Exchange Board of India Act, 1992 in respect of the Noticees. Sadhna Broadcast Limited was incorporated in 1994 and listed on BSE in January 2018. SEBI received complaints regarding alleged price manipulation and misleading YouTube videos. Searches were conducted at certain premises, revealing connected sellers in SBL\u2019s shares. A show cause notice was consequently issued, citing Sections 11(1), 11(4), 11(4A), 11B(1), and 11B(2) of the SEBI Act, 1992, for alleged violations involving artificially inflating the scrip\u2019s price and offloading shares at elevated rates.", "5. SEBI conducted a detailed investigation into the alleged manipulation in the scrip of SBL for the period from March 8, 2022 to November 30, 2022 (Investigation Period /IP). Based on the findings of the investigation, a show cause notice (SCN) was issued to 64 entities calling upon them to show cause as to why suitable directions under Sections 11(1), 11(4), 11(4A), 11B(1) and 11B(2) of the SEBI Act, 1992 should not be issued against them for the violations alleged therein.", "13.5. Electronic Records \u2013 It is observed that certain Noticees vide their replies contested the admissibility of electronic records seized during the Search -and-Seizure operations . In this regard, I note that SEBI appointed an Investigating Authority under section 11C of the SEBI Act, 1992 to carry out an investigation in the matter. Subsequently, after obtaining due permission of the Competent Court, a Search -and-Seizure operation was carried out. The said order of the Competent Court granted authorisation to the Investigating Authority to search and seize evidence including electronic data stored in electronic devices. Further, wherever required, a certificate under Section 65B of the Indian Evidence Act 1872 was duly obtained to ensure the admissibility of electronic records.", "258. The conduct of all the Noticees, other than Noticees 14, 48 , 59 and 64 , in manipulating the share price of SBL is in violation of the provisions of Sections 12A(a), (b) and (c) of the SEBI Act, 1992 read with Regulations 3(a), (b), (c), (d), 4(1) and 4(2)(a), (d) and (e) of the PFUTP Regulations, 2003. Additionally, Noticee 52 has violated the provisions of Regulations 4(2) (k) and (r) of the PFUTP Regulations, 2003.", "Paragraph 101:\n\n\"Explanation. \u2014For the removal of doubts, it is clarified that the power to adjudge the quantum of penalty under sections 15A to 15E, clauses (b) and (c) of section 15F, 15G, 15H and 15HA shall be and shall always be deemed to have been exercised under the provisions of this section.\u201d\n\nParagraph 263:\n\n\"263. Additionally, reference is made to the case of Adjudicating Officer, SEBI V. Bhavesh Pabari, 2 whereby the Supreme Court had held, \u201c...if the penalty provisions are to be understood as not admitting of any exception or discretion and the penalty as prescribed in Section 15\u2011A to Section 15\u2011HA of the SEBI Act is to be mandatorily imposed in case of default/failure, Section 15\u2011J of the SEBI Act would stand obliterated and eclipsed. Hence, the question referred. Sections 15\u2011A(a) to 15\u2011HA have to be read along with Section 15\u2011J in a manner to avoid any inconsistency or repugnancy.\u201d\"\n\nParagraph 278:\n\n\"278. In view of the aforesaid findings and having regard to the facts and circumstances of the matter, I, in exercise of the powers conferred upon me under Section 19 read with Sections 11(1), 11(4), 11(4A) and 11B read with Section 15I of the SEBI Act and Rule 5 of the Adjudication Rules, 1995, hereby direct as under: \n\na. Noticees 1, 2, 21, 25, 26, 39 and 52 are restrained from accessing the securities market and further prohibited from buying, selling or otherwise dealing in securities, directly or indirectly, or being associated with the securities market in any manner, whatsoever, for a period of five (5) years from the date of this Order. \n\nb. Noticees 3, 4-7, 9-13, 15-20, 22-24, 27-38, 40-47, 49-51, 53-58 and 60-63 are restrained from accessing the securities market and further prohibited from buying, selling or otherwise dealing in securities, directly or indirectly, or being associated with the securities market in any manner, whatsoever, for a period of one (1) year from the date of this Order. \n\nc. Noticees shall disgorge the amounts mentioned against their respective names in the Table under Para 255 above, along with simple interest at the rate of 12% per annum, calculated from the end of the Investigation Period till the date of actual payment. \n\nd. The amount mentioned in paragraph 278(c) shall be remitted by the aforementioned Noticees to the Investor Protection and Education Fund (IPEF) referred to in Section 11(5) of the SEBI Act, within 45 (forty\u2013five) days from the date of receipt of this Order. An intimation regarding the payment of said disgorgement amount directed to be paid herein, shall be sent to \u201cThe Division Chief, ISD-SEC 5, SEBI, SEBI Bhavan II, Plot no. C-7, \u2018G\u2019 Block, Bandra Kurla Complex, Bandra (E), Mumbai \u2013400 051\u201d. \n\ne. The following Noticees are hereby imposed with a monetary penalty under Section 15HA of the SEBI Act, as indicated in the Table below: \nNoticee No. | Name of the Noticee | Penalty\n1. | Gaurav Gupta | 2,00,00,000\n2. | Rakesh Kumar Gupta | 2,00,00,000\n3. | Shreya Gupta | 25,00,000\n4. | Saurabh Gupta | 25,00,000\n5. | Arpan Gupta | 10,00,000\n6. | Sadhna Bio Oils Pvt. Ltd. | 25,00,000\n7. | Virtual Business Solution Pvt. Ltd. | 25,00,000\n8. | Varun Media Pvt Ltd | No penalty\n9. | Naman Broadcastings And Telecommunications Pvt Ltd | 25,00,000\"", "(d) The amount mentioned in paragraph 278(c) shall be remitted by the aforementioned Noticees to the Investor Protection and Education Fund (IPEF) referred to in Section 11(5) of the SEBI Act, within 45 (forty\u2013five) days from the date of receipt of this Order. An intimation regarding the payment of said disgorgement amount directed to be paid herein, shall be sent to \u0027The Division Chief, ISD-SEC 5, SEBI, SEBI Bhavan II, Plot no. C-7, \u0027G\u0027 Block, Bandra Kurla Complex, Bandra (E), Mumbai \u2013400 051\u0027.", "e. The following Noticees are hereby imposed with a monetary penalty under Section 15HA of the SEBI Act, as indicated in the Table below: Noticee No. Name of the Noticee Penalty 1. Gaurav Gupta 2,00,00,000 2. Rakesh Kumar Gupta 2,00,00,000 3. Shreya Gupta 25,00,000 4. Saurabh Gupta 25,00,000 5. Arpan Gupta 10,00,000 6. Sadhna Bio Oils Pvt. Ltd. 25,00,000 7. Virtual Business Solution Pvt. Ltd. 25,00,000 8. Varun Media Pvt Ltd No penalty 9. Naman Broadcastings And Telecommunications Pvt Ltd 25,00,000" ] }, "held": "SEBI concluded that promoters and multiple connected Noticees engaged in misleading promotions and structured trades to inflate SBL\u2019s share price, thereby violating securities regulations. The final order imposed liability for unlawful gains, monetary penalties, and temporary bars on entering the securities market. Certain individuals were spared adverse findings where the evidence was insufficient or they settled separately. The decision underscores strict enforcement against market manipulation and clarifies that those found to have conspired are jointly and severally accountable for illicit profits.", "latin_principles": {}, "legal_issues": [ "Whether certain promoters, connected entities, and individuals orchestrated a coordinated plan to inflate SBL\u2019s share price via misleading media and trades", "Whether the promotional videos and structured selling activity constituted fraudulent and unfair trade practices", "Whether procedural objections on document inspection, cross-examination, and electronic evidence affected the legality of the proceedings", "Whether the overlapping accounts, fund transfers, and high-volume trades confirmed a concerted attempt to manipulate share price and volume." ], "prayer": "", "reserved_date": null, "second_party": [], "statutes": { "Indian Evidence Act, 1872": "13.5. Electronic Records \u2013 It is observed that certain Noticees vide their replies contested the admissibility of electronic records seized during the Search-and-Seizure operations. In this regard, I note that SEBI appointed an Investigating Authority under section 11C of the SEBI Act, 1992 to carry out an investigation in the matter. Subsequently, after obtaining due permission of the Competent Court, a Search-and-Seizure operation was carried out. The said order of the Competent Court granted authorisation to the Investigating Authority to search and seize evidence including electronic data stored in electronic devices. Further, wherever required, a certificate under Section 65B of the Indian Evidence Act 1872 was duly obtained to ensure the admissibility of electronic records.", "Insolvency and Bankruptcy Code (IBC)": "Paragraph 277: In view of the pending CIRP proceedings against Varun Media Pvt. Ltd. (Noticee 8) and prevailing moratorium under Section 14 of the IBC, monetary penalty is not being imposed on Noticee 8 at this stage and the proceedings against the Company will be decided through a separate order by SEBI. However, direction for disgorgement shall be applicable against the said Noticee.", "PFUTP Regulations, 2003": "8. The SCN also detailed the linkages between the various entities based on common KYC attributes, call data records, fund transfers, common addresses, familial relationships, and trading behaviour. It was alleged that the 64 Noticees acted in concert and were part of a common fraudulent scheme in contravention of the provisions of the SEBI Act, 1992 and the SEBI (Prohibition of Fraudulent and Unfair Trade Practices Relating to Securities Market) Regulations, 2003 (\u201cPFUTP Regulations, 2003\u201d).\n\n183. In view of the above, I hold that Peeyush Agrawal (Noticee 25) and Lokesh Shah (Noticee 26) were part of the scheme to manipulate the price of the scrip of SBL and towards this end they were operating the accounts of Noticees 27 to 38. The shares of SBL held in the accounts of Noticees 27 to 38 were sold in a manner to support the manipulative scheme orchestrated by the promoters of SBL in collusion with Manish Mishra. Noticees 27 to 38, by allowing their accounts to be used in this manner, have violated the provisions of the PFUTP Regulations, as alleged in the SCN.\n\nParagraph 275: Such conduct strikes at the very heart of market integrity. It not only violates the provisions of the PFUTP Regulations, 2003, but also undermines investor trust in the fairness and transparency of the securities market.", "Securities and Exchange Board of India (Procedure for Holding Inquiry and Imposing Penalties) Rules, 1995": "Paragraph 278: In view of the aforesaid findings and having regard to the facts and circumstances of the matter, I, in exercise of the powers conferred upon me under Section 19 read with Sections 11(1), 11(4), 11(4A) and 11B read with Section 15I of the SEBI Act and Rule 5 of the Adjudication Rules, 1995, hereby direct as under: (a) Noticees 1, 2, 21, 25, 26, 39 and 52 are restrained\u2026 (b) Noticees 3,4-7,9-13,15-20, 22-24, 27-38, 40-47, 49-51, 53-58 and 60-63 are restrained\u2026 (c) Noticees shall disgorge\u2026 (d) The amount shall be remitted\u2026 (e) The following Noticees are hereby imposed with a monetary penalty under Section 15HA of the SEBI Act\u2026", "Securities and Exchange Board of India (Settlement Proceedings) Regulations 2018": "241. Ravindra Dahyabhai Patel (Noticee 59) submitted a settlement application under Securities and Exchange Board of India (Settlement Proceedings) Regulations 2018, and the proceedings initiated against Ravindra Dahyabhai Patel vide SCN dated January 9, 2024 were disposed of vide settlement order dated February 27, 2025. It is noted that in terms of Regulation 27(2) of the Settlement Regulations, a settlement order issued by SEBI does not automatically conclude or affect other potential proceedings against Noticees related to the individual.", "Securities and Exchange Board of India Act, 1992": "FINAL ORDER Under Sections 11(1), 11(4) and 11B of the Securities and Exchange Board of India Act, 1992 in respect of the Noticees. Sadhna Broadcast Limited was incorporated in 1994 and listed on BSE in January 2018. SEBI received complaints regarding alleged price manipulation and misleading YouTube videos. Searches were conducted at certain premises, revealing connected sellers in SBL\u2019s shares. A show cause notice was consequently issued, citing Sections 11(1), 11(4), 11(4A), 11B(1), and 11B(2) of the SEBI Act, 1992, for alleged violations involving artificially inflating the scrip\u2019s price and offloading shares at elevated rates.\n\n5. SEBI conducted a detailed investigation into the alleged manipulation in the scrip of SBL for the period from March 8, 2022 to November 30, 2022 (Investigation Period /IP). Based on the findings of the investigation, a show cause notice (SCN) was issued to 64 entities calling upon them to show cause as to why suitable directions under Sections 11(1), 11(4), 11(4A), 11B(1) and 11B(2) of the SEBI Act, 1992 should not be issued against them for the violations alleged therein.\n\n13.5. Electronic Records \u2013 It is observed that certain Noticees vide their replies contested the admissibility of electronic records seized during the Search-and-Seizure operations. In this regard, I note that SEBI appointed an Investigating Authority under section 11C of the SEBI Act, 1992 to carry out an investigation in the matter. Subsequently, after obtaining due permission of the Competent Court, a Search-and-Seizure operation was carried out. The said order of the Competent Court granted authorisation to the Investigating Authority to search and seize evidence including electronic data stored in electronic devices. Further, wherever required, a certificate under Section 65B of the Indian Evidence Act 1872 was duly obtained to ensure the admissibility of electronic records.\n\nParagraph 263: Additionally, reference is made to the case of Adjudicating Officer, SEBI V. Bhavesh Pabari, 2 whereby the Supreme Court had held, \u201c\u2026if the penalty provisions are to be understood as not admitting of any exception or discretion and the penalty as prescribed in Section 15A to 15E, clauses (b) and (c) of section 15F, 15G, 15H and 15HA of the SEBI Act is to be mandatorily imposed in case of default/failure, Section 15J of the SEBI Act would stand obliterated\u2026\u201d\n\nParagraph 278: In view of the aforesaid findings and having regard to the facts and circumstances of the matter, I, in exercise of the powers conferred upon me under Section 19 read with Sections 11(1), 11(4), 11(4A) and 11B read with Section 15I of the SEBI Act and Rule 5 of the Adjudication Rules, 1995, hereby direct as under: (a) Noticees 1, 2, 21, 25, 26, 39 and 52 are restrained from accessing the securities market\u2026 (b) Noticees 3, 4-7, 9-13, 15-20, 22-24, 27-38, 40-47, 49-51, 53-58 and 60-63 are restrained\u2026 (c) Noticees shall disgorge\u2026 (d) The amount mentioned\u2026 (e) The following Noticees are hereby imposed with a monetary penalty under Section 15HA of the SEBI Act\u2026" }, "statutes_headnotes": { "Indian Evidence Act, 1872": "\u2014 Admissibility of Electronic Records \u2014 Noticees objected to electronic data seized under lawful Search-and-Seizure \u2014 Investigating Authority obtained Section 65B certificates \u2014 Compliance ensured admissibility of cloned data \u2014 Objections overruled.", "Insolvency and Bankruptcy Code (IBC)": "\u2014 Pending CIRP under Section 14 \u2014 Moratorium prevents immediate monetary penalty on Noticee 8 \u2014 SEBI to issue separate order \u2014 Disgorgement direction remains enforceable.", "PFUTP Regulations, 2003": "\u2014 Market Manipulation and Fraud \u2014 Pump-and-Dump Scheme \u2014 Noticees orchestrated misleading promotions and synchronized trades to inflate share price \u2014 Collusion established through common KYC data, call records, familial ties \u2014 Violations of Sections 12A(a), (b), (c) of SEBI Act and Regulations 3(a), (b), (c), (d), 4(1), 4(2)(a), (d), (e), (k), (r) of PFUTP \u2014 Disgorgement, monetary penalties, and market restrictions imposed; some Noticees received relief due to lack of evidence or settlement.", "Securities and Exchange Board of India (Procedure for Holding Inquiry and Imposing Penalties) Rules, 1995": "\u2014 Adjudication Proceedings \u2014 Show Cause Notice under Rule 4 and Rule 5 for alleged pump-and-dump in Sadhna Broadcast Limited \u2014 Directions invoked under Sections 11(4A), 11B(2) of SEBI Act, penalty under Section 15HA \u2014 Final Order restraining Noticees from market access, directing disgorgement with interest, and imposing penalties \u2014 Procedural objections on document inspection and cross-examination deemed non-fatal.", "Securities and Exchange Board of India (Settlement Proceedings) Regulations 2018": "\u2014 Settlement Application \u2014 Noticee 59\u2019s application disposed of under SCN \u2014 Under Regulation 27(2), Settlement Order does not preclude further proceedings against other Noticees \u2014 SEBI retains authority to initiate additional action if warranted.", "Securities and Exchange Board of India Act, 1992": "\u2014 Price Manipulation \u2014 Pump-and-Dump Scheme \u2014 Promoters and connected entities disseminated misleading YouTube videos, engaged in structured trades \u2014 Violations of Sections 12A(a), (b), (c) \u2014 Valid Search-and-Seizure operations and Section 65B certification upheld electronic evidence \u2014 Market bar and disgorgement with interest enforced under Sections 11(1), 11(4), 11B, and Section 15HA \u2014 Supreme Court ruling in Bhavesh Pabari applied on penalty discretion \u2014 Certain Noticees granted partial relief for insufficient proof." } }, "summary": { "formatted_summary": "Multiple notices were issued to promoters, associates, and other individuals linked to Sadhna Broadcast Limited for allegedly orchestrating a pump-and-dump scheme involving misleading YouTube promotions and structured trades. The investigation revealed that certain noticees collaborated to inflate the share price and offload shares at elevated values, attracting unsuspecting investors. Writ petitions and appeals were filed, but there was no judicial stay preventing SEBI from finalizing its action. The final order imposed market access restrictions, disgorgement with interest, and monetary penalties on most implicated noticees. Several individuals received limited relief due to settlement agreements or insufficient evidence of involvement, reflecting a strong regulatory stance on preventing manipulative market practices." } }