PFUTP violations can be inferred from coordinated trading patterns and far-away prices, supporting broker liability.

Repeated large orders placed at prices materially away from the prevailing market price, together with coordinated trading and awareness of the impending client order, were treated as sufficient to indicate manipulative intent under the PFUTP framework. Direct evidence was not required; the regulator and tribunal could rely on the totality of circumstances to assess whether the trading pattern created a false market impression and artificial depth. A broker may be held responsible where its conduct facilitates clients' manipulative trades and falls short of the required standards of integrity, care, and diligence. The suspension order was upheld and the appeal was dismissed.

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Issues: Whether the suspension of the stock broker's certificate was warranted for engaging in cross deals and synchronised trading at prices far away from the prevailing market price, thereby creating artificial depth and violating the PFUTP Regulations and the Code of Conduct.

Analysis: Repeated orders were placed in substantial quantities at prices materially different from the last traded price. Even where some orders did not fructify, the pattern of placing such orders could still create a false impression in the market. The broker's involvement in the clients' trades, the admitted awareness of the impending UTI order, and the coordinated trading pattern were relevant in assessing manipulative intent. In determining PFUTP violations, direct evidence is not indispensable and the totality of the circumstances may be relied upon. A broker can be held liable where its conduct enables or facilitates the manipulative trades of its clients and falls short of the required standards of integrity, care, and diligence.

Conclusion: The suspension order was upheld. The appeal was dismissed.

Ratio Decidendi: PFUTP violations may be established from the totality of circumstances, including repeated large orders at far away prices and coordinated trading patterns, and a broker may be held responsible where it facilitates such manipulative conduct by its clients.

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