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2025 (8) TMI 813
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.... InterGlobe Aviation Limited ........66 F.4 Illustration of Recommendation on ZEE Business news channel- Steel Authority of India Limited (SAIL) .....................75 F.5 Illustration of Recommendation on ZEE Business news channel- GODREJCP..............89 G. OTHER TRADES INVOLVING SIMILAR MODUS OPERANDI .........................105 H. ROLE OF NOTICEES ............................108 I. PROFIT SHARING AMONGST NOTICEES ......................114 J. EXAMINATION OF VIOLATION OF PROVISIONS OF THE SEBI ACT AND REGULATIONS MADE THEREUNDER ..........................124 K. LIABILITY OF DIRECTORS/ADVISOR OF THE PROFIT MAKERS ........................138 L. NEED FOR INTERIM EX-PARTE ORDER ................................................140 M. JOINT AND SEVERAL LIABILITY OF NOTICEES ..............................143 N. INTERIM ORDER ......................................................................146 A. BACKGROUND 1. The present proceedings emanate from an investigation conducted by the Securities and Exchange Board of India (hereinafter referred to as "SEBI"), for the period from January 01, 2020 to June 12, 2024 (hereinafter referred to as "Relevant Period/Investigation P....
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....g Vihar, Atlas Chowk, Gurgram, Haryana- 122015. 2. Ashish Kapur (Noticee No. 3) Residence: House No. M-48, Grater Kailash Part 1, Greater Kailash, South Delhi, New Delhi- 110048. 3. RRB Master Securities Delhi Limited (Noticee No. 4) Office: H-72, Connaught Place, New Delhi- 110001. 4. Rajiv Kapoor (Noticee No. 5) Residence: J7/47, 2nd Floor, Rajouri Garden, West Delhi- 110027. 5. Jagat Singh (Noticee No. 6) Residence: 901, Tower 7, Sunshine County, Sonipat, Haryana- 131023. 4. Further, data from electronic devices pertaining to Lalit Bhasin was also obtained during the said operation. Apart from above entities, search & seizure order was also issued by Competent Court against an entity, who is not a Noticee in the instant Order, however, on the day of search & seizure, the entity was neither found at the residential location nor at the official location and hence the search warrant could not be executed. Nothing adverse has also been found against this entity at this stage. B. DETAILS OF NOTICEES INVOLVED IN THE MATTER Based on findings of investigation, details of Noticees involved in the matter are elaborated as under: 5. Guest Expert 5.1 Sanjiv Bhasin (Noticee....
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....s appearances on TV channels run by the Times Group viz. "ET Now" and "ET Now Swadesh" from October 2023 onwards. The Noticee No. 1 was given this contract on the basis of his experience with IIFL and his popularity among the retail investors (both Hindi and English Channel followers). 5.5 As discussed earlier, IIFL is registered with SEBI as a Research Analyst (hereinafter referred to as "RA") and Investment Advisor (hereinafter referred to as "IA"), however, the Noticee No. 1 was not registered with SEBI either as an IA or as an RA, in his personal capacity. Investigation revealed that the Noticee No. 1 was popular on social media platforms as per the details of the followers/subscribers of his various social media channels: Table 3 SR. NO. SOCIAL MEDIA PLATFORM FOLLOWER/SUBSCRIBERS AS ON MARCH 26, 2025 1. X (formerly Twitter) 3,21,000 Followers 2. You Tube channel (Wealth Creation India) 4,12,000 Subscribers 3. LinkedIn 21,000 Followers 6. Enablers (who may be beneficiary/profit maker) 6.1 RRB Master Securities Delhi Private Limited (RRB Master/Noticee No. 4) (CIN No. U74899DL1993PLC055382) is an unlisted company and a Trading Member registered with SEBI having....
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....t Ltd 2,719.80 51.58% 2 HB Stockholdings Limited 1,502.67 28.50% 3 Mars Forge Private Limited 170.09 3.23% 4 Gemini Portfolios Private Limited 120.27 2.28% 5 Leo Portfolios Private Limited 110.80 2.10% Total for F.Y. 2022-2023 4,623.64 87.69% F.Y 2023-2024 & Qtr. I of F.Y. 2024-25 4,877.33 1 Venus Portfolios Pvt Ltd 2,567.61 52.64% 2 HB Stockholdings Limited 1,634.19 33.51% 3 RRB Securities Ltd 167.53 3.43% 4 Rima Arora 132.21 2.71% 5 HB Portfolio Limited 90.43 1.85% Total for F.Y 2023-2024 & Qtr. I of F.Y 2024-2025 4,591.96 94.15% 6.5 On a perusal of the data in the above table, it is seen that even though the Noticee No. 4 had more than 100 clients in various Financial Years between 2020-2024, nearly 75% and above of the total turnover in the respective financial years had been generated from those clients of RRB Master, who were related/connected to directors/promoters of RRB Master, as shown in the succeeding paragraphs. During the investigation, it was revealed that Ashish Kapur being the MD of the Noticee No. 4 had authorized dealers of the Noticee No. 4 viz. Rajiv Kapoor (Noticee No. 5), Jagat Singh (Noticee No.....
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.... in the trading accounts of Venus, Gemini and HB Stockholdings, as per the instructions of Sanjiv Bhasin as received from time to time over phone calls/WhatsApp chats before the same recommendations were made public by Sanjiv Bhasin on Media Channels. Further, Noticee Nos. 5 and 6 being privy to the recommendations of trades of Sanjiv Bhasin, mirrored the same trades as done in accounts of Venus, Gemini and HB in their own accounts also. 7.2 During the investigation period, the Noticee No. 5 used to place the orders of clients of RRB Master through CTCL ID-110034002006 located at address "H-72, Connaught Circus New Delhi -110001, India" of RRB Master. Table 9 DEALER NAME SEGMENT CTCL ID ADDRESS OF RRB MASTER MO. EMAIL Rajiv Kapoor CM & FO 110034002006 H-72, Connaught Circus New Delhi -110001, India 981****406 ********@investshoppe.com 7.3 During the investigation period, the Noticee No. 6 used to place the orders of clients of RRB Master through CTCL ID-110034002002 located at address "A-2,3,4 Third Floor, HB Twin Tower, Netaji Subhash Place, Pitampura, New Delhi, 110034" of RRB Master. Table 10 DEALER NAME SEGMENT CTCL ID ADDRESS OF RRB MASTER MO. ....
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.... that there was a complex web of shareholding among connected entities and there was a cross shareholding among several connected entities (e.g. Venus, Gemini, Bhasin Investment, Aquarious etc.) to possibly obfuscate the identity as well as exact shareholding of the Ultimate Beneficial Owner. To calculate the ultimate shareholding of Venus held by various beneficiaries, three levels of shareholding structure were analysed. The details of the ultimate shareholding structure of Venus as on March 31, 2023 are as follows: Table 13 Shareholding analysis of Venus Portfolios Pvt Limited 1st Level (A) 2nd Level (B) Third Level (C) Final Shareholding (D = A*B*C) Final Shareholder Merry Gold Investments Limited 19.23% Lalit Bhasin 12.60% 2.42% Lalit Bhasin Jupiter Portfolios P Ltd.(Jupiter) 19.23% 19.23% Jupiter 30.77% Mamta Kapur 96.00% 29.53% Mamta Kapur Aquarious Portfolios P Ltd. (Aquarious) Bhasin Investments Ltd. 4.00% Sanjiv Bhasin 4.78% 0.06% Sanjiv Bhasin Lalit Bhasin 40.47% 0.50% Lalit Bhasin Bhasin Investments Ltd. 11.54% Sanjiv Bhasin 4.78% 0.55....
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....sp; 6.73% Jupiter Aquarious 30.76% Mamta Kapur 96.00% 10.34% Mamta Kapur Bhasin Investments Ltd. 4.00% Sanjiv Bhasin 4.78% 0.07% Sanjiv Bhasin Lalit Bhasin 40.47% 0.57% Lalit Bhasin Bhasin Investments Ltd. 11.53% Sanjiv Bhasin 4.78% 0.19% Sanjiv Bhasin Lalit Bhasin 40.47% 1.63% Lalit Bhasin Gemini Portfolios Pvt Limited 19.23% 6.73% Gemini Portfolios Pvt Limited Aquarious Portfolio P Ltd. 50% Mamta Kapur 96% 48.00% Mamta Kapur Bhasin Investments Ltd 4% Sanjiv Bhasin 4.78% 0.10% Sanjiv Bhasin Lalit Bhasin 40.47% 0.81% Lalit Bhasin RRB Securities Ltd. 15% Lalit Bhasin 48% 7.27% Lalit Bhasin Mamta Kapur 8.69% 1.30% Mamta Kapur 8.8 On a perusal of the above table, it is seen that Mamta Kapur held 59.64% share capital in Gemini through Venus, Aquarious and RRB Master. Sanjiv Bhasin held 0.36% share capital in Gemini through Venus and A....
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.... Kapur AJPPK9522R Non-Executive - Non Independent Director Nil 6 Urvija Shah - Non-Executive - Independent Director Nil 7 Yash Kumar Sehgal BDXPS4867A Non-Executive - Independent Director Nil 8 Mahesh Kumar Gupta - CFO Nil 9 Reema Miglani - Company Secretary & Compliance Officer Nil 8.12 The details of its shareholders are tabulated in the table below: Table 20 Sl. Name No. of shares % Shareholding as on March 31, 2024 1 Lalit Bhasin 36,78,691 51.54 2 Manasvin Arora 22,500 0.32 3 Kanishk Kapur 22,500 0.32 4 Ayush Kapur 22,500 0.32 5 Mehar Arora 22,500 0.32 6 H B Corporate Services Ltd 20,496 0.29 7 Merrygold Investments Ltd 9,148 0.13 8 Public 33,39,330 46.78 Total 100% 8.13 Upon perusal of the above tables, it can be seen that Lalit Bhasin held major shareholding in HB (51.54%) and was the Whole-time Director cum Promoter (sole Executive Director) in HB. During the statement recording under oath, Sanjiv Bhasin had stated that Lalit Bhasin had authorized him to place trades in accounts of Venus and Gemini, however, dealers of RRB Master may have used the account of HB for carrying out trades due to s....
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....ife Babita Gupta ("Noticee No. 12") and thereby made profit in the account of the Noticee No. 12. C. KEY EVIDENCES COLLECTED DURING THE INVESTIGATION AND SEARCH & SEIZURE 9. During the investigation and the search, seizure conducted at the premises of Noticees, following evidences have been collected: i. data contained in electronic devices seized during search and seizure operation; ii. Analysis of Client Application Forms ('CAF') provided by Telecom Service Providers ('TSP'); iii. Evidence of connection amongst Noticees based on the Call Data Records ('CDR') of Noticees before and after the recommendations made on Media Channels; iv. Analysis of KYC details, trading activities of entities, bank account statements and statements of the Noticees taken under oath; v. Analysis of recorded videos and data of recommendation provided by News channels viz. 'CNBC Awaaz', 'CNBC English' 'ET Now', 'ET Now Swadesh' and 'Zee Business' vi. Analysis of recommendation data on IIFL's Telegram Channel; vii. Analysis of relevant material available on Ministry of Corporate Affairs (MCA) website regarding the Noticee companies; viii. Data provided by RRB Master; and ix. Contents o....
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....his instructions. 14. Lalit Bhasin managed the day to day affairs/management of Venus and Gemini directly/indirectly, being associated with them in the capacity of an Advisor. Lalit Bhasin was the Executive Director cum Promoter of HB during the investigation period, having 51.54% shareholding. Ashish Kapur, brother-in-law of Lalit Bhasin, was also connected with HB in the capacity of being a Non-Executive Non-Independent Director. Further, it has been seen that Lalit Bhasin was one of the authorized signatories for operating the bank account of HB. Moreover, as per the data received from RRB Master, it has been observed that Lalit Bhasin was one of the authorized signatories for placing orders for HB, with RRB Master, during the investigation period. 15. In the statement recorded by Investigating Authority on oath, Sanjiv Bhasin had categorically stated that Lalit Bhasin had authorised him to place buy/sell orders/trades in the trading accounts of Venus and Gemini through the dealers of RRB Master viz. Rajiv Kapoor, Jagat Singh, etc. thereby establishing prima facie connection between them. He further stated that dealers of RRB Master may have used the account of HB for carrying....
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....on between entities and it can also be seen that the Noticee No. 3 was aware about orders being placed by dealers of RRB Master, viz. Noticee Nos. 5 and 6 in trading accounts of Venus, Gemini and HB, on instructions of the Noticee No. 1. Inference: On Dec 07, 2023, Jagat informed Ashish that he will not attend the office due to fever for which Ashish informed Jagat to message about his absence to Sanjiv Bhasin. In reply, Jagat has informed that he will message Sanjiv Bhasin about his absence and also inform ******** (Dealer 2), another dealer of RRB, to reach office early to coordinate with Sanjiv Bhasin for his trade. This interaction reveals that, Ashish was aware of Sanjiv Bhasin trading through RRB Master. Similar types of chat were observed between Ashish and Jagat, which are as follows: Text in the image Jagat Singh -2,50,000 JP Power bought @ 14.17 Caught in high fever Will not be able to attend office Ashish Kapoor - Oh ok get Well soon Inform Sanjiv Ji Jagat Singh - Will message to Sanjiv Ji and *****(Dealer 2) to reach on time Ashish Kapoor -How r u feeling Jaggu? Date: Feb 01, 2024 Inference: On Feb 01, 2024, Jagat informed Ashish that he would not be ....
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....hannels for giving stock recommendations, took positions (majorly buy) in Venus, Gemini and HB through Jagat Singh and Rajiv Kapoor, dealers of RRB Master. Subsequently, he would recommend certain scrips in Media Channels (majorly buy) which would include those scrips in which he would have already taken position (majorly buy), through the dealers of RRB Master. Thereupon, his recommendations on the Media Channels used to create huge impact on the price/volume of the scrip, owing to his large viewership/following on various social media platforms and wider dissemination of information through Media channels/Telegram. 21. Once his recommendations would have created substantial impact on the price/volume of the recommended scrip in the market (as would be discussed later in the succeeding paragraphs in Part F of this Order), he used to instruct dealers of RRB Master to carry out trades (majorly sell) opposite to his own majorly buy recommendations in Media Channels earlier. 22. The important thing to note here in the alleged scheme is that all through this while, Sanjiv Bhasin would constantly remain in touch with dealers of RRB Master for immediate compliance of his directions and....
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....anjiv Bhasin on the business TV Channels. 27. By virtue of mapping of clients, namely Venus, Gemini and HB with all dealers of RRB Master namely Rajiv, Jagat and Ashish Kapur, they became privy to trades being carried out by Sanjiv Bhasin in accounts of Venus, Gemini and HB. Thus, such non-public information allowed Rajiv, Jagat and Ashish to carry out similar trades in their respective account and made profit. The mapping of entities with dealers of RRB Master is shown below: Table 24 Sr. No. Dealer name Client Name Period 1 Ashish Kapur Babita Gupta 23/11/2020-21/10/2023 Leo Portfolios Private Limited 23/11/2020-21/10/2023 2 Dealer 1 Babita Gupta 01/01/2020-20/02/2024 Gemini Portfolios Private Limited 01/01/2020-20/02/2024 HB Stockholdings Limited 01/01/2020-20/02/2024 Leo Portfolios Private Limited 01/01/2020-18/12/2023 Venus Portfolios Pvt. Ltd 01/01/2020-20/02/2024 3 Jagat K Singh Ashish Kapur / HUF 01/01/2020-22/12/2023 Babita Gupta 01/01/2020-28/08/2024 Gemini Portfolios Private Limited 01/01/2020-28/08/2024 HB Stockholdings Limited 01/01/2020-28/08/2024 Leo Portfolios Private Limited 01/01/2020-18/12/2023 Venus Portfolios Pvt. ....
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.... 30. During the investigation period, Noticees cumulatively carried out 39,971 trades on both exchanges. Out of the total trades, 39489 trades (98.79%) were carried out on NSE and mere 482 trades (1.21%) were carried out on BSE, hence trade data obtained from NSE has only been considered for the purpose of examination of trades and calculation of ill-gotten gain. 31. The segment wise trades carried out on NSE by Noticees are provided in the table below: Table 26 Details of segment wise number of scrip days of Noticees on Exchange (NSE) CLIENT NAME CASH SEGMENT STOCK FUTURES STOCK OPTIONS INDEX FUTURES INDEX OPTIONS GRAND TOTAL Gemini Portfolio Pvt. Ltd 266 1812 158 23 137 2396 HB Stockholdings Ltd 2152 3726 90 114 182 6264 Venus Portfolios Pvt. Ltd 125 6959 151 347 77 7659 Sub-Total (A) 2543 12497 399 484 396 16319 Leo Portfolios Pvt. ltd 1469 3056 2415 119 3104 10163 Ashish Kapur 1200 1897 265 48 1578 4988 Rajiv Kapoor 137 1648 0 3 19 1807 Jagat Singh 402 2633 1082 10 132 4259 Babita Gupta 579 1020 59 70 225 1953 Sub-Total (B) 3787 ....
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.... 0.10% Volume Impact Post Recommendation Avg Trading vol in preceding 15 mins [t-15] (number of shares/underlying shares) 1350 687 17 Avg Trading Vol during recommendation time and succeeding 2 mins [t and t+2] (number of shares/underlying shares) 12467 7302 229 Avg Trading Vol for succeeding 15 mins [t+15] (number of shares/underlying shares) 4250 2674 114 Relevant Price Sensitive Corporate Announcement on the day of the recommendation or the prior day No 36. The analysis of the price impact in the LTTS scrip shows the following: i. In the preceding 15 minutes before the recommendation, the average high/low price variation was relatively low at 0.04%, 0.08%, 0.04% for LTTS scrip at BSE (EQ), NSE (EQ) and NSE (Future) respectively. ii. However, during the recommendation time and the subsequent 2 minutes (t and t+2), there was a significant surge in price volatility, with an average high/low variation of 0.15%, 0.22% and 0.26% for LTTS scrip at BSE (EQ), NSE (EQ) and NSE (Future) respectively. iii. In the succeeding 15 minutes (t+15) after the recommendation, the average high/low variation stood at 0.10%, 0.14%, 0.11% for LTTS scrip at BSE (EQ), NSE (EQ) and N....
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....Buy LTTS Fourth Call 12:47 PM Buy LTTS Fifth Call 12:50 PM Buy LTTS Recommendation on ZEE Business TV Channel at 13:33 Sixth Call 13:36 Sell LTTS 39.3 The detailed transcript of first conversation exchanged between Sanjiv Bhasin and Rajiv Kapoor for the said instance at 09:55 AM is as under: "Sanjiv Bhasin - Rajiv LTTS Dekhiyo Rajiv - 5650 - 5610.............. ................. Sanjiv Bhasin - 65 karke 1000 lele Rajiv - Aa gaye Sanjiv Bhasin - Kya Average hain Rajiv - 5660.48 Sanjiv Bhasin - 5660.48 main 1000 LTTS Rajiv - Hanji Sanjiv Bhasin - Theek Hain Rajiv" 39.4 On a bare perusal of the above conversation, it is revealed that the Noticee No. 1 first enquired the price of scrip LTTS Futures from the Noticee No. 5 and then instructed him to buy 1000 shares (5 lots; 1 lot equivalent to 200 shares) of LTTS at the limit price of Rs.65 (which means Rs.5665 per share). Subsequently, the Noticee No.1 enquired the average acquisition price of shares bought from the Noticee No. 5, for which Rajiv informed that the average price of the shares bought was Rs.5660.48 per share. 39.5 Upon perusal of the trade log data obtained for the scrip day from NSE, it....
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.... perusal of the order log subsequent to this call, it is observed that as instructed by the Noticee No.1, Noticee No. 5 had placed sell orders for 1000 shares (600 shares at Rs.5708 and 400 shares at Rs.5713). As the last traded price was lower than the sell order limit price, the sell orders were not executed. Since no sell orders were executed, total quantity remained same as 1000 shares (5 lots). The order log data is provided below: Table 32 Sell Order Date Sell Order Time Sell Client Name Sell Order no. Sell order original Vol Sell order limit price Sell LTP prior to order entry Trade no .* 11/01/2022 09:57:09 VENUS PORTFOLIOS PVT LTD 1500000008106820 600 5708 5655.05 NULL 11/01/2022 09:57:14 VENUS PORTFOLIOS PVT LTD 1500000008119910 400 5713 5655.05 NULL *NULL - Indicates non-execution of trades 39.9 The detailed transcript of third conversation exchanged between Sanjiv Bhasin and Rajiv Kapoor for the buy instance at 12:42 PM is as under: "Rajiv - Hello Sanjiv Bhasin - LTTS Dekhiyo.....40 Karke 5 lot aur lelo.... Rajiv - Ek reh gaya sir Sanjiv Bhasin - Aa gaye Rajiv Rajiv - Ek reh gaya sir Sanjiv - ok" 39.10 From the above call, it is....
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....Rs.5,632 per share. Subsequently, the Noticee No. 1 instructed Noticee No. 5 to buy another 2 lots @ 32 which meant Rs.5632 per share, then 2 lots @30.50 which meant Rs.5,630.50 per share and further 3 lots @ 28.50 which meant Rs.5,628.50 per share. Further, the Noticee No. 1 instructed Noticee No. 5 to revise the last pending order price to 35 which meant Rs.5,635 per share. Subsequently, the Noticee No. 5 confirmed that the pending buy orders were standing @32, @30.50 and @35 which meant, Rs.5,632, Rs.5630.50 and Rs.5,635 per share. After the end of the fourth call, the total bought quantity became 3800. The instructions given by the Noticee No. 1 to Noticee No. 5 to place aforementioned orders in the scrip of LTTS Future can be seen in the order log data given below: Table 34 Buy Order Date Buy Order Time Buy Client Name Buy Order no. Buy order original Vol Trade Quantity Buy order limit price Buy LTP prior to order entry Trade no .* 11/01/2022 12:47:45 VENUS PORTFOLIOS PVT LTD 1500000032838810 400 0 5632 5635 NULL 11/01/2022 12:47:46 VENUS PORTFOLIOS PVT LTD 1500000032838810 400 200 5632 5635 20220111500208100 11/01/2022 12:47:46 VENUS PORTFOLIOS ....
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....:49 5635 11/01/2022 12:49 200 5635 11/01/2022 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R LTTS FUTSTK 11/01/2022 12:49 5635 11/01/2022 12:49 200 5635 11/01/2022 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R LTTS FUTSTK 11/01/2022 12:49 5632 11/01/2022 12:49 200 5632 11/01/2022 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R LTTS FUTSTK 11/01/2022 12:49 5630.5 11/01/2022 12:49 200 5630.5 11/01/2022 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R LTTS FUTSTK 11/01/2022 12:49 5630.5 11/01/2022 12:49 200 5630.5 Total 1800 5633 39.14 The detailed transcript of the fifth conversation exchanged between Sanjiv Bhasin and Rajiv Kapoor for the buy instance at 12:50 PM is as under: "Rajiv - Hello Sanjiv - Aa Gaye Rajiv....Kitne Hue.....Kitne ho gaye... Rajiv - Ye ho gaye....3800...5641.81 Sanjiv - 3800 go haye.....200 aur le le...abhi le le 15 main.....18 karde Rajiv Rajiv - Aacha ji .....8 -8 Rupee ka to gap hain, 10-10 rupee ka Sanjiv - Chal ....Kitne aa gaye....Chal Rehn de ....
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....original Vol Sell order limit price Sell LTP prior to order entry Trade no .* 11/01/2022 13:10:00 VENUS PORTFOLIOS PVT LTD 1500000008119910 400 5713 5655.05 NULL 11/01/2022 13:10:03 VENUS PORTFOLIOS PVT LTD 1500000008106820 600 5708 5655.05 NULL 11/01/2022 13:10:18 VENUS PORTFOLIOS PVT LTD 1500000035588730 400 5688 5637.95 NULL 11/01/2022 13:10:36 VENUS PORTFOLIOS PVT LTD 1500000035634020 400 5690 5638 NULL 11/01/2022 13:10:42 VENUS PORTFOLIOS PVT LTD 1500000035651760 400 5692 5638 NULL 11/01/2022 13:10:46 VENUS PORTFOLIOS PVT LTD 1500000035658920 400 5694 5638 NULL 11/01/2022 13:10:51 VENUS PORTFOLIOS PVT LTD 1500000035671740 400 5696 5638 NULL 11/01/2022 13:10:59 VENUS PORTFOLIOS PVT LTD 1500000035686730 400 5698 5638 NULL 11/01/2022 13:11:03 VENUS PORTFOLIOS PVT LTD 1500000035695800 400 5700 5638 NULL 11/01/2022 13:11:42 VENUS PORTFOLIOS PVT LTD 1500000035770320 400 5687 5634 NULL 11/01/2022 13:12:00 VENUS PORTFOLIOS PVT LTD 1500000035817710 200 5691 5634 NULL 11/01/2022 13:12:07 VENUS PORTFOLIOS PVT LTD 1500000035843220 200 5695 5634 NULL 11/01/2022 13:12:12 VENUS PORTFOLIOS PV....
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....ee No. 1 first enquired Noticee No. 5, whether he had already placed the sell orders at the price of Rs.5687 or above. To this, the Noticee No. 5 replied that all the orders in the scrip were standing at the price between Rs.5687 - Rs.5700. The same is reflected in the order log data provided in the preceding paras at Table 37. Thereafter, the Noticee No. 1 instructed Noticee No. 5 to revise all the pending sell orders placed at highest rates, to Rs.5675-5677 and sell 1000 shares in the quantity range of 200-200 each. 39.20 Due to the effect of the recommendations of the Noticee No.1, as the rates started surging upwards to Rs.5684, the Noticee No. 1 first asked Noticee No. 5 to wait and then instructed him to sell 1000 shares (in the quantity range of 200-200 each) at a price exceeding Rs.5680. It is pertinent to mention here that the Noticee No. 5 followed all the instructions being given by the Noticee No. 1 to him before and immediately after the recommendation given at 13:33 PM. As the momentum in the scrip continued, the Noticee No. 1 then informed Noticee No. 5 to revise the order and sell 1000 shares at a price exceeding Rs.5684. 39.21 Afterwards, when the price fell, t....
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.... 200 5682 11/01/2022 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R LTTS FUTSTK 11/01/2022 13:38 5683 11/01/2022 13:38 400 5683 11/01/2022 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R LTTS FUTSTK 11/01/2022 13:38 5680 11/01/2022 13:38 200 5680 11/01/2022 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R LTTS FUTSTK 11/01/2022 13:38 5680 11/01/2022 13:38 200 5680 11/01/2022 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R ILTTS FUTSTK 11/01/2022 15:21 5668 11/01/2022 15:21 200 5668 11/01/2022 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R LTTS FUTSTK 11/01/2022 15:21 5668 11/01/2022 15:21 200 5668 11/01/2022 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R LTTS FUTSTK 11/01/2022 15:22 5668 11/01/2022 15:22 400 5668 11/01/2022 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R ILTTS FUTSTK 11/01/2022 15:22 5668 11/01/2022 15:22 400 5668 Total 3800 5678.6 39.22 For the sake of clarity, a table det....
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....es were sold at average price of Rs.5677.79 Profit (Average sell price Rs.5677.79 - average buy price Rs.5641.81) * quantity 3800 = Profit Rs.136724 approx. 39.23 From the aforementioned transcripts of call conversations, it is clear that prior to and post the recommendations on news channel given by the Noticee No. 1 at 13:33 PM, he had called Noticee No. 5, and traded in the account of Venus by placing orders through him. It may be noted that despite not being a client of RRB Master, the Noticee No. 1 was in constant touch/contact with dealer of RRB Master viz. the Noticee No. 5 through phone calls, for placing the trade orders in the account of Venus, in the scrip of LTTS, which was recommended to the viewers for long term perspective. 39.24 On a perusal of the transcripts of calls coupled with the trades carried out as per the instructions of the Noticee No.1 given to Noticee No. 5 it can be reasonably, prima facie, inferred that the Noticee No. 1 carried out first Leg of transaction, i.e. buy trades in the LTTS scrip between 09:56 AM to 12:49 PM, prior to his recommendation on Business channel, at an average price of Rs.5641.80 per share. Thereafter, the Noticee....
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....Noticee No. 5 made a profit of Rs.7,400. 40.2 The Noticee No. 6 was an employee of RRB Master since 2008. Investigation revealed that the Noticee clients of RRB Master were mapped with Dealer ID of Noticee No. 6, which allowed him to view the trades/orders of any client mapped to his Dealer ID. Accordingly, upon further examination, it was observed that the Noticee No. 6 mirrored the trades of Venus. The Noticee No. 6 misused the facility of having access to information of trades of other clients of the Trading member RRB Master, by virtue of being an employee, and he carried out trades in his own account by mirroring the trades of the Noticee No. 1, carried out in the account of Venus in the instant example by the Noticee No. 5. Noticee No. 6 placed a total of five buy orders of LTTS Futures (Comprising 1000 shares cumulatively), and out of which, he placed two orders at 09:59 AM and the remaining three orders between 11:53 AM- 12:40 PM. Thereafter, emulating the pattern of trades in Venus, the Noticee No. 6 placed five limit sell orders of LTTS Future (comprising 200 shares each, aggregate of 1000 shares), out of which, he had placed one sell order at 11:51 AM and remaining fou....
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....een 13:36 PM to 15:22 PM. Similarly, Ashish placed sell orders in the scrip at 13:37 PM and Leo between 13:37 PM to 15:03 PM, which was immediately after the recommendations aired on Media Channel. Accordingly, Leo and Ashish made a profit of Rs.12,000 and Rs.3,990, respectively. 40.5 A brief analysis of trades carried out and further profits made by Noticees, as discussed hereinabove vis-à-vis recommendations given by the Noticee No. 1, is given in the table below: Table 41 Analysis of trades carried out by the clients in the scrip "LTTS" Date and Recommendation time - Jan 11, 2022, 13:33 (Contract- LTTS22JANFUT) Client Name PAN Buy (First Leg) Sell (Second Leg) Client Scrip Trade Val to all scrips trd val. Profit Rs. Order Time Trade Time Average Price (in Rs.) Traded Quantity Total Value Traded Rs. Order Time Trade Time Average Price Traded Quantity Total Value Traded Rs. Venus AAACV4306R 09.56 - 12.49 09.56 - 12.49 5641.8 3800 21438880 13.36 - 13.38 13.36 - 15.22 5677.79 3800 21,575,600 35.21% 136720 LEO AAACL2384F 10:04 - 12:49 10:04 - 12:49 5654 600 3392400 13:37 - 15:03 13:37 - 15:03 5673 600 340....
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....rice Stop Loss Recommendation Platform Feb 07, 2024 Parag Milk Foods Limited ("PARAGMILK"). Rs.220 Rs.300 Rs.202 Buy (Long term - 31 days) @ Rs.210-220 IIFL Telegram, IIFL Markets App, IIFL Trading terminals 44. Investigation also revealed that the research report of Noticee No. 1 in the scrip (PARAGMILK), Titled "Sanjiv Bhasin Special Stock pick - Parag Milk Foods", was circulated by IIFL through its official email id (********@iifl.com) to its various group emails such as ********@iifl.com, ********@iifl.com; ********@5paisa.com, ********@iifl.com, ********@iifl.com, ********@iifl.com, the email IDs of employees/authorised persons of IIFL. The email was forwarded at 14:22 PM. The recommendation details of the research report are as follows: Table 44 Date Scrip CMP Target Price Stop Loss Recommendation Platform Feb 07, 2024 Parag Milk Foods Limited ("PARAGMILK"). Rs.223 Rs.365 Rs.215 Buy (Long term - 90 days) @ Rs.215 IIFL Emails 45. The snapshot of the recommendation email through which the research report was disseminated can be seen below: Figure 5 46. In the initial recommendation dated February 07, 2024 to buy shares of Parag Milk Foods, Noticee N....
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....nd t+2] (number of shares/underlying shares) 2388 7308 Avg Trading Vol for succeeding 15 mins [t+15] (number of shares/underlying shares) 856 2674 Relevant Price Sensitive Corporate Announcement on the day of the recommendation or the prior day There was a price sensitive announcement of Financial results on February 07, 2024, at 14:36 PM. However, the alleged transactions were carried out before this announcement 50. The analysis of the price impact in the scrip shows the following: i. In the preceding 15 minutes before the recommendation, the average high/low price variation was relatively low at 0.09%, and 0.21% for PARAGMILK scrip at BSE (EQ), and NSE (EQ) respectively. ii. However, during the recommendation time and the subsequent 2 minutes (t and t+2), there was a significant surge in price volatility, with an average high/low variation of 0.52%, and 0.67% PARAGMILK scrip at BSE (EQ), and NSE (EQ) respectively. iii. In the succeeding 15 minutes (t+15) after the recommendation, the average high/low variation stood at 0.25%, and 0.39% for PARAGMILK scrip at BSE (EQ), and NSE (EQ) respectively. 51. An analysis of the volume impact in the scrip shows the followi....
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....it is clear that Sanjiv Bhasin had called Rajiv Kapoor for a second time at 09:37 AM to confirm whether, as instructed by Sanjiv Bhasin to Praveen Gupta, shares of Indiabulls were sold and shares of Paragmilk scrip were purchased. To this, Rajiv replied that he received the information of trades to be carried out in the scrip Paragmilk and Indiabulls from Praveen just moments before and the orders were not yet placed. Upon hearing the reply of Rajiv Kapoor, Sanjiv Bhasin vented his frustration on the non-execution of his instructions and also informed Rajiv Kapoor to complete the same at the earliest. Further, it was revealed that Sanjiv Bhasin (Ph: 981****162), on February 07, 2024 had two phone calls with Praveen Gupta (Ph: 981****959) at 09:28:04 AM and 09:29:20 AM. 52.6 WhatsApp chat and calls between Sanjiv Bhasin and Lalit Bhasin on February 07, 2024 at 09:38 AM (1st Buy leg). It is important to note here that Sanjiv Bhasin and Lalit Bhasin had also communicated through WhatsApp (chats/calls) w.r.t the execution of trades in the scrip of Paragmilk. From the WhatsApp data obtained from the Seized/Backed-up device of Sanjiv Bhasin (Ph: 981****162), it was observed that ther....
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....agMilk at an average buy price of Rs.220.08 per share, as per the instructions in the WhatsApp chat above. The 2nd buy leg details of HB in the scrip are as follows: Table 49 NAME: HB STOCKHOLDINGS LTD PAN: AAACH0637F DATE SYMBOL INSTRUMENT TYPE BUY QUANTITY BUY VALUE AVG. BUY PRICE BUY ORDER RECO. TIME Start Time End Time 07.02.2024 PARAGMILK CASH 25000 55,02,149.95 220.08 11:28:15 11:34:37 13:18 & 14:22 52.10 From the above details of buy leg, it is seen that Rajiv Kapoor placed orders in the scrip between 11:28 to 11:34. Investigation revealed that the average buy price and number of shares details shared by Lalit Bhasin to Sanjiv Bhasin matched exactly with the data from the trade log and the above chat reveals that the message containing average buy price (i.e. 220.08) and number of shares (i.e. 25,000) purchased in ParagMilk was shared by Lalit Bhasin to Sanjiv Bhasin. Further, it has also been found that Lalit Bhasin and Rajiv Kapoor work in the same premises i.e. "H-72, Connaught Circus, New Delhi-110001". 52.11 WhatsApp chat and calls between Sanjiv Bhasin (981****162) and Lalit Bhasin (981**....
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....Sanjiv Bhasin immediately sends a message to Lalit Bhasin that now Rs.1.22 Crores is his cash. This amount matches exactly with the sale value of PARAGMILK shares. This also corroborates the fact that this trade in account of HB Stockholdings Ltd is in fact Sanjiv Bhasin's trade. Content: "I will chk" Explanation: After receiving the message of "Now my cash is Rs.1.22 Cr", Lalit Bhasin sends a message that he will check the same. Content: "Kindly get this in my daily sheet" Explanation: Here, Sanjiv Bhasin says to get the Rs.1.22 Cr cash in his daily sheet indicating that this is a regular occurrence. 52.14 It can be seen from the above screenshot that upon receipt of confirmation of execution of trades from Lalit Bhasin, Sanjiv Bhasin confirmed with Lalit Bhasin that his cash was now Rs.1.22 Crores which was the proceeds of the sale of shares of Parag Milk Foods. In the next message Sanjiv Bhasin instructed Lalit Bhasin to get that figure (i.e. Rs.1.22 Cr) in his daily sheet. This gives an inference that the same was a daily/regular occurrence and Lalit Bhasin had been aware of the trading details as well as the scheme. Lalit Bhasin received instructions from Sanjiv Bhas....
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....rip of Paragmilk. Sanjiv Bhasin on being aware that the orders were not placed in the scrip of Paragmilk, vented his frustration on the non-execution of instructions and also informed Rajiv to execute the trades at the earliest. During the call between Rajiv Kapoor and Sanjiv Bhasin, Rajiv, when enquired about the status of placement of orders of Paragmilk by Sanjiv Bhasin, had informed the receipt of order information from Praveen Gupta making the connection and sharing of information evident. It can therefore, be prima facie, inferred that Sanjiv Bhasin had initially informed Praveen Gupta to place orders in the scrip of Paragmilk and subsequently enquired the placement of orders from Rajiv Kapoor. 52.18 The details of trades of Praveen Gupta in the trading account of Babita Gupta is given in the table below: Table 54 NAME: BABITA GUPTA PAN: AAEPG1745N DATE SYMBOL INSTRUMENT TYPE BUY QUANTITY BUY VALUE BUY ORDER SELL QUANTITY SELL VALUE SELL ORDER RECO. TIME Start Time End Time Start Time End Time 07.02.2024 PARAGMILK CASH 400 86,220 09.34 09:34 400 94,000 14:48 1....
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....pearance and the recommendation is given below: Figure 8 55. The details of the recommendation are given below: Table 56 SCRIP NAME RECOMMENDATION DATE AND TIME OF RECOMMENDATION TARGET PRICE STOP LOSS InterGlobe Aviation Limited (INDIGO) Buy Wednesday, January 30, 2024 (around 08:51 AM) Rs.3100 Rs.2835 56. Investigation revealed that Sanjiv Bhasin had carried out the trades, contrary to his own recommendation in the instrument - INDIGO24FEBFUT, in the trading account of Venus, through RRB Master, on Jan 29-30, 2024. 57. The recommendation was made on Jan 30, 2024 during pre-opening session at around 08:51 AM on ET Now. The price and volume chart, during 15 minutes pre and post the recommendation time (i.e. From 3:15-3:30 (Jan 29, 2024) to 9:15-9:30 (Jan 30, 2024)) in the scrip of "INDIGO" in BSE NSE equity cash segment and NSE Futures is given below: Figure 9 58. A significant impact on the price and the trading volume of the scrip/contract was observed post recommendation in the show, as shown below: Table 57 Recommendation date January 30, 2024 Recommendation time (t) 08:51 AM Scrip/Contract Recommended INDIGO Recommended Levels (For Cash....
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....and NSE (Future) respectively. iii. In the succeeding 15 minutes (t+15) after the recommendation and opening session, the average trading volume remained elevated at 192 shares, 4084 shares and 14980 shares for the scrip INDIGO at BSE (EQ), NSE (EQ) and NSE (Future) respectively. 61. From the above, it is seen that the recommendation had a significant impact on both the price and trading volume of the scrip INDIGO and its derivatives contract. Further, there were no relevant price-sensitive corporate announcements around the time of recommendation, which could explain the sudden rise in price and volume in the scrip of INDIGO and also no material relevant price sensitive corporate announcement on the day of the recommendation (Jan 30, 2024) or the prior trading day (Jan 29, 2024). 62. During the investigation, it was revealed that Venus created buy position in INDIGO24FEBFUT on January 29, 2024 and squared off the positon on the day of recommendation i.e. on January 30, 2024. The summary of trading activity of Venus is as under: Table 58 VENUS PORTFOLIOS PRIVATE LIMITED Instrument INDIGO24FEBFUT Date of Buy Leg Tuesday, January 29, 2024 Net Qty 9900 Average Price....
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....069694780 12:11:28-12:11:28 12:13:03-12:13:36 900 Total Traded Quantity 9900 62.5 Upon further examination and comparison of timing of sell orders vis-à-vis price/volume variation, it is seen that Venus wanted to get maximum benefit out of surge in price/volume in scrip owing to the recommendation made by Sanjiv Bhasin on ET Now. The time of trades and price / volume chart are provided below: Figure 10 62.6 The aforesaid buy and sell orders in the account of Venus were placed by Jagat Singh, Noticee No. 6, dealer at RRB Master on Jan 29 2024 and Jan 30, 2024, respectively. Investigation revealed that the timing of the buy and sell orders in INDIGO24FEBFUT matched with the timing of calls between Sanjiv Bhasin and Jagat Singh, which is explained through the below table: Table 61 Date Timing Nos. of Call Sanjiv to Jagat Jagat to Sanjiv Jan 29, 2024 09:12:40 - 13:07:17 5 4 1 Jan 30, 2024 09:14:15 - 15:18:31 17 15 2 Total 22 19 3 62.7 On Jan 29, 2024, Sanjiv Bhasin (981****162) called Jagat (836****616) during 13:07:17 PM-13:12:33 PM (Duration- 317 seconds). Investigation revealed that during this call, the buy ord....
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....y INDIGO24FEBFUT. Screenshot sent on Jan 29, 2024: The aforesaid chats were also found in seized data from Jagat Singh Mobile (852****988). WhatsApp Chat on Jan 30, 2024 ( Sell Leg in INDIGO24FEBFUT) Jan 30, 2024: Content: Text- "Send me screenshots" Explanation: On Jan 30, 2024, around 1:00 PM, Sanjiv Bhasin asked Jagat Singh to forward screen shot of trades executed on Jan 30, 2024. It may be noted that on this day by 12:14 PM, Jagat sold 9900 INDIGO24FEBFUT. Jan 30, 2024: Content- Attachment - The screenshot of trades executed. Explanation: In reply to the above message, on Jan 30, 2024, around 1:08 PM, Jagat forwarded the details of the trades executed. This screen shot includes the details of the sell order executed in the scrip of Indigo. Screenshot sent on Jan 30, 2024: The aforesaid chats were also found in seized data from Jagat Singh's Mobile (852****988). 63. From the above, it can be seen that Jagat had executed trades in the scrip in INDIGO24FEBFUT as per the instructions of Sanjiv Bhasin, which was further confirmed by Jagat and the screenshots of the same were also shared with Sanjiv Bhasin. The same can be verified fr....
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....tures is given below: Figure 12 69. It is seen that significant impact on the price and the trading volume of the scrip was observed post the aforesaid recommendation in the show, the details of which are given in the table below: Table 65 Recommendation date August 26, 2022 Recommendation time (t) 09:52 AM Scrip/Contract Recommended SAIL Recommended Levels CMP (Rs.) 82.30 Target Price (Rs.) 90 Stop Loss (Rs.) 78 Scrip/Contract Steel Authority of India Limited BSE (EQ) NSE (EQ) NSE (FF) Price Impact Post Recommendation Average High/ Low Variation % in preceding 15 mins [t-15] 0.13% 0.11% 0.09% Average High/ Low Variation % during recommendation time and succeeding 2 mins [t and t+2] 0.14% 0.16% 0.18% Average High/ Low Variation % in succeeding 15 mins [t+15] 0.14% 0.14% 0.10% Volume Impact Post Recommendation Avg Trading Vol in Preceding 15 mins [t-15] (number of shares/underlying shares) 8727 65737 85600 Avg Trading Vol during recommendation time and succeeding 2 mins [t and t+2] (number of shares/underlying shares) 16998 131575 176000 Avg Trading Vol for succeeding 15 mins [t+15] (n....
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.... 73.1 The investigation reveals that, before making the said recommendation on the news channel, the Noticee No. 1 had made four phone calls to Noticee No. 5 for placing buy orders in the scrip of SAIL. Further, post the recommendation (at 09:52 AM), the Noticee No. 1 had made two phone calls to Noticee No. 5 for placing sell orders in the scrip of SAIL and squaring-off the positions taken earlier. The summary of calls exchanged between Noticee No. 1 and Noticee No. 5 during the recommendation day (before and after the recommendation time of 09:52 AM), is tabulated below: Table 66 Call Details Time Instruction (On call) First Call 09:14 AM Buy SAIL Second Call 09:25 AM Buy SAIL Third Call 09:31 AM Buy SAIL & Sell SAIL* Fourth Call 09:40 AM Buy SAIL Recommendation on ZEE Business Media Channel at 09:52 AM Fifth Call 10:19 AM Sell SAIL Sixth Call 10:40 AM Sell SAIL *As per the trade logs, the orders instructed by Sanjiv Bhasin during his call could not be executed. 73.2 The details of trades done in the trading account of HB are given below: Table 67 Date and Recommendation time - Aug 26, 2022, 09:52 AM (Contract- SAIL22SEPFUT) &nb....
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....LTD. HB STOCKHOLDINGS LIMITED AAACH0637F SAIL FUTSTK 26/08/2022 09:15 82 26/08/2022 09:15 6000 81.9 Total 36000 81.83 73.5 From the above, it is seen that the average price (Rs.81.83) of the executed trades is matching exactly with the price mentioned by the Noticee No. 5 in the transcript. 73.6 Transcript of 2nd call at 09:25 AM on Aug 26, 2022- Buy Side is given below: "Sanjiv - SAIL kya aa raha Rajiv- SAIL aa raha hain 10 81 20 Sanjiv - Thik hain OK" From the above, it can be seen that Noticee No. 1 called Noticee No. 5 in a gap of 10 minutes again at 09:25 AM to enquire about the share price of SAIL, to which Rajiv replied that the scrip price was in the range of Rs.81.10 - 81.20. 73.7 Transcript of 3rd call at 09:31 AM on Aug 26, 2022- Buy Side as well as Sell Side: "Sanjiv - Aur SAIL dekhiyo Rajiv- 82 15 20 Sanjiv - Lele 5 lot Rajiv- laga diya Sanjiv -aa gaye Rajiv- 2 hi aaye,10 se 20 main 3 aaye Sanjiv - Thik hain, 83 main aaj ki selling dal diyo puri haan Rajiv- aaj wali Sanjiv - mane 36000 jitne liya hain na Rajiv-abhi 66 aaye hain Sanjiv -aa gaye, ab 82 90 aur 9....
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.... Rs.82.90-82.95. As per the instructions of Sanjiv Bhasin, Rajiv Kapoor placed buy orders for 5 lots at 09:40 AM. The same can be confirmed from the trade data presented below: Table 70 Date Buy Trading Member Name Buy Client Name Buy Client PAN Buy Symbol Buy Instrume nt Buy Order Date & Time Buy Order Limit Price Trade Date & Time Trade Quantity Trade Price 26/08/2022 RRB MASTER SECURITIES DELHI LTD. HB STOCKHOLDINGS LIMITED AAACH0637F SAIL FUTSTK 26/08/2022 09:40 82.15 26/08/2022 09:40 6000 82.15 26/08/2022 RRB MASTER SECURITIES DELHI LTD. HB STOCKHOLDINGS LIMITED AAACH0637F SAIL FUTSTK 26/08/2022 09:40 82.15 26/08/2022 09:40 6000 82.15 26/08/2022 RRB MASTER SECURITIES DELHI LTD. HB STOCKHOLDINGS LIMITED AAACH0637F SAIL FUTSTK 26/08/2022 09:40 82.15 26/08/2022 09:40 6000 82.15 26/08/2022 RRB MASTER SECURITIES DELHI LTD. HB STOCKHOLDINGS LIMITED AAACH0637F SAIL FUTSTK 26/08/2022 09:40 82.15 26/08/2022 09:40 12000 82.15 73.11 However, the sell orders as instructed by Sanjiv Bhasin in the transcript were placed but could not be executed, as per the order log data obtained from NSE, and can be seen in the below table: Table ....
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....6/08/2022 10:40 18000 82.6 73.15 Further, Sanjiv Bhasin informed Rajiv to cancel all pending sell orders of the remaining lots and instructed him to place sell orders for 36000 shares at Rs.82.75 and the remaining (i.e. 24000 shares) at Rs.82.80. To which Rajiv confirmed that the sell order placed for 36000 shares at Rs.82.75 got executed and the one placed at Rs.82.80 got executed for 18000 shares and one lot (6000 shares) is remaining. The same can be confirmed from the trade data presented below: Table 73 Date Sell Trading Member Name Sell Client Name Sell Client PAN Sell Symbol Sell Instrument Sell Order Date & Time Sell Order Limit Price Trade Date & Time Trade Quantity Price Trade 26/08/2022 RRB MASTER SECURITIES DELHI LTD. HB STOCKHOLDINGS LIMITED AAACH0637F SAIL FUTSTK 26/08/2022 10:41 82.75 26/08/2022 10:41 6000 82.75 26/08/2022 RRB MASTER SECURITIES DELHI LTD. HB STOCKHOLDINGS LIMITED AAACH0637F SAIL FUTSTK 26/08/2022 10:41 82.75 26/08/2022 10:41 6000 82.75 26/08/2022 RRB MASTER SECURITIES DELHI LTD. HB STOCKHOLDINGS LIMITED AAACH0637F SAIL FUTSTK 26/08/2022 10:41 82.75 26/08/2022 10:41 6000 82.75 26/08/2022 RRB MASTER SE....
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.... no sell order was executed 09:40 Sanjiv Bhasin instructed Rajiv Kapoor to buy 5 lots 09:40 Rajiv Kapoor placed buy orders for 5 lots (30000 shares) at Rs.82.15 30000 Sanjiv Bhasin instructed Rajiv Kapoor to place sell orders in the price range of Rs.82.90 to Rs.82.95 As per trade log, it appears that sell orders were placed, however, no sell order was executed 10:19 Saniv Bhasin enquired form Rajiv whether Sell orders have been placed at the price range of Rs.82.90 to Rs.82.95. 10:40 Sanjiv Bhasin instructed Rajiv Kapoor to place sell orders for 36000 shares at Rs.82.60 10:40 As instructed, Rajiv Kapoor placed sell orders for 36000 shares at Rs.82.60 -36000 Sanjiv Bhasin instructed Rajiv Kapoor to place sell orders for 36000 shares at Rs.82.75 and the remaining (24000) shares at Rs.82.80 10:41 Rajiv Kapoor placed sell orders for 36000 shares at Rs.82.75 and 24000 shares at Rs.82.80. However, for the trade placed at Rs.82.80, only 18000 shares got sold. Hence, Rajiv informed Sanjiv Bhasin that one mor....
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....nalysis of trades carried out by the clients in the scrip "SAIL" Date and Recommendation time - Aug 26, 2022, 09:52 AM (Contract- SAIL22SEPFUT) Client Name PAN Buy (First Leg) Sell (Second Leg) Profit Rs. Order Time Trade Time Buy Price Range Traded Quantity Total Value Traded Rs. Order Time Trade Time Sell Price Range Traded Quantity Total Value Traded Rs. HB Stockholdings Limited AAACH0637F 09:15 - 09:40 09:15 - 09:40 81.75 - 82.15 96000 7876200 10:40 - 10:42 10:40 - 10:42 82.60 - 82.80 96000 7939200 63000 Babita Gupta AAEPG1745N 09:32 - 09:43 09:32 - 09:44 82.15 12000 985800 09:52 - 09:53 09:54 82.40 - 82.50 12000 989400 3600 Rajiv Kapoor ARSPK9663Q 09:35 09:37 82.05 6000 492300 09:53 10:36 82.55 6000 495300 3000 Jagat Singh BSRPS9870C 09:37 - 09:41 09:38 - 09:42 82.05 - 82.10 24000 1969800 09:53 09:53 -09:54 82.40 24000 1977600 7800 Leo Portfolios Private Limited AAACL2384F 09:43 09:44 82.15 12000 985800 10:43 10:43 82.65 12000 991800 6000 74. As per the trade log data, the trading member details of Noticees are as under: Table 77 Broker wise order placement details Client Name Tradin....
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....d statement of Dealer 1, it can be prima facie inferred that though the Terminal was in the name of Dealer 1, it was used by other dealers to place trade orders. 74.3 As shown in the illustration of LTTS Future dated January 11, 2022 in the preceding paras, the Noticee No. 6 also followed similar trading strategy in the instant scrip of SAIL Futures in his own trading account, and placed the orders in his trading account through broker Zerodha using IBT. Accordingly, from the trade log data, it can be seen that the Noticee No. 6 placed buy orders of SAIL FUTSTK for 12000 shares each at 09:37 AM and 09:41 AM, respectively, just prior to the recommendation made by Sanjiv Bhasin in news channel and later squared off his entire position at 09:53 AM (i.e. soon after the recommendation) and earned profit of Rs.7,800. 74.4 Similarly, investigation revealed that similar trading strategy was also implemented in the trading account of the Noticee No. 11, Leo in the instant scrip of SAIL Future. Buy orders were placed for 12000 shares at 09:43 AM and later its entire position was squared off at 10:43 AM (i.e. post recommendation of Sanjiv Bhasin). It may be noted that the trades were plac....
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....Trading Vol in Preceding 15 mins [t-15] (number of shares/underlying shares) 30.26 2122 2533.33 Avg Trading Vol during recommendation time and succeeding 2 mins [t and t+2] (number of shares/underlying shares) 130 6000.33 23333.33 Avg Trading Vol for succeeding 15 mins [t+15] (number of shares/underlying shares) 45.20 1918.46 7266.67 Relevant Price Sensitive Corporate Announcement on the day of the recommendation or the prior day NA 80. The analysis of the price impact in the scrip shows the following: i. In the preceding 15 minutes before the recommendation, the average high/low price variation was at 0.01%, 0.08%, 0.04% for GODREJCP scrip at BSE (EQ), NSE (EQ) and NSE (Future) respectively. ii. However, during the recommendation time and the subsequent 2 minutes (t and t+2), there was a significant surge in price volatility, with an average high/low variation of 0.09%, 0.16% and 0.14% for GODREJCP scrip at BSE (EQ), NSE (EQ) and NSE (Future) respectively. iii. In the succeeding 15 minutes (t+15) after the recommendation, the average high/low variation stood at 0.02%, 0.08%, 0.05% for GODREJCP scrip at BSE (EQ), NSE (EQ) and NSE (Future) respective....
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....35 PM *As per the trade log, the orders instructed by Sanjiv Bhasin during his call were not executed. # Sell orders were placed during the timings of call recordings, however the orders got executed post recommendation. 83.2 Transcript of 1st call at 10:35 AM on Sep 13, 2022 - Buy Side: "Rajiv Kapoor - Hanji Sir Sanjiv Bhasin - Ye Godrej CP dekhiyo Rajiv Rajiv Kapoor - 947 - 47 - 85 Sanjiv Bhasin - 48 tak 5 lot le le Rajiv Kapoor - aa gaye sir Sanjiv Bhasin - 5 aur le le, aa gaye Rajiv Kapoor - ek aaya hai Sanjiv Bhasin - baki hata de, 2 - 47.65 main laga dein, 2 - 47.55 main laga dein Rajiv Kapoor - theek hain ji Sanjiv Bhasin - kitne aa gaye, 6000 aa gaye na Rajiv Kapoor - haan ji Sanjiv Bhasin - .... Vo 6000 ki kya average hain Rajiv Kapoor - 947.97 Sanjiv Bhasin - 948, theek hain" 83.3 From the above, it can be seen that Sanjiv Bhasin called Rajiv at 10.35 AM and enquired from him the price of GODREJCP. To which Rajiv informed Sanjiv Bhasin that the price is at Rs.947.85. Sanjiv Bhasin then instructed Rajiv to buy 5 lots of shares of GODREJCP till the price reaches Rs.948. Rajiv informed Sanjiv Bhasin that the order for 5 lots got executed. ....
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....uantity Trade Price 2022-09-13 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R GODREJCP Fut 10:48:15 946.65 11:02:01 2000 946.65 2022-09-13 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R GODREJCP Fut 10:48:07 946.55 11:02:01 1000 946.55 2022-09-13 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R GODREJCP Fut 10:48:07 946.55 11:02:01 1000 946.55 83.5 Transcript of 3rd call at 11:09 AM on Sep 13, 2022 - Buy Side "Sanjiv Bhasin - kya aa rahi yaar, Jindal, JSW or Godrej Rajiv Kapoor - 47.50 aa raha hain Godrej Sanjiv Bhasin - Hamare lage hain na 65 - 55 main Rajiv Kapoor - Wo aa gaye the wo to Sanjiv Bhasin - 10000 ho gaye hamare Rajiv Kapoor - haan ji Sanjiv Bhasin - 10000 ki kya average hain Rajiv Rajiv Kapoor - 47.42 paise Sanjiv Bhasin - theek hain, 4000 aur laga dein, 44.65 - 44.55 main, Rajiv Kapoor - theek hain..." 83.6 From the above, it can be seen that Sanjiv Bhasin enquired from Rajiv Kapoor whether he has placed buy orders at Rs.946.65 and Rs.946.55, to which Rajiv informed Sanjiv Bhasin that those orders got executed. Subsequently, Sanjiv Bhasin confirme....
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....tion ("BUY") on the news channel. However, since the CMP was lesser than the sell order limit price, the orders didn't get executed. The order details are provided below: Table 84 Sell Order Date Sell Order Time Sell Client Name Sell Order no. Sell order original Vol Sell order limit price Sell LTP prior to order entry Sell LTP prior to order mod Trade no .* 13/09/2022 11:34:10 VENUS PORTFOLIOS PVT LTD 2500000018948900 1000 949.25 948.6 948.6 NULL 13/09/2022 11:34:16 VENUS PORTFOLIOS PVT LTD 2500000018957340 1000 949.3 948.6 948.6 NULL 13/09/2022 11:34:24 VENUS PORTFOLIOS PVT LTD 2500000018975390 1000 949.35 948.6 948.6 NULL 13/09/2022 11:34:29 VENUS PORTFOLIOS PVT LTD 2500000018987390 1000 949.4 948.6 948.6 NULL *NULL - Indicates non-execution of trades 83.9 Transcript of 5th call at 11:44 AM on Sep 13, 2022 - Sell Side "Sanjiv Bhasin - Bik gaye wo kuch Rajiv Kapoor - nahi sir, 46.35-46.95 Sanjiv Bhasin - hum dalte he order niche aa jata hain, kuch bhi nahi bika Rajiv Kapoor - kuch bhi nahi Sanjiv Bhasin - ye buying hata de iski niche jo dal rakhi hain Rajiv Kapoor - aacha ji" 83.10 Transcript of 6th call at 12:00 PM o....
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....to place buy orders for 2 lots each at Rs.943.65 and Rs.943.55. Upon perusal of the trade data, it can be seen that the contents of the phone recordings are exactly matching with the trade data of Venus. As instructed by Sanjiv Bhasin, Rajiv Kapoor placed 2 buy orders for 2 lots each at Rs.943.65 and Rs.943.55. However, upon perusal of the trade data, it can be seen that out of 2 buy orders placed, only one buy order placed at the price of Rs.943.65 was executed. The trade data and order log data are presented in the below tables: Table 86 Trade Date Buy Trading Member Name Buy Client Name Buy Client PAN Buy Symbol Buy Instrument Buy Order Time Buy Order Price Trade Time Trade Quantity Trade Price 2022-09-13 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R GODREJCP Fut 12:15:41 943.65 12:21:14 2000 943.65 Table 87 Buy Order Date Buy Order Time Buy Client Name Buy Order No. Buy Order Original Vol Buy Order Limit Price Buy LTP Prior to Order Entry Buy LTP Prior to Order Mod Trade No. 13/09/2022 12:15:34 VENUS PORTFOLIOS PVT LTD 2500000023453150 2000 943.55 945.35 945.35 NULL 83.14 Transcript of 8th call at 12:26 ....
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....2000 943.65 TOTAL 16000 946.24 83.16 Transcript of 9th call at 12:57 PM on Sep 13, 2022 - Sell Side "Sanjiv Bhasin - 47.20 main bhi 2 laga de godrej, 47.30 main 2, 47.40 main 2 laga de, aur ek tune laga rakha hain 47 main Rajiv Kapoor - hanji Sanjiv Bhasin - tho 7 ho gaye, 47.80 - 85 - 90 main bhi 2-2 laga de Rajiv Kapoor - 80-85-90 main, theek hain ji Sanjiv Bhasin - 6-6, 12 aur ek 13 Rajiv Kapoor - main dekh leta hu sir Sanjiv Bhasin - theek hai ok" 83.17 From the above, it can be seen that Sanjiv Bhasin instructed Rajiv to place sell orders for 2 lots each at Rs.947.20, Rs.947.30 and Rs.947.40 and also he enquired whether Rajiv had already placed one sell order for 1 lot at Rs.947. Further, Sanjiv Bhasin informed that once 7 lots are sold, place orders for 4 lots in the price range of Rs.947.80 - 947.90. From the transcript above, it is clear that Sanjiv Bhasin had instructed Rajiv to place sell orders for 13 lots (13000 shares) at various limit prices. Accordingly, from the order log data, it is evident that Rajiv Kapoor placed sell orders for 13000 shares at the afore-mentioned limit prices a....
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.... Rs.949.20 got executed at 13:37. However, it can be seen that the sell order placed for 3000 shares at Rs.949.40 didn't get executed. The details of the executed trades are provided in the table below: Table 90 Trade_Date Sell Trading Member Name Sell Client Name Sell Client PAN Sell Symbol Sell Instrume nt Sell Order Time Sell order Price Trade time Trade Quantity Trade Price 2022-09-13 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R GODREJCP Fut 13:06:48 949 13:37:04 1000 949 2022-09-13 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD | AAACV4306R GODREJCP Fut 13:06:48 949 13:37:06 1000 949 2022-09-13 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R GODREJCP Fut 13:06:48 949 13:37:06 1000 949 2022-09-13 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R GODREJCP Fut 13:07:21 949.2 13:37:56 3000 949.2 83.20 Transcript of 11th call at 13:12 PM on Sep 13, 2022 - Sell Side "Sanjiv Bhasin - Ek bech de GodrejCP 46.25 main Rajiv Kapoor - Lagaya hain par bika nahi Sanjiv Bhasin - Cancel kar de yaar Rajiv Kapoor - kar diya Sanjiv Bhasin - Ab 46.50 par la....
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....d and Lalit Bhasin, was aware of the modus operandi of the trades of Sanjiv Bhasin. Upon perusal of the trade log obtained from NSE, it is observed that Leo Portfolios had also traded in the scrip GODREJCP on September 13, 2022 and made profit. 83.25 A brief analysis of all the entities trades based on such advance information of recommendations given by Sanjiv Bhasin is given below: Table 91 Analysis of trades carried out by the entities in the scrip "GODREJCP" Date and Recommendation time - Sept 13, 2022, 13:35 (Contract- GODREJCP22SEPFUT) Client Name PAN Buy (First Leg) Sell (Second Leg) Gross Trd. Vol to Mkt Vol. Scrip Trd Val. to all scrips trd val. Profit Rs. Order Time Trade Time Buy Price range Traded Quantity Total Value Traded Rs. Order Time Trade Time Sell Price range Traded Quantity Total Value Traded Rs. Gemini Portfolios Private Limited AAACG4847Q 12:01 - 12:02 12:15 944.65 4000 3778400 14:14 14:14 949.20 4000 3796800 0.24% 33% 18400 Venus Portfolios Pvt Ltd AAACV4306R 10:36 - 13:54 10:36 - 14:14 943.65 - 949.20 16000 15158300 13:06 - 13:23 13:12 - 13:37 946 - 949.20 16000 15165850....
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....rder placement analysis, it is inferred that entities executed their trades aiming to capitalize on the price-volume movement in the scrip/contract GODREJCP as a result of the recommendation made on the show by Noticee No. 1. 89. Accordingly, a total profit of Rs.27,200 was made by Noticees namely Venus, Gemini and Leo in the scrip of GODREJCP. G. OTHER TRADES INVOLVING SIMILAR MODUS OPERANDI 90. On sample basis, similar analysis was carried out for more than 100 instances during the Investigation Period, where corroborative evidence similar to what is detailed in above five illustations are available, and it is found that the Noticee No. 1 along with other Noticees, employed similar strategy in these other instances too and made huge profits. In addition, it was seen that there are thousands of instances where the buy recommendations by the Noticee No. 1 on Media Channels/Telegram were preceded by buy trade in the accounts of profit makers/beneficiaries and succeeded by sell trades in such accounts. 91. For a detailed analysis of the matter involving huge number of trades done by Noticees during the IP, trades of the Noticee No. 1 in the trading accounts of profit makers/benef....
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.... Intraday Positional Intraday Positional Total trades Matching trades Total trades Matching trades Total trades Matching trades Total trades Matching trades Gemini Portfolios Private Limited 2.52 0.44 33.16 0.52 170.78 101.79 398.89 53.20 HB Stockholdings Limited 29.46 8.66 421.73 27.81 1,030.10 511.33 2,516.83 306.84 Venus Portfolios Pvt. Ltd 2.87 2.64 17.99 0.68 4,532.63 2,750.60 3,125.72 1,212.18 Leo Portfolios Private Limited 16.08 8.01 47.16 1.45 712.90 470.84 59.43 8.85 Babita Gupta 1.70 0.97 2.07 0.21 497.95 323.74 8.36 4.10 Ashish Kapur 2.63 0.14 49.61 1.87 466.78 314.12 19.25 4.23 Rajiv Kapoor 5.89 1.39 1.84 0.02 219.32 114.46 65.66 15.93 Jagat Singh 49.52 29.09 0.52 - 953.70 669.86 69.20 26.43 Total GTV 110.67 51.34 574.07 32.57 8,584.15 5,256.73 6,263.33 1,631.77 % of GTV of matching trades to Total GTV 46.39% 5.67% 61.24% 26.05% *Gross traded value (GTV) includes both buy value and sell value 94. On a perusal of the above table, the following can be seen w.r.t. the value of matching trades of Noticees: 94.1 Out of total GTV of Rs.110.67 Crores traded in cash segment on ....
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.... and HB Stock Holdings through Noticee Nos. 5 and 6, dealers of RRB Master. 99. Subsequently, he used to recommend majorly buy recommendations in certain scrips on TV Channels, which included those scrips in which he had already taken huge buy positions. Thereafter, contrary to his own buy recommendations given to the viewers en masse, he would give instructions to Noticee Nos. 5 and 6 to carry out opposite trades (sell). In his statement recorded under oath, the Noticee No. 1 admitted that he was giving daily stock recommendation either through IIFL daily Newsletter or by appearing in various business news channels on behalf of IIFL. Considering the huge viewership of the Media Channels and the stature of the Noticee No. 1 in the securities market, the recommendations of Sanjiv Bhasin created significant price/volume impact in the recommended scrips enabling Noticees to make profit by placing sell order contrary to the recommendations. Noticee Nos. 2, 3 and 4 100. The Noticee No. 2 acted as enabler and was also beneficiary of the alleged fraudulent scheme orchestrated by his cousin brother/ guest expert Sanjiv Bhasin/Noticee No. 1. The Noticee No. 2 was an Advisor of Venus and ....
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....us Portfolios Limited, Gemini Portfolios Limited, HB Stock Holdings Limited and RRB Master Securities Delhi Limited? A.7. I have met the authorized person; the details are below. 1. Venus Portfolios Limited- Mr. Raj Kumar Sharma and Mr. M.S. Sharma 2. Gemini Portfolios Limited- I don't recollect now 3. HB Stock Holdings Limited- Lalit Bhasin 4. RRB Master Securities Delhi Ltd- Ashish Kapur They were aware of me carrying out trades in the accounts of Venus and Gemini. Particularly, Mr. Ashish Kapur was also aware of carrying out trades by me in the accounts of Venus, Gemini and HB Stock." 104. From perusal of the statement of the Noticee No. 1, it can be inferred that Noticee Nos. 2 and 3 were aware of the trades being carried out in the accounts of Venus, Gemini and HB Stock. This strengthens the connection amongst the entities and their awareness of orders being placed in the trading accounts, as per the instructions of Noticee No.1. 105. W.r.t. the authority of the Noticee No. 1 for the trades being placed in trading accounts of the certain Profit Makers, the Noticee No. 3 submitted the following during his statement recorded under oath: "Q. In what authority, San....
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....ied out by the Noticee No. 1, the Noticee No. 5 in his statement recorded under oath on June 13, 2024 stated that Lalit Bhasin had instructed him to place orders as per instructions of the Noticee No. 1 and he merely followed instructions of Sanjiv Bhasin. He further stated that when he used to handle the account of Venus and place orders, following instructions of Sanjiv Bhasin, there would be approximately 30-40 calls from/to Sanjiv Bhasin on an average per day. The following statements of the Noticee No. 5 show that he was aware about the trading strategy of the Noticee No. 1 and used to follow his instructions. It can also be seen that the Noticee No. 5 has acknowledged that sometimes he placed orders in the same scrips for which he received instructions from the Noticee No. 1. "Q. 14 Do you know that Sanjiv Bhasin does BTST (Buy Today Sell Tomorrow) trades? (i.e.) he appears in news channels prior to pre market session and recommends the same scrips that he owns in the portfolio of VP and which he subsequently asks you to sell post recommendation. A. 14 Yes, I assume he is doing the same since the scrip he recommends spurts in volume post recommendation. As I am a dealer i....
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....97.99 56,31,985.01 17,32,352.70 88,14,561.90 2,42,37,798 4 Leo Portfolios Private Limited 44,668.75 1,23,895.38 4,56,368.60 59,40,600.25 65,65,533 5 Ashish Kapur 8,870.83 1,64,612.97 2,504.30 30,65,808.60 32,41,797 6 Babita Gupta -56,057.96 - 6,385.55 74,042.75 32,08,291.45 32,19,891 7 Jagat Singh - 1,30,430.70 - -5,04,704.65 85,79,095.55 89,53,370 8 Rajiv Kapoor - 2,59,948.00 1,125.00 95,476.00 16,97,194.70 15,33,848 Grand Total (in Rs.) 1,01,99,262 64,84,663 31,69,060 9,38,66,185 11,37,19,170 113. Out of the total trades carried out by Noticees, profit has been calculated only for matching trades discussed earlier at Part G of this order. On the basis of examination of matching trades vis-à-vis the recommendations made by the Noticee No. 1, the alleged ill-gotten gains have been calculated for cash segment and futures segment for positional trades and intraday trades. Only trades carried out on the NSE platform were considered for examination including calculation of alleged ill-gotten gains. It is seen form the above table that an amount of Rs.11,37,19,170/- was gained from these matching trades collectively carried ou....
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.... in the future segment. Date: July 28, 2023 Content: Sanjiv Bhasin texted Lalit Bhasin: "Got the new one" Inference: Upon sharing the MTOM sheet dated July 28, 2023 and highlighting the discrepancies to Lalit Bhasin, Sanjiv Bhasin informed Lalit Bhasin that he got the revised MTOM sheet. Date: July 28, 2023 Content: Lalit Bhasin texted Sanjiv Bhasin: "Ok great". Inference: Lalit Bhasin noted the Sanjiv Bhasin's confirmation of receiving revised MTOM sheet. 114.2 From the above WhatsApp Chats between Sanjiv Bhasin and Lalit Bhasin, it is inferred that there was maintenance of records of trades carried out/open position in FUTURES Contracts on a particular day along with Mark to Market value of such trades. 114.3 Sharing of Periodic Trade Sheet in Cash Segment: Investigation revealed that Sanjiv Bhasin kept account of details of trades carried out in the accounts of Venus, Gemini and HB in cash segment on periodic basis. Such trade details included the name of the scrips, trade prices and the amount of profit/loss earned on such trades. In this regard, certain images as extracted from the WhatsApp chats between Sanjiv Bhasin and Lalit Bhasin are produced belo....
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.... + 22.5 + 15 + 16 + 11.5 + 13.5 + 21.5 = Total 207.9) from LB (i.e. Lalit Bhasin) on several dates during the period from Jan 2022 to May 2024). Inference: Considering the period of investigation which is more than four years and the amount of turnover carried out in the accounts of Venus, Gemini and HB, the amount mentioned in the referred 'Notes' of Sanjiv Bhasin can be said to be in lacs and total amount received is Rs.207.9 Lacs from Lalit Bhasin during the period from Jan 2022 to May 2024. Since there is no evidence of bank transfer about the aforesaid transactions, it is inferred that such fund transfers would have been carried out through non-banking channels. 116. The aforesaid record of 'Notes' in the aforesaid table indicates that Sanjiv Bhasin had received funds on several dates during the period from Jan 2022 to May 2024 from Lalit Bhasin. 117. The succeeding paragraphs discuss about the evidence of meeting between Sanjiv Bhasin and Lalit Bhasin categorically on the dates on which funds were received by Sanjiv Bhasin from Lalit Bhasin. The details of meeting are discussed in the below table: Table 98 Images of meeting of Sanjiv Bhasin and Lalit Bhasin on regular ....
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.... meeting early. Date: Jan 09, 2024 Content: Sanjiv Bhasin texted Lalit Bhasin: "On my way.... kindly order 2 mushroom patties. " Inference: Sanjiv Bhasin again texted Lalit Bhasin that he was on the way and also asked him to order 2 mushroom patties. 3. Evidence of Meeting on Feb 26, 2024 As per the 'Notes' extracted from IPhone of Sanjiv Bhasin, it is observed that on this date, Sanjiv Bhasin had received amount of Rs.11.50 lacs from Lalit Bhasin. The following WhatsApp Chats exchanged between Sanjiv Bhasin and Lalit Bhasin indicates that they met on Feb 26,2024 at Connaught Place, Delhi. It is to be noted that registered offices of Venus, RRB Master and Leo are located at Connaught Place, New Delhi. Date: Feb 26, 2024 Content: Sanjiv Bhasin texted Lalit Bhasin: "Jai Mata Di.... See you around 6 in CP today evening." Inference: Sanjiv Bhasin asked Lalit Bhasin to meet at 06 PM at the CP (Connaught Place). Date: Feb 26, 2024 Content: Lalit Bhasin texted Sanjiv Bhasin - "JMD Yes" (JMD means ... "Jai Mata Di") Inference: Lalit Bhasin agreed with Sanjiv Bhasin's proposal to meet. 4. Evidence of Meeting on May 18, 2024 As per the 'Notes' extracted from IPhone....
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....e (d) of sub regulation (2) of regulation 4 of the PFUTP Regulations, and sub-regulation (2) of regulation 16 and sub-regulation (2) of regulation (21) of the RA Regulations. In case the answer to the above is in affirmative, it is to be examined whether the facts of the matter warrant an urgent action in exercising power bestowed under the provisions of section 11, section 11B of the SEBI Act and clause (d) of sub-regulation 1 of regulation 11 of the PFUTP Regulations. Before proceeding further, it is necessary to refer the relevant provisions of law which are reproduced here under for reference: "SEBI Act, 1992 Functions of Board. Section 11. (1) Subject to the provisions of this Act, it shall be the duty of the Board to protect the interests of investors in securities and to promote the development of, and to regulate the securities market, by such measures as it thinks fit. .... (4) Without prejudice to the provisions contained in sub-sections (1), (2), (2A) and (3) and section 11B, the Board may, by an order, for reasons to be recorded in writing, in the interests of investors or securities market, take any of the following measures, either pending investigation or....
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.... sections 15A, 15B, 15C, 15D, 15E, 15EA, 15EB, 15F, 15G, 15H, 15HA and 15HB after holding an inquiry in the prescribed manner. Prohibition of manipulative and deceptive devices, insider trading and substantial acquisition of securities or control Section 12A No person shall directly or indirectly- (a) use or employ, in connection with the issue, purchase or sale of any securities listed or proposed to be listed on a recognized stock exchange, any manipulative or deceptive device or contrivance in contravention of the provisions of this Act or the rules or the regulations made thereunder; (b) employ any device, scheme or artifice to defraud in connection with issue or dealing in securities which are listed or proposed to be listed on a recognised stock exchange; (c) engage in any act, practice, course of business which operates or would operate as fraud or deceit upon any person, in connection with the issue, dealing in securities which are listed or proposed to be listed on a recognised stock exchange, in contravention of the provisions of this Act or the rules or the regulations made thereunder .... (e) deal in securities while in possession of material or non-publ....
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....ealing in securities in order to induce another person or his agent to deal in securities, whether or not there is any wrongful gain or avoidance of any loss, and shall also include- (1) a knowing misrepresentation of the truth or concealment of material fact in order that another person may act to his detriment; (2) a suggestion as to a fact which is not true by one who does not believe it to be true; (3) an active concealment of a fact by a person having knowledge or belief of the fact; (4) a promise made without any intention of performing it; (5) a representation made in a reckless and careless manner whether it be true or false; (6) any such act or omission as any other law specifically declares to be fraudulent, (7) deceptive behaviour by a person depriving another of informed consent or full participation, (8) a false statement made without reasonable ground for believing it to be true. (9) the act of an issuer of securities giving out misinformation that affects the market price of the security, resulting in investors being effectively misled even though they did not rely on the statement itself or anything derived from it other than the market price. An....
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....g any person for dealing in any securities for artificially inflating, depressing, maintaining or causing fluctuation in the price of securities through any means including by paying, offering or agreeing to pay or offer any money or money's worth, directly or indirectly, to any person; Regulation 11 (1) The Board may, without prejudice to the provisions contained in sub-sections (1), (2), (2A) and (3) of section 11 and section 11B of the Act, by an order, for reasons to be recorded in writing, in the interests of investors and securities market, issue or take any of the following actions or directions, either pending investigation or enquiry or on completion of such investigation or enquiry, namely: - (a) suspend the trading of the security found to be or prima facie found to be involved in fraudulent and unfair trade practice in a recognized stock exchange; (b) restrain persons from accessing the securities market and prohibit any person associated with securities market to buy, sell or deal in securities; (c) suspend any office-bearer of any stock exchange or self-regulatory organization from holding such position; (d) impound and retain the proceeds or securitie....
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.... the provisions of regulations 16 and 17 shall apply mutatis mutandis to him and he shall disclose his name, registration status and details of financial interest in the subject company at the time of,- (i)making such recommendation or offering such opinion in personal capacity; (ii) responding to queries from audiences or journalists in personal capacity; (iii)communicating the research report or substance of the research report through the public media. SEBI (Intermediaries) Regulations, 2008 Definitions Regulation 2 .... (1)(b) "associate" means any person controlled, directly or indirectly, by the intermediary, or any person who controls, directly or indirectly, the intermediary, or any entity or person under common control with such intermediary, and where such intermediary is a natural person will include any relative of such intermediary and where such intermediary is a body corporate will include its group companies (as defined in the Monopolies and Restrictive Trade Practices Act, 1969 (Act No. 54 of 1969) or any re-enactment thereof) or companies under the same management;" 121. I note that clause (c) of sub-regulation (1) of regulation (2) of the PFUTP R....
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....ndermines the "integrity" and efficiency of the market." The facts of this case clearly show that Noticees devised a scheme to interfere in the ordinary operation of market forces of supply and demand to make unlawful gains for themselves and eventually succeeded in making alleged huge ill-gotten gains. Thus, this would prima facie qualify as manipulation and the scheme that they devised would qualify as a manipulative scheme. 124. Further, reliance is placed on the observations of Hon'ble Supreme Court in the matter of SEBI and Ors. vs. Shri Kanaiyalal Baldevbhai Patel and Ors. (2017 SCC Online SC 1148), wherein the following was held: "31. Although unfair trade practice has not been defined under the regulation, various other legislations in India have defined the concept of unfair trade practice in different contexts. A clear cut generalized definition of the 'unfair trade practice' may not be possible to be culled out from the aforesaid definitions. Broadly trade practice is unfair if the conduct undermines the ethical standards and good faith dealings between parties engaged in business transactions. It is to be noted that unfair trade practices are not subject to a single ....
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....o.1 has violated provisions of clauses (a), (b), (c) and (e) of Section 12A of the SEBI Act, r/w clauses (a), (b), (c) and (d) of Regulation 3, sub-regulation (1) of regulation (4), clause (d) of sub-regulation (2) of regulation (4) of the PFUTP Regulations. ii. Noticee Nos. 2 to 12 have violated provisions of clauses (a), (b), (c) and (e) of Section 12A of the SEBI Act, r/w clauses (a), (b), (c) and (d) of Regulation 3, and sub-regulation (1) of regulation (4) of the PFUTP Regulations. 128. It is imperative to note here that during the statement recording under oath, Noticee No. 1 submitted the following w.r.t. the capacity under which recommendations were being given by him on various news channels: "Q.2 How are you related to IIFL? A.2 I was appointed as Executive Vice President in year 2015 at IIFL. Subsequently, I was appointed as Director Equity Research in the year 2018-19. Thereafter, I was appointed as Consultant in the year 2022-23 till June 2024." "Q.3 Under what capacity you are recommending scrips? A.3 IIFL has been registered as Research Analyst and I my role at IIFL was to publish research reports and give daily stock recommendation either through IIFL dai....
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....g accounts. 132. As per Section 27 of the SEBI Act, any person who was in charge of or responsible to the company for the conduct of the business of the company shall be deemed to be guilty of this provision along with the company, and be held liable accordingly. It has been revealed during the investigation that other Directors in these companies viz. Venus and Gemini were namesake Directors and were not involved in the day-to-day management of affairs of these companies. 133. The Noticee No. 2 being the Advisor and major shareholder of these entities/companies was responsible for taking decisions in these companies. 134. In order to ascertain the liability of the persons responsible for the conduct of business of Noticee Nos. 4, 8, 9, 10 and 11, a table has been prepared below showing the details of directors/Persons who were in charge of, and were responsible to, the company for the conduct of its business during the Investigation Period and the role played by them: Table 99 Name Designation Whether Charged Rationale for charging or not charging the director Lalit Bhasin (Noticee No. 2) i. Advisor in Venus Portfolios Pvt. Ltd. and Gemini Portfolios Pvt. Ltd. ii. Direc....
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....tions. In view of the above, it is important to examine as to whether this would be a fit case wherein an interim ex-parte order would require to be passed. SEBI cannot remain a mute spectator when such kind of fraudulent and manipulative activities take place in the securities markets by personalities who are actually revered in the securities markets domain and have a huge following on various social media platforms. SEBI is required to take note when innocent and gullible investors invest huge corpus/amount of money based on ill intended recommendations of such experts, associated with Intermediaries registered with SEBI. What is more distressing to see is that such entities leave no stone unturned in making unlawful gains/profits at the cost of innocent investors. 136. SEBI has time again advised investors in the securities markets to remain diligent, attentive and exercise caution while believing anyone giving stock market recommendations associated with securities markets. Noticees herein are individuals who have been associated with securities markets for quite a long time. The Noticee No. 1 is Director/Consultant of IIFL, a registered SEBI intermediary. It has been shown w....
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....he securities market. In one of such cases, the Hon'ble Supreme Court, in the matter of N Narayanan vs. Adjudicating Officer, SEBI decided on April 26, 2013, while dealing with the concept of market abuse in securities market inter alia held as follows: "Prevention of market abuse and preservation of market integrity is the hallmark of Securities Law. Section 12A read with Regulations 3 and 4 of the Regulations 2003 essentially intended to preserve 'market integrity' and to prevent 'Market abuse'. The object of the SEBI Act is to protect the interest of investors in securities and to promote the development and to regulate the securities market, so as to promote orderly, healthy growth of securities market and to promote investors protection. Securities market is based on free and open access to information, the integrity of the market is predicated on the quality and the manner on which it is made available to market. 'Market abuse' impairs economic growth and erodes investor's confidence. Market abuse refers to the use of manipulative and deceptive devices, giving out incorrect or misleading information, so as to encourage investors to jump into conclusions, on wrong premises, ....
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....94 in the order which would need to be impounded to keep the integrity of the securities markets intact and to punish the wrongdoers for the same. The evidences collected during the investigation bring out the manner in which the unlawful gains have been amassed by the Noticees by placing trades contrary to the recommendations being given by the Noticee No. 1 on Media Channels. 145. It is worth noting that the Noticee No. 2 in his statement recording had mentioned earlier that it was decided to share the profits with Noticee No. 1, out of such trades as to be done on the recommendations of Noticee No. 1, in a ratio of 40:60. However, the same was not formalised and no fixed ratio had been fixed or arrived at. He further clarified that an agreement had been reached with Noticee No. 1 to ensure that the profits earned in these trading accounts would be retained in the respective trading accounts. In this backdrop, it becomes imperative to understand that in such intricately designed cases wherein the fraudulent activities are planned by the Noticees in such an immaculate and clandestine manner, identification of the actual trail of profits becomes a herculean task. As outlined herei....
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....of joint tort-feasors i.e. the liability that an individual or business either shares with other tort-feasor or bears individually without the others. Thus, joint tort-feasors are jointly and severally liable for the whole damage resulting from the tort. In assessing damages against joint tort-feasors or several tort-feasors causing same or indivisible damage, one set of damages will be fixed, and joint tort-feasors may be assessed according to the aggregate amount of the injury resulting from the common act or acts. The reason being is that where the cause of action is one and indivisible then all persons become liable jointly and severally." 148. In the facts of the present case, wherein, the Noticee No. 1 is the Mastermind of the manipulative/fraudulent scheme, and all other Noticees have played different roles in the scheme, they shall be held liable jointly and severally for impounding the unlawful gains made as per Table 100 above. Given the aforesaid peculiar facts and circumstances of the case and legal principles enunciated by Hon'ble SAT in a number of cases, I deem it appropriate to hold that Noticees shall be jointly and severally liable for the impounding of unlawful ....
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....l also be directed that no debit shall be made, without permission of SEBI, in respect of the demat accounts held by Noticees. However, credits, if any, into the accounts may be allowed. Further, this direction shall not apply to those demat accounts of the Noticee No. 4 which deal with clients' securities, since the Noticee No. 4 is a stock broker registered with SEBI and deals with securities of clients. vi. Banks and the Depositories are directed to ensure that all the aforesaid directions are strictly enforced and complied with. Further, debits in the bank accounts may also be allowed for amounts available in the account in excess of the amount to be impounded. Banks are allowed to debit the accounts for the purpose of complying with this Order. vii. The Registrar and Transfer Agents shall ensure that, they neither permit any transfer nor redemption of securities, including Mutual Funds units, held by Noticees. viii. Noticees shall not dispose of or alienate any of their assets/properties, till such time, the amount of unlawful gains is credited to fixed deposit account(s) except with the prior permission of SEBI. ix. Noticees are further directed to provide a full inve....