TaxTMI 
TaxTMI 
2026 (10) TMI 319
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....d/synchronized trading 79 F.5 Manipulation through cash segment activity of the same underlying 83 G. COMPUTATION OF WRONGFUL GAINS 86 H. CONSIDERATION OF ISSUES AND PRIMA FACIE FINDINGS 88 I. LIABILITY OF DIRECTORS OF PRRSAAR AND CHAUBARA 102 J. NEED FOR INTERIM ORDER IN THE MATTER 108 K. INTERIM ORDER 111 A. BACKGROUND 1. The present proceedings emanate from an internal analysis carried out by the National Stock Exchange of India Limited (hereinafter referred to as "NSE") and the Securities and Exchange Board of India (hereinafter referred to as "SEBI") highlighting abnormal trading pattern of one entity namely Prrsaar Sampada Private Limited (formerly known as Prrsaar Commodities Private Limited) (hereinafter referred to as "Prrsaar"/"Noticee No. 1"), registered with SEBI as a stock broker (Registration No. INZ000027432), as a Depository Participant (Registration No. 563-2021) and as a Research Analyst (Registration No. INH000020323) in the stock derivatives segment, wherein, the entity was alleged to be making abnormally high profit in stock options segment and loss in stock futures segment by doing manipulative acts. ....
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....re directors of Prrsaar, whereas, Ms. Saroj Gupta (hereinafter referred to as the "Saroj/Noticee No. 5") and Mr. Gaurav Tomar (hereinafter referred to as the "Gaurav/Noticee No. 6") are directors of Chaubara. 8. During the analysis of connection between Prrsaar and Chaubara, it was observed that Noticee Nos. 2, 3 and 5 had family relations and were related to each other as diagrammatically shown in the figure below: 9. Upon perusal of the Know Your Customer ("KYC") form submitted by the Noticee No. 3 for Reliance Mutual Fund, it was noted that one Mr. R **** G **** is spouse of Ms. Priti Gupta. Also, Ms. Priti Gupta is designated as a nominee of Mr. R **** G **** and vice-versa. In the KYC application form of Mr. R **** G **** submitted with MSB e-Trade Securities Limited, it was mentioned that the Noticee No. 2 is his father and the Noticee No. 5 is his mother. In view of the above, it is established that Ved Prakash Gupta/Noticee No. 2 (director of Prrsaar) is husband of Saroj Gupta/Noticee No. 5 (director of Chaubara) and further, Ms. Priti Gupta/Noticee No. 3 (another director of Prrsaar) is daughter- in-law of Noticee Nos. 2 and 5. 10. Further, Mr. Ved Prakash Gupta i....
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..... In this transaction, an option seller receives the option premium and is obligated to sell or buy an instrument at the strike price as per the option contract, if exercised by the option buyer. An option buyer pays a relatively small premium, known as leverage, for market exposure, in relation to the contract value. Due to this leverage, a trader can see large percentage gains from comparatively small, favourable percentage moves in the premium movement, margin and other expenses. 13. A futures contract and a combination of options contracts can provide the same economic exposure. The pay-off from the futures of a specific expiry day is same as the payoff from a combination of same strike price call option and put option expiring on the same day. A long call option combined with a short-put option replicates the payoff of a long futures contract. Such combinations are commonly referred to as synthetic futures positions, as they substantially provide the same economic exposure as actual futures contracts, before considering the option premiums. 14. For example, suppose the shares of a stock ABC are trading at Rs.100 and an investor buys a futures price Rs.102 expiring on a g....
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....le simultaneously executing trades in the corresponding stock futures contracts. Here, any artificial price movement induced in the futures segment may also affect the prices and valuation of the corresponding options contracts, enabling the participant to derive an economic benefit in the options segment through its price influenced by trading in the futures segment. This manipulation is different form arbitrage and hedging referred to in para 15. 18. The modus operandi typically involve the manipulator executing aggressive trades of substantial quantity in futures contract of a security at prices significantly above the Last Traded Price (hereinafter referred to as "LTP"), in case of buy trades, or below the LTP, in case of sell trades. Such trades artificially move the price of the futures contract and create an impression of buying demand (for buy trade), which leads to artificial price and valuation difference between said futures contracts and related options contracts and provide arbitrage opportunity. The uninformed market participants are deceived into assuming it to be genuine opportunity and trade in such stock derivative contracts. The manipulator then derives benefi....
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.... futures segment. E. MODUS OPERANDI ALLEGEDLY ADOPTED BY NOTICEES 22. In the instant case, it was observed during the examination that Noticees allegedly adopted the cross segment price manipulation practice using single stock futures and options. In view of the inter-linkage between the prices of futures contracts and options contracts, the aggressive net directional trades of futures contracts at prices away from the LTP had impacted prices of futures contracts, which, in turn also impacted the prices of options contracts of the scrip favourably, thereby, benefitting from trades executed in options segment by Noticees. 23. The brief of the strategy, wherein, Noticees traded in various time patches during the day, is as under: Step 1: Selecting the underlying security: i. The prima facie manipulative trading activity was carried out pre-dominantly in bottom 100 scrips in terms of market capitalization out of total of about 211 equity scrips at NSE that had equity derivatives segment, as of June 2026. The price of scrips that are having relatively lower market capitalization can be influenced with lower capital in comparison to those with higher market ca....
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....tively contributing to trade LTP in sell patches. ii. In buy time patch in futures, entity is net buyer in futures segment, buying substantial portion of market volume above LTP at the time of trade and contributed to the positive LTP, consequently resulting in rise in the price of the futures. iii. In view of the interlinkage between the price of stock futures and stock options, the premium of call options would increase and premium on put option would decrease. As a result, the orders placed by an entity to sell call options at a costlier rate or buy put options at a cheaper rate, would get executed. Thus, aggressive buy activity in stock futures segment benefitted the entity in the already positioned sentimentally bearish orders (at price higher than LTP) executed in stock options segment. iv. Similarly, in net futures sell time patch, the entity is noted to be selling huge quantities of futures contract forming substantial portion of market volume at price below the LTP at the time of trade and contributed to the negative LTP, consequently resulting in fall in the price of the futures. v. In view of the interlinkage between the price of stock....
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.... facie, the entities earned wrongful gains from their positions in Stock derivative segment, compared to the profit/loss they would have made otherwise. Such artificially created prices impacts other market players as well as impacts the integrity of the market. F. TRADING ACTIVITY OF NOTICEES DURING PRE-EXAMINATION AND EXAMINATION PERIOD 25. At this stage, it would be useful to look at the trading activities of Noticees. In this regard, it is observed that NSE vide letters dated February 06, 2026 and March 16, 2026 had sought trading rationale from Prrsaar for trading in the stock future contracts and taking significant positions in the options on the same stock. On this, Prrsaar had submitted their response vide letters dated February 13, 2026 and April 14, 2026 respectively. The response was examined and noted that it does not provide specific justifiable rationale for engaging in such manipulative trading activity. Subsequent to receipt of these letters from NSE, there was a significant drop in the GTV (i.e. gross buy + gross sell value in the given period) of stock options and stock futures of Prrsaar from March 2026, as compared with trading in the preceding two months,....
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....xamination Period 1: Examination period for Prrsaar (Oct. 2025- Feb. 2026) 11.22 40.10 4389.22 345.83 4786.36 Examination Period 2: Examination period for Chaubara (Mar. 2026 - June 2026) 47.15 40.24 566.94 49.55 703.88 Chaubara Pre -Examination period (Apr. - Sept. 2025) 243.12 20.70 718.71 6.64 987.08 Examination Period 1: Examination period for Prrsaar (Oct. 2025- Feb. 2026) 76.95 22.41 421.84 7.88 526.72 Examination Period 2: Examination period for Chaubara (Mar. 2026 - June 2026) 55.08 32.95 2657.55 205.62 2951.20 29. The trading pattern of Prrsaar and Chaubara from the above table indicates a sequential shift in trading activity in the stock futures and stock options segment during the Period 1 and Period 2 of the examination period, respectively. It is observed that Prrsaar was predominantly active in stock futures and stock options during the Period 1 of examination period (October 2025 to February 2026), while its trading activity in index futures and index options remained relatively unchange....
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.... period. 32. As noted from Table 2 above, it was observed that the trading activity of Prrsaar and Chaubara across exchanges was significantly concentrated in stock derivative segment in comparison to the index derivatives segment. Upon further examination of exchange-wise trading in the stock derivative segment, as tabulated below, it was noted that more than 98% of GTV of both the entities in stock options and stock futures was through NSE, with minuscule trading through BSE. Table 3 Entity Name and PAN Time period Across NSE and BSE Of which, Trading at NSE alone Stock Future Stock Option Stock Future Stock Option Prrsaar October, 2025 to June, 2026 24,219.13 1,929.96 24,213.85 (99%) 1,927.36(99%) Chaubara 12,937.98 874.06 12,739.40 (98.4%) 861.91(98.6%) 33. In view of the above trading concentration of GTV in both stock futures and stock option derivatives at NSE, further analysis of trading activity of the entities was focused towards trades executed by them at NSE alone at this stage which constituted about 99% of the total trades executed by them. 34. The profits made by entities during the examination peri....
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....xamination period was nearly 7 times the monthly net profit made during the pre-examination period. Further, in stock options segment alone, Chaubara made a profit of Rs.18.74 crore, vis-à-vis Rs.0.2 crore made during pre- examination period April 2025 to September 2025, which is nearly 93.7 times the monthly profit made in pre-examination period. 37. The total net profit made by both Prrsaar and Chaubara together in stock derivatives segment increased from Rs.4.07 crore during the pre-examination period to Rs.12.53 crore during the examination period. Thus, they made substantial net profits during the examination period vis-à-vis the pre- examination period. In addition to the above, net to gross square-off difference were computed in NSE's stock futures and option segment for each entity during the examination period, as summarized below: Table 5 Entity Instrument type Gross square off profit (in Rs. Crs.) Gross square off loss (in Rs. Crs.) Net square off profit / loss (in Rs. Crs.) Prrsaar Sampada Private Limited (for period October 2025 to February 2026) Stock Futures 2.14 -47.18 -45.04 S....
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....ve been computed considering no. of trade days * no. of unique underlying security's derivative contracts traded. ● Contract level profit aggregated for the respective period. 40. As noted from the table above, out of the total scrip days, where Noticees traded in the stock derivatives segment, they traded in both stock futures & options segments of the same underlying in approximately 10% instances for Prrsaar and 18% instances for Chaubara. The total profit made by entities by simultaneously trading in both the segments of stock futures & options of the same underlying such that the entity made losses in futures and profits in options segment amounted to major portion of total profit (viz. 90% for Prrsaar and 55% for Chaubara) in NSE's equity stock derivative segment during the examination period. 41. Here, out of the total scrip days, entities made profit in stock options segment & simultaneously made loss in stock futures segment through simultaneous trading in the stock futures and options of the same underlying in 256 scrips days for Prrsaar and 140 scrip days for Chaubara. Upon combining both segments, Prrsaar made net profit of Rs.13.03 crores on 1....
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....03, 2025, when Prrsaar was noted to be trading in the futures and options contracts of KFINTECH, the price of the underlying security & its near-month futures contract had moved nearly 1% as noted under: Table 7 Security / Contract Date 03-Dec- 25 Open High Low Close High to low % change Open to close % change Volume KFINTECH - Cash segment 1,083.80 1,095.00 1,064.00 1,071.40 2.8% 1% 13,37,298 KFINTECH - 30-Dec- 2025 - FF - 0 1088.50 1102.00 1067.70 1077.60 3.1% 1 % 23,30,550 47. On the given day, the entity was noted to be trading in stock futures and stock options segments during the time-patch between 09:15:18 to 10:33:56 (i.e. for 01 hour and 19 minutes), with no trades in the underlying scrip's cash segment. Contract wise summary of the trading activity, trading concentration to total market trades and intraday square-off profit in derivative contracts of KFINTECH on December 03, 2025 by Prrsaar is as under: Table 8 Contract (Underlying stock - Expiry - Instrument - Strike Price) Buy Sell Total Market Traded Quantity across the day % to Market Concentration ....
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....(viz. 23.30 lakhs) of the contract throughout the day and about 26% of the total market volume (viz. 17.34 lakhs) during the time patch when the entity was trading in the given stock derivative contracts, as tabulated in the table below. 49. There is another KFINTECH's middle month expiry stock futures contract- 27- Jan-2026-FF contracts, where the entity traded in the given time and made a square off profit of Rs.8.68 lakhs in the given contract. It is pertinent to note here that the trading activity in this contract is in opposite direction to that of the activity in December expiry futures. While entity was aggressively selling in futures contracts expiring in near-month (December futures) at a lower price, the entity was simultaneously accumulating futures contracts expiring in the middle month (January futures). Similarly, when entity was aggressively buying at higher prices in near-month futures (December futures), the entity was selling in middle-month futures contract. The activity in the middle-month futures contract was carried out, prima facie with the intention to mislead the surveillance mechanisms. 50. Simultaneously, in the same time patch as KFINTECH's....
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....ectionally on one side and then switching to other side during the day. Since the buying and selling of futures contracts were in different time intervals, these intervals were segregated into distinct time patches. 53. Coinciding with the trading activity in stock futures contracts, Prrsaar was noted to be trading in stock options contracts of KFINTECH, however, prima facie sentimentally opposite positions were being taken in the options contracts. The patch wise summary of trading activity of 01 hour and 19 minutes, segregated into 6 different time patches, along-with smaller portion of trading in single segment, is as follows: Table 9 Pat ch No. Patch Time Type of patch Futures Market One sided traded quantity Market conc. in futures Call Options Put Options Market concentration in Options in value terms* Net Qty. in Futures Net delta position in options segment Ratio of Net delta/ Net qty. in Futures Buy Qty. Sell Qty. Buy Qty. Sell Qty. Buy Qty. Sell Qty. &....
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....the Futures & options contracts of KFINTECH as per the aforesaid 6 patches: 55. On a perusal of the above table and the graphical representation, it is observed that the entity had significant volume concentration when compared to total traded quantity of the market in the futures segment. The volume contribution of Prrsaar ranged from 35.1% to 55.7% in each of these patches in the futures segment, which indicates that the entity had maintained a dominant position in KFintech's concerned futures contracts in the given time patch. 56. Similarly, it had significant volume concentration in the options segment when compared to total traded quantity of the market in options segment. The volume contribution in terms of value by the entity ranged from 34.78% to 53.34% in each of these patches, which indicates that the entity had maintained dominant position in KFintech's concerned options contracts in the given time patch. 57. It was observed that during the time patches between 09:15:18 to 10:33:56 majority of its trades in futures and options contracts were in opposite directions, i.e. whenever the entity was exhibiting bullish sentiment in options segment by placing or....
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....e than twice compared to the positions taken in futures contracts. For example, in patch 1 i.e. during 09:15:18 to 09:19:49, entity had net delta position in futures of -44,450 (delta of futures being 1) while there was net delta in options segment of +1,68,262. As such, the ratio of delta in options contracts to that of net delta in futures segment was opposite by nearly 3.79 times. 61. The significantly larger position in options in delta terms relative to the futures exposure demonstrates that the futures position was not intended to reflect the entity's actual market view, nor it was used for hedging the options positions. Instead, such trading pattern suggests that the entity retained its principal economic exposure in the Options segment while using comparatively smaller Futures positions to influence derivative prices as a part of larger manipulative strategy. LTP Variation in Futures Contract Expiring on December 30, 2025: 62. To understand the intent behind entity's trading in KFINTECH futures contract on December 03, 2025, order and trade-level LTP analysis was further carried out. Detailed LTP analysis of variation between order price and LTP at the time....
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....reby, voluntarily executing at the adverse price. This prima facie indicated that immediate profit in the futures segment was not the primary objective of the entity and rather it was willing to incur losses in futures segment in order to achieve higher economic benefit in options segment. 66. To ascertain the impact of the directional trading activity of the entity on movement in price of the scrip, trade price and LTP at the time of trade were analysed. The LTP contributed by the entity through its trading activity in stock futures expiring in December 2025 and January 2026 were considered. The summary of patch wise trade LTP variation in the December and January Futures Contract of KFINTECH is as under: Table 11 Buy-side Sell-side Patch Start Time End Time Entity's Negative LTP contribution Entity's Positive LTP contribution Entity's Net LTP contribution Market Positive LTP Entity's positive LTP Contribution % to market positive LTP Entity's Negative LTP contribution Entity's Positive LTP contribution Entity's Net LTP....
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....n price in each of the patches. ii. The cumulative trade LTP variation attributable to the entity was a positive Rs.106.50 out of a total of Rs.264.3 i.e. about 40% of the market positive LTP during buy-side patches and a negative Rs.-142.20 out of a total of Rs.-405.60 i.e. about 35% of the market negative LTP during sell-side patches. iii. Such trades contributed significantly to market LTP variation such that in buy patch, entity's buy trades positively influenced the LTP in the range of 38%-43.6% of total positive LTP movement in the given individual patches and in sell patch, its sell trades negatively influenced the LTP in the range of 24.09% to 41.2% of total negative LTP movement in the given individual patches. iv. As such, in entity's buy patches, by buying huge quantity of futures contract at higher prices in comparison to last traded prices in the futures contract, the entity's buy orders resulted in positively influencing the trade price of the futures contract. Similarly, in entity's sell patches, by selling huge quantity of futures contracts at lower prices in comparison to prevailing traded prices, its sell orders resulted ....
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.... (iv) the corresponding options orders obtained favourable execution immediately thereafter; and (v) the inexecutable futures orders were subsequently cancelled. Demonstration of such repeated sequencing would indicate a structured trading strategy rather than independent trading decisions. Analysis of sample patch 4 74. In Patch 4, (i.e. from 09:46:40 to 10:02:16), entity bought net 1,76,700 futures contracts (i.e. indicating bullish sentiment in futures). On the other hand, entity sold 6,02,550 call options contracts and bought 4,72,950 put option contracts (i.e. indicating bearish sentiment in options), while also buying comparatively smaller quantities of call options contracts and selling smaller quantities of put options contracts, such that at the end of the patch 4, the entity had a net delta position of negative 5,09,684 in options contracts. 75. While the entity had multiple order-level and trade-level activity in various futures and options contracts during the said time patch, for illustration purpose, analysis was undertaken for orders entered in the KFINTECH near-month futures contract and the KFINTECH 1100-strike Call Option contract (bot....
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....rder to artificially increase the price, to show sudden interest in the security and thereby deceive gullible investors. Orders Executed 4 Future Buy Above LTP The futures buy order at step 3 is immediately executed at price above LTP 5 Call Option Sell Above LTP Pursuant to upwards movement in futures price, the price of call options moved upward and sell orders in sequence 2 got executed at a favourable price. Orders Cancelled 6 Future Buy Below LTP Buy orders below LTP which were placed at Step 1 to create artificial demand were cancelled after achieving desired result of execution of sell trades in options segment at higher price. 79. Step-wise illustration of sample orders is placed below: Table 14 Contract (Expiry Dec 30, 2025) Step Order Time Order No. Order Limit Price (In Rs.) LTP prior to Order Entry (Rs.) Order Qty. Diff. in Order price & LTP at order entry (In Rs.) Total pending buy order qty. of entity Total buy side depth of market % of total pending buy order of entity w.r.t. market depth F....
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....TP of Rs.1087.60. At the time of order entry, this order accounted for 12% of the total buy-side market depth in the contract and entity's total pending buy orders accounted for 30% of the total buy-side market depth in the contract. ii. Thereafter, the entity placed 3 other fully disclosed orders (order nos. 2200000013521836, 2200000013537154 and 220000001379219) of 450 quantities each, at limit price Rs.1087.5- 1087.6 below or at the prevailing LTP in near month futures contract. iii. Since most of these orders were placed below the LTP, the same could not be executed and remained pending in the order book, which contributed in visible increase in buying interest (i.e. depth on the buy side) of the futures contract without the execution risk. These were placed to show artificial demand as these were not intended to be traded. Step 2(a) iv. Thereafter, at 09:48:55 hours, the entity first placed 11 sell orders for total of 5,850 contracts in the 1100-strike Call Option at a limit price in the range of Rs.29.65 to Rs.30.25, which was Rs.0.15 to Rs.0.75 above the prevailing LTP of Rs.29.50. Given that order price of such sell orders in....
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....xecuted at Rs.1091. These trades resulted in price spike in futures segment and positively contributed to the LTP by Rs.2.50. It prima facie appears that such price spike had been created with an intention to artificially influence the price of futures contract and to give a signal of buying interest among investors. The rise in futures prices impacted the prices of options due to price interlinkage between the two segments. Step 5 viii. After the trades in stock futures got executed above the LTP in step 4, the call option sell orders immediately got executed as a result of trades in the futures segment in step 4. In this manner, the entity achieved complete execution of its sell orders of call options at prices above the LTP. The entire quantity of 25,650 of sell call options contracts was executed at the price range of Rs.29.25 to 30.15 across 15 trades concluding by 09:50:08. ix. It is pertinent to add that while order price of one of the sell orders (order no. 2300000018681549) in call options was placed below LTP at the time of order placement; however, on account of aggressive trades in futures segment, a huge demand was created in options segment ....
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....t had been placed far below the LTP prima facie without the intention of execution had contributed visible buy-side depth to the futures order book throughout the material period, were withdrawn/cancelled once they had served the purpose of depicting artificial demand in the market. 85. The cancellation immediately after execution of the corresponding options trades prima facie indicates that the orders were not intended for execution but were maintained only during the period relevant for the entity's trading strategy, thereby contributing visible buying interest in the segment while facilitating the execution of the options positions. Such big orders on buy side were cancelled prior to the creation of the selling interest in the next patch by entity. The sequence of events in the sub-patch as discussed above, is shown below: 86. In this manner during the patch 4 i.e. between 09:46:40 to 10:02:16, following orders were placed by the entity: Table 17 Futures Buy-side Order type Order Time Range No. of Orders Total Quantity % Order Qty. placed at LTP % Order Qty. placed below LTP % Order Qty. placed above LTP ....
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....ions and net buy of 4,54,500 contracts in put options, exhibiting bearish sentiment. The trade price of maximum call options sold was at or above the LTP at the time of trade and further, the trade price of maximum put options bought was below or at the LTP at the time of trade which had prima facie been possible due to the execution of orders by the entity in the futures segment. Execution of trades in options contract at a favourable price had prima facie been possible due to the execution of aggressive and manipulative trades of in the stock futures segment. Analysis of sample patch 5 90. During patch 5, (i.e. from 10:02:17 to 10:26:10), entity sold net 2,66,900 futures contracts (i.e. indicating bearish sentiment in futures). In options segment, entity bought 6,01,650 call option contracts and sold 5,37,750 put option contracts (i.e. indicating bullish sentiment in options), while also buying comparatively smaller quantities of put options contracts and selling smaller quantities of call options contracts, such that the entity had a net delta position of 5,22,694 contracts in options. 91. While the entity had multiple order-level and trade-level activity in various fut....
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....nterest in scrip is increased. Certain orders are intentionally placed below LTP in order to benefit from the subsequent fall in price of futures. 3 Future Sell Below LTP Sell orders are placed below LTP, in order to artificially decrease the price, to show high supply in the security and thereby deceive gullible investors. Orders Executed 4 Future Sell Below LTP The futures sell order at step 3 is immediately executed at price below LTP 5 Call Option Buy Below LTP Pursuant to downward movement in futures price, the price of call options moved downward and buy orders in sequence 2 got executed at a favourable price Orders Cancelled 6 Future Sell Above LTP Sell orders above LTP which were placed at Step 1 to create artificial supply were cancelled after achieving desired result of execution of Buy trades in call options at lower price. 95. Step-wise illustration of sample orders and the sequential order of events during the sub-patch are as under: Table 20 Contract (Expiry Dec 30, 2025) Step Order Time Order No. Order....
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....in the price range of Rs.1074 to Rs.1085.3, at price (-)Rs.4.4 to (+)Rs.1.1. away from the sell order LTP, of which 33 orders of 84, 150 qty. got executed. Maximum of these executed orders were placed aggressively below LTP or at LTP. Also, few order were cancelled. Step 2 iii. Thereafter, at 10:20:06 hours, the entity placed three buy orders (order no. 2300000033011587, 2300000033011752, 2300000033011753) for total 45,450 quantities in the 1080-strike Call Option contracts at a limit price of Rs.34.90, below the prevailing option LTP of Rs.35.00. Given that order price of such buy order was lower than the prevailing LTP, this significant volume of buy order rested in the order book of the options contract. Step 3 iv. Subsequently, one second later, at 10:20:07 hours, the entity entered another sell order of same futures contract (order no. 2200000024957114) for 18,450 quantities at a limit price of Rs.1073.50, i.e., Rs.3.70 below the prevailing LTP of Rs.1077.20. At the time of order entry, the said order accounted for 6% of the total sell-side market depth in the contract and total pending sell orders increased to 37% of the total sell-side mar....
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....0:07 hours in a total elapsed time of approximately 2 milliseconds viz. lower than LTP of Rs.35.00 at the time of order entry and LTP of Rs.34.95 at the time of trade execution. 99. Thus, the sell activity in the futures segment coincided with buy activity in the options segment. The execution of aggressive sell trades in futures segment led to downward movement in the futures price that increased selling interest in the Call Option, among the gullible market participants, and thereby resulting in near-instantaneous execution of pre-positioned call options buy orders at a cheaper rate. As such, the artificial price movement by the entity in futures segment benefited it to create position in options segment at a favourable price. 100. The trading sequence observed in patch 5 mirrors the sequence identified in patch 4, on the opposite side of the order book. In patch 5, the entity first created pending long position option orders and thereafter executed aggressive futures sell trades to first move prices downward, obtaining favourable execution of its pending buy order in options contract at a lower price, almost immediately thereafter, and finally cancelling the inexecutable f....
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.... Sell-Fully executed 10:03:36 10:25:55 125 3,01,850 2.09% 86.70% 11.21% Sell-Partially executed 10:03:36 10:19:48 2 20,700 100.00% 0.00% 0.00% Sell-fully cancelled 10:03:36 10:25:47 186 1,59,650 1.50% 6.51% 91.98% Total 313 4,82,200 Note: 1. Data pertains to original order volumes. 2. Spread Order and Market Order were not considered for the above data. 103. As seen from the above table, during patch 5, the entity placed a total of 313 sell orders for a total of 4,82,200 quantities in futures contract. In case of 125 fully executed orders with a total 3,01,850 qty., 87% orders were placed below LTP. This helped to achieve instant execution and move the price artificially towards desired downward direction, to benefit the entity in options segment. Further, in case of 2 partially executed orders with a total 20,700 qty., 100% orders were placed at LTP. Whereas, 186 orders with a total 1,59,650 quantities in futures....
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....ers in call options and placing buy orders in put options), it was observed to be bullish in futures contracts by placing aggressive buy orders above the LTP, such that the price manipulated by the entity in futures segment in upward direction led to favourable execution of pending orders in options segment. 108. On the other hand, whenever the entity was exhibiting sentimentally bullish position in options (i.e. placing buy orders in call options and placing sell orders in put options), it was observed to be bearish in futures contracts by placing aggressive sell orders below the LTP, such that the price manipulated by the entity in futures segment in downward direction led to favourable execution of pending orders in options segment. 109. Considering the relationship between futures & options prices, when an entity is aggressively buying stock futures at a higher price, the entity is able to sell call options and buy put options, at a favourable price. Similarly, when an entity is aggressively selling stock futures at a lower price, the entity is able to buy call options and sell put options, at a favourable price. The patch-wise earning in each contract highlights that the....
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....l price of Rs.41.57). Overall, through the prima facie manipulative activity in futures, Prrsaar made a total profit of Rs.27,25,808 in the mentioned options contract by trading on December 03, 2025. 111. Similarly, for KFINTECH 1100 CE, in every patch, Prrsaar bought at a lower price (i.e. average buy price of Rs.25.90) and subsequently in the next patches, sold at a higher price (i.e. average sell price of Rs.30.57). Overall, through the prima facie manipulative activity in futures, Prrsaar made a total profit of Rs.25,46,978 in the mentioned options contract by trading on December 03, 2025. 112. It was also observed that in each of the patches, the net delta of options was much higher in comparison to that of the activity in futures, such that trades in futures segment influenced prices, and benefited the entity in options segment. The pattern discussed above prima facie demonstrates a consistent trading sequence across all six patches in the futures and options segments. In each instance, the entity first established economically significant positions in the options segment, thereafter, executed aggressive futures trades at prices adverse to its own economic interest (i.e....
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....r and 03 minutes), with no trades in the underlying scrip's cash segment. Contract wise summary of the trading activity, trading concentration to total market trades and intraday square-off profit in derivative contracts of Swiggy on June 16, 2026 by Chaubara is as under: Table 27 Contract (Underlying stock - Expiry - Instrument - Strike Price) Buy Sell Total Market Traded Quantity % to Market Concentration of given contract Net square-off difference (in Rs.Lakhs) Quantity Value (in Rs.lakhs) Quantity Value (in Rs.lakhs) Futures SWIGGY-30-Jun-2026- FF-0 24,84,300 6525.26 24,84,300 6477.41 1,13,37,300 21.91 (48.45) Total 24,84,300 6525.26 24,84,300 6477.41 1,13,37,300 21.91 (48.45) Options SWIGGY-30-Jun-2026- CE-260 39,09,100 299.67 39,09,100 319.03 ....
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....option contracts of SWIGGY, the entity made significant square off profit of about Rs.60.98 lakhs in a single scrip day. Similar to its trading in the futures segment, trading activity of the entity in options segment was concentrated between 11:07:44 to 12:11:09 (i.e. for 01 hour and 03 minutes) during the entire day, which accounted for 3.7%-41.27% of the total trading volume of each of these contract throughout the day. 121. Prima facie, the trading activity indicates that the entity was not independently trading in the futures contracts with the objective of earning profits from this segment. Rather, the entity prima facie appears to have used the futures segment as a means to influence the prices of derivative contracts while retaining its principal economic exposure in the options segment. This is evident from the fact that although Chaubara incurred a square-off loss of Rs.48.45 lakh in the futures contract, simultaneously in the same time patch, Chaubara earned profits of about Rs.60.98 lakh in the options segment, resulting in an overall profit of Rs.12.53 lakh. Such a trading pattern prima facie lacks commercial rationale if the futures trades are viewed in isolation. ....
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.... Futures Buy 3,61,400 5,07,000 71.28% 10,400 18,25,200 13,46,800 - 64.5% 3,61,400 -1,606,949.99 -4.45 3 11:17:05 to 11:32:50 Futures Sell 8,56,700 11,29,700 75.83% 16,14,600 1,80,700 2,600 15,26,200 45.7% -8,56,700 15,22,191.35 -1.78 4 11:32:58 to 11:38:10 Futures Buy 4,66,700 6,26,600 74.48% 7,800 12,03,800 13,44,200 2,600 59.9% 4,66,700 -14,07,530.58 -3.02 5 11:38:22 to 11:45:09 Futures Sell 18,200 5,55,100 7,44,900 74.52% 15,27,500 - - 13,66,300 58.6% -536,900 16,06,003.54 -2.99 6 11:45:14 to 11:46:42 Futures Buy 3,38,000 4,78,400 70.65% - 13,57,200 8,58,000 - 70.1% 3,38,000 -12,73,119.43 -3.77 7 11:47:34 to 11:51:39 Futures Sell 4,32,900 6,00,600 72.08% 14,57,300 ....
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....ich indicates that the entity had maintained dominant position in Swiggy's concerned futures contracts in the given time patch. Similarly, it also had significant volume concentration when compared to the total traded quantity of the market in the options segment. The volume contribution of the entity ranged from 45.7% to 70.15% in each of these patches, which indicates that the entity had maintained dominant position in Swiggy's concerned options contracts in the given time patch. 127. It is further observed that during the time patches from 11:07:44 to 12:11:09, majority of its trades in futures and options contracts were in sentimentally opposite directions and the entity exhibited similar trading pattern as that of Prrsaar as seen in the foregoing paragraphs, i.e. whenever the entity was exhibiting bullish sentiment in options segment by placing orders for buying call options below the LTP and selling put options above the LTP, it was prima facie observed that the entity was bearish in futures segment by placing aggressive sell orders below the LTP. For instance, in Patch 1 i.e. from 11:07:44 to 11:11:04, the entity sold 1,62,500 qty. of futures contracts (i.e. exhib....
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....that the futures position was not intended to reflect the entity's actual market view, nor was it being used for hedging the options positions exposure. Instead, such trading pattern prima facie suggests that the entity retained its principal economic exposure in the options segment while using comparatively smaller futures positions to prima facie influence derivative prices as a part of a larger manipulative strategy. LTP variation in Futures Contract expiring on June 30, 2026 131. To understand intent behind entity's trading in SWIGGY futures contract on June 16, 2026, order and trade-level LTP analysis was further carried out. Detailed LTP analysis of variation between order and trade LTP at the time of order placement was carried out for the orders which were fully executed by the entity in SWIGGY futures expiring on June 30, 2026. On the buy side, a total of 23,50,400 qty. of futures contracts were fully executed and on sell side, a total of 24,11,500 qty. of futures contracts were fully executed. Herein, given that fully executed orders constituted in the range of 94% (on buy side) and 97% (on sell side) of the total trades executed by the entity, detailed LTP ....
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....t in price of the scrip, trade price and the LTP at the time of trade were analysed. The LTP contributed by the entity through its trading activity in stock futures were considered. The summary of patch wise trade LTP variation in the June futures contract of SWIGGY is as under: Table 30 Buy-side Sell-side Patch Start Time End Time Entity's Negative LTP contribution Entity's Positive LTP contribution Entity's Net LTP contribution Market Positive LTP Entity's LTP Contribution to positive LTP Entity's Negative LTP contribution Entity's Positive LTP contribution Entity's Net LTP contribution Market Negative LTP Entity's LTP Contribution to negative LTP 1 - SELL 11:07:44 11:11:04 - - 4.5 0.00% -1.8 0.65 -1.15 -5.3 33.96% 2 - BUY 11:11:46 11:16:48 -0.6 4.95 4.35 10.5 47.14% - - 0 -5.75 0.00% 3 - SELL 11:17:05 11:32:50 - - - 16.8 0.....
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....e had following impact on the market: i. While trading in futures segment Chaubara was not only noted to be having volume concentration, but also is noted to be significantly contributing to movement in price in each of the patches. ii. The cumulative trade LTP variation attributable to the entity was a positive Rs.24.45 out of a total of Rs.102.70 i.e. about 23.81% of market positive LTP during buy-side patches and a negative Rs.23.60 out of a total of negative Rs.89.70 i.e. about 26.31% of market negative LTP during sell-side patches. iii. Such trades contributed significantly to market LTP variation such that in buy patch, entity's buy trades positively influenced LTP in the range of 31.37% to 54.59% of total positive LTP movement in the given individual patches and in sell patch, its sell trades negatively influenced the LTP in the range of 23.68% to 56.13% of total negative LTP movement in the given individual patches. iv. As such, in entity's buy patches, by buying huge quantity of future contracts at higher prices in comparison to prevailing traded prices in the futures contract, the entity's buy orders have resulted in positiv....
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....ng comparatively smaller quantities of put options contracts and selling smaller quantities of call options contracts such that at the end of patch 3, the entity had a net delta position of positive 15,22,191 qty. in option contracts. 143. While the entity had multiple order-level and trade-level activity in various option contracts during the said time patch, for illustration purpose, analysis was undertaken in the SWIGGY near-month futures contract and SWIGGY 260-strike Call Option contract (both expiring on June 30, 2026), where the entity was having highest GTV in the given analysed sub patch. The price movement of SWIGGY near-month futures contract and SWIGGY 260-strike Call Option contract (both expiring on June 30, 2026) in patch 3 (i.e. from 11:17:05 to 11:32:50) is provided below in a chart along-with trades executed by Chaubara in these contract and price at which these trades were executed: 144. The above highlights that: i. Price of SWIGGY near-month futures contract and SWIGGY 260-strike Call Option contract (both expiring on June 30, 2026) are moving in tandem; ii. The entity is selling futures and simultaneously buying options contracts; and ....
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.... options at lower price. Orders entered 147. The sequential order of events observed to be carried out during the sub-patch are as under: Table 33 Contract Step Order Time Order No. Order Limit Price (Rs.) LTP prior to Order Entry (Rs.) Order Qty. Diff. in Order price & LTP at order entry (Rs.) Total Disclosed Sell Qty. of Entity at the time of Order Entry Total sell side depth of market % of total pending sell order of entity w.r.t. market depth Futures Sell (viz. cancelled later) 1 11:22:39 21000000 73589806 260.50 259.75 91,000 0.75 6,37,000 13,55,900 47.0% 11:23:44 (Order Modified) 21000000 73589806 261.00 259.75 91,000 1.25 - - Other sell orders 11:22:39 to 11:24:40 24 other sell orders 259.7 to 260.5 259.75 to 260 79300 - 0.05 to 0.75 5,47,300 to 6,85,100 12,55,800 to 1,40,660 CE 260 Buy 2 11:24:44 21000000 74449846 7.25 7.35 91,000 -0.10 - ....
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.... sell-side market depth in the contract and total pending sell orders increased to 48% of the total sell-side market depth in the contract, highlighting entity's dominance in the concerned contract. Further, given that sell orders were placed at lower than the prevailing price, they will get priority over the existing pending sell orders and would execute immediately. Orders executed 149. Pursuant to steps 2 & 3, following orders got traded at the given trade price: Table 34 Contract Step Trade Time Order No. Trade Price (In Rs.) LTP prior to Trade execution (Rs.) Trade Quantity Trade LTP (In Rs.) (Expiry June 30, 2026) Futures Sell 4 11:24:44 2100000074451902 259.40- 260.00 260.15 91,000 -0.75 CE -260 Buy 5 11:24:44 2100000074449846 7.25 7.25 - 7.40 91,000 -0.20 150. From the above table, the following is prima facie noted: Step 4 vi. Since the last futures sell order (order no. 2100000074451902) was aggressive order placed....
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....ly influenced market prices, enabling execution of its pending buy order in options contract at a lower price. The futures trades, therefore, prima facie appear to have functioned as the mechanism through which favourable execution was achieved in the options segment. Cancellation of remaining futures orders Table 35 Contract Step Order Cancellation Time Order No. Order Limit Price (Rs.) LTP prior to Order Entry (Rs.) Cancelled Quantity Order LTP Variation (In Rs.) Future Sell 6 11:24:45 2100000073589806 261.00 259.75 91,000 1.25 Step 6 ix. At 11:24:45 hours, i.e., approximately one minute after the aforesaid executions of orders in both futures and options segments towards the close of sub-patch, the entity cancelled the first futures sell order (Order No. 2100000073589806) in full. The entire quantity of 91,000 in futures contract was cancelled without a single quantity being executed. x. Thus, a sell order, that had been placed above the prevailing LTP prima facie without the intention of executing it had contributed visible sell-side depth to the futu....
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....atch, when the entity achieved its desired purpose. 156. As a whole, after including market orders (5200 qty.), the above sell orders led to execution of 8,56,700 qty. of futures contract, viz. 75.8% to the market volume (11,29,700 contracts) in futures contracts during the given time-patch. Through these trades the net LTP contribution of the entity was negative to the extent of Rs.3.75. The entity's total negative LTP contribution was Rs.7.6 out of Rs.14.85 of market negative LTP, i.e. entity contributed nearly 51.18% of market total negative LTP during the given time patch. Simultaneously, in the same time-patch, the entity executed and bought net 14,33,900 contracts in call options and sold net 15,23,600 contracts in put options, exhibiting bullish sentiment. The trade price of maximum call options bought was at or below the LTP at the time of trade and the trade price of maximum put options sold was above or at the LTP at the time of trade. Execution of trades in options contract at a favourable price had prima facie been possible due to the execution of aggressive and manipulative trades of the entity in the stock futures. Activity across the day 157. A similar t....
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....026 6 - 6,34,400 58,08,790 9.16 SWIGGY - CE - 260 - 30-Jun-2026 7 7,03,300 61,74,090 8.78 - SWIGGY - CE - 260 - 30-Jun-2026 8 - 5,59,000 50,71,040 9.07 SWIGGY - CE - 260 - 30-Jun-2026 9 1,80,700 14,99,810 8.30 1,300 11,505 8.85 SWIGGY - CE - 260 - 30-Jun-2026 10 - 4,06,900 36,14,325 8.88 SWIGGY - CE - 260 - 30-Jun-2026 11 2,62,600 22,12,470 8.43 1,50,800 13,34,580 8.85 SWIGGY - CE - 260 - 30-Jun-2026 Trading not covered in patches 1,80,700 12,93,175 7.16 - SWIGGY - CE - 260 - 30-Jun-2026 Total 39,09,100 2,99,66,820 7.67 39,09,100 3,19,03,495 8.16 159. From the above, it is noted that for SWIGGY 260 CE contract, Chaubara bought at a lower price (i.e. average buy price of Rs.7.67) and subsequently in the next patches, sold at a higher....
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....te positions in the option segment at a favourable price. iv. At the end of the time patch, when sentimentally opposite trades in option segment got executed, the orders that were placed at prices away from the LTP and remained unexecuted in futures segment, were cancelled. 163. As detailed in the instance of KFINTECH, on December 03, 2025 in patch 4, at the start of buy patch, entity placed four orders aggregating to buy 19,350 quantities in near month futures contract at a price lower than the LTP and accounted for 12.5% of the total buy-side market depth in the contract. This remained visible in the order book showing increase in buying interest (i.e. depth on the buy side) till the entity was able to buy call options at a cheaper rate and sell put options at higher rate, prima facie to show artificial demand in the market. Once the sentimentally opposite orders in the options segment got executed, these deceptive orders were cancelled. Thereafter, the entity placed such deceptive orders in the opposite side of the order book, to show artificial supply and benefit the entity in options segment. 164. Such activity was noted during various patches across the day, su....
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.... to another entity. 168. While analysing the aspect of co-ordinated trading, in multiple instances, during Period 2 of examination period i.e. March 2026-June 2026, it was observed that while the entity Chaubara was placing aggressive orders in futures segment, its group entity Prrsaar was noted to be counterparty to these trades, taking advantage of the price movement, as highlighted under: Table 40 Sr. No. Date Instrument name Total Trade Qty. by Prrsaar (A) Trade Quantity matched & reversed between Prrsaar and Chaubara (B) Traded Qty. reversed with related entity as % of total traded qty. (B/A) Intraday Profit (in Rs.) 1 09-03-2026 HINDZINC26MARFUT 1,49,450 1,43,325 95.90 6,28,500 2 09-03-2026 VEDL26MARFUT 3,46,150 2,39,200 69.10 4,25,674 3 12-03-2026 MARICO26MARFUT 2,98,800 1,84,800 61.85 15,20,891 4 12-03-2026 INDUSTOWER26MARFUT 3,58,700 2,82,200 78.67 3,04,817 5 13-03-2026 WAAREEENER26MARFUT 32,900 18,725 56.91 6,76,971 ....
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.... Trade reversal value [A*C] (in Rs.) Buy (A) 10:47:44 to 12:57:15 32,900 2740. 10 26,425 80% 18,725 5,13,08,459 Sell (B) 10:47:44 to 12:57:15 32,900 2776.25 18,725 57% 5,19,85,430 Intra-day profit due to trade reversal by Prrsaar (i.e. B-A) 6,76,971 iii. While in sell patches of Chaubara, when the entity was allegedly manipulating and selling aggressively at a lower price, its group entity Prrsaar was counterparty to Chaubara's trades and bought 26,425 quantities from Chaubara, at an average price of Rs.2740.1. These trades between Prrsaar and Chaubara accounted for about 80.32% of Prrsaar 's total buy trades of 32,900 quantities on that given day. On account of aggressive sell trades at a lower price by Chaubara, Prrsaar benefited by buying these futures contract at a lower price. iv. On the other hand, while in buy patches of Chaubara, when the entity was allegedly manipulating and buying aggressively at a higher price, its group entity Prrsaar was counter-par....
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.... and a gain of Rs.1,06,62,676 in options contracts, through cross segment price manipulation in the scrip of Torrent Power Ltd., resulting in net profit of Rs.28,92,486. Simultaneously, Prrsaar had traded in stock options in Torrent Power Ltd. at the same time as Chaubara and made a net profit of Rs.4,90,599 benefitting from the artificial movement in futures prices created by Chaubara. The details of the same are shown below: Table 42 Prrsaar Chaubara Day Date Symbol FUTSTK OPTSTK Total FUTSTK OPTSTK Total 02-Mar-26 TORNTPOWER - 4,90,599 4,90,599 (77,70,190) 1,06,62,676 28,92,486 174. Considering such nature of trades by the group entities, it also needs to be further investigated whether entities also made wrongful gains, wherein, one group entity was involved in artificial movement in price in the stock futures segment, while other group entity benefitted from such manipulation in options segment. The examination is currently undergoing. F.5 Manipulation through cash segment activity of the same underlying 175. During the examination period on the scrip days when Prrsaar prima facie found t....
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....000 1,552.00 15,000 11:41:29 Sell 15,000 1,552.00 15,000 11:47:08 Sell Buy 15,000 1,545.50 15,000 11:47:20 Buy 15,000 1,545.50 15,000 11:48:30 Buy 15,000 1,545.20 15,000 11:48:52 Buy 15,000 1,545.10 15,000 iii. During the time patch between 11:37:51 to 11:41:29, on one hand, Prrsaar was noted to be aggressively buying 1,34,400 qty. of stock futures contracts, on the other hand, Prrsaar sold 90,000 shares in the cash segment, viz. in sentimentally opposite direction to that of its trades in futures segment. Herein, Prrsaar was able to sell its cash segment trades at a higher price of Rs.1552to Rs.1554. iv. Subsequently, during the time patch between 11:44:01 to 12:02:28, on one hand, Prrsaar was seen to be an aggressive net seller of 3,09,400 qty. of futures contracts, on the other hand, Prrsaar bought 60,000 shares in cash segment, viz. in sentimentally opposite direction to that of its trades in futures segment at lower price. Herein, Prrsaar was able to buy its cash segment trades at a lower price of Rs.1545.10 to Rs.1545.50. 176. The activity in the futures segment had coinci....
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....n options segment and earning wrongful gains thereof. By allegedly manipulating the prices in stock futures, the entities made wrongful gains in stock options. The total cumulative profit earned by entities from the cross segment manipulative activities on the following scrip days during October 2025 to June 2026 is as under: Table 46 Sr. No Name of the Noticee Day Date Symbol of scrip Wrongful gains in stock options segment (in Rs.) 1 Prrsaar Sampada Private Limited 06-Jan-26 BDL 3,84,34,848 2 05-Jan-26 GODREJPROP 2,83,52,871 3 15-Dec-25 360ONE 2,30,64,575 4 04-Dec-25 KFINTECH 2,21,00,783 5 23-Dec-25 KFINTECH 1,64,66,251 6 09-Feb-26 GODREJCP 1,62,39,575 7 05-Dec-25 UNOMINDA 1,36,17,258 8 03-Dec-25 KFINTECH 1,29,09,533 9 17-Dec-25 360ONE 1,26,92,300 10 23-Jan-26 GODREJCP 1,16,16,100 11 24-Dec-25 PRESTIGE 1,13,98,457 12 10-Feb-26 KFINTECH 85,39,750 13 20-Feb-26 MPHASIS 52,12,405 Total wrongful gains 22,06,44,706 14 Chaubara Eats Private Limited 13-Mar-26 WAAREEENER 1,37,42,590 15 ....
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....s 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 inquiry or on completion of such investigation or inquiry, namely: - (a) suspend the trading of any security in a recognised 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 organisation from holding such position; (d) impound and retain the proceeds or securities in respect of any transaction which is under investigation; (e) attach, for a period not exceeding ninety days, bank accounts or other property of any intermediary or any pe....
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.... such directions, - (a) to any person or class of persons referred to in section 12, or associated with the securities market; or (b) to any company in respect of matters specified in section 11A, as may be appropriate in the interests of investors in securities and the securities market. Explanation. - For the removal of doubts, it is hereby declared that the power to issue directions under this section shall include and always be deemed to have been included the power to direct any person, who made profit or averted loss by indulging in any transaction or activity in contravention of the provisions of this Act or regulations made thereunder, to disgorge an amount equivalent to the wrongful gain made or loss averted by such contravention. 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 contravent....
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.... (a) "company" means any body corporate and includes a firm or other association of individuals; and (b) "director", in relation to a firm, means a partner in the firm. PFUTP Regulations, 2003 Definitions Regulation 2 (1) .... (b) "dealing in securities" includes: (i) an act of buying, selling or subscribing pursuant to any issue of any security or agreeing to buy, sell or subscribe to any issue of any security or otherwise transacting in any way in any security by any persons including as principal, agent, or intermediary referred to in section 12 of the Act, either by themselves or through mule accounts; (ii) such acts which may be knowingly designed to influence the decision of investors in securities; and (iii) any act of providing assistance to carry out the aforementioned acts. (c) "fraud" includes any act, expression, omission or concealment committed whether in a deceitful manner or not by a person or by any other person with his connivance or by his agent while dealing in securities in order to induce another person or his agent to deal in securities, whether or not there is an....
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....lation 3, no person shall indulge in a manipulative, fraudulent or an unfair trade practice in securities markets. Explanation .- For the removal of doubts, it is clarified that- (i) any act of diversion, misutilisation or siphoning off of assets or earnings of a company whose securities are listed or any concealment of such act or any device, scheme or artifice to manipulate the books of accounts or financial statement of such a company that would directly or indirectly manipulate the price of securities of that company, or (ii) transactions through mule accounts for indulging in manipulative, fraudulent and unfair trade practice shall be and shall always be deemed to have been included in sub-regulation (1). (2) Dealing in securities shall be deemed to be a manipulative fraudulent or an unfair trade practice if it involves any of the following :- (a) knowingly indulging in an act which creates false or misleading appearance of trading in the securities market; (b) dealing in a security not intended to effect transfer of beneficial ownership but intended to operate only as a device to inflate, depress or cause fluctuations in the price ....
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....d, it has been prima facie shown that entities executed non-genuine trades in the stock futures and stock options segment to derive undue benefit and earn wrongful gains from the same. On one hand, the entity booked losses in the stock futures segment deliberately by placing consistent sell / buy orders aggressively below/above the LTP, sweeping the order book, correspondingly affecting the price on the stock options contracts and then on the other hand made wrongful gains in the stock options segment by creating or squaring off the positions at the manipulated price. 186. It has been brought out in the examination that entities interfered with the market forces depriving the innocent investors of the actual position of the order book by placing orders which were not intended to be executed. The repeated pattern of structured and pre-planned manipulative trades in multiple patches followed over a considerable period of time shows that the trading pattern was an ingenuity of the entities to tinker with the free flow of demand and supply in the market, manipulating the price and volume of securities to earn wrongful gains. In the instant matter, the entities were observed to be ex....
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.... move prices of the related stock options contracts in a favourable direction and benefitting therefrom. 190. I note that the execution of trades was meticulously planned inasmuch as the buy orders in stock futures were placed above the LTP so that the same could be executed instantaneously, and due to the effect of this on the price of stock options, the pending orders in stock options segment were executed at a favourable price. Such trades cannot be prima facie accepted to be genuine since there is evidence to suggest that entities created misleading appearance of trading in the derivatives and drove the price in the direction where it benefitted them the most by trading the positions in the stock options segment. 191. In any market, efficient price discovery essentially depends on the supply and demand of any security. Such factors cannot be allowed to be tinkered with by adoption of such manipulative and fraudulent trade practices. If price discovery is based on extraneous factors, a normal investor could never be expected to freely participate in the securities market. 192. In view of the above, I find that the prima facie wrongdoings of the entities while dealing in....
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....much on the meaning of unfair trade practices in securities. Contextually and in simple words, it means a practice which does not conform to the fair and transparent principles of trades in the stock market. In the instant case, one party booked gains and the other party booked a loss. Nobody intentionally trades for loss. An intentional trading for loss per se, is not a genuine dealing in securities. The platform of the stock exchange has been used for a non-genuine trade. Trading is always with the aim to make profits. But if one party consistently makes loss and that too in preplanned and rapid reverse trades, it is not genuine; it is an unfair trade practice. Protection of interest of investors should necessarily include prevention of misuse of the market. Orchestrated trades are a misuse of the market mechanism. It is playing the market and it affects the market integrity. ..... 38. Rather than allowing the market forces to operate in their natural course, the traders repeatedly carried out the impugned transactions which deprived other market players from full participation. The repeated reversals and predetermined arrangement to book profits and losses resp....
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....cing orders for non- genuine trades with the intent to not transfer the beneficial ownership of the securities and earn wrongful gains. 196. Further, the activity cannot be construed as hedging as in case of hedging the exposures in stock futures segment would have to be nearly equal to their exposures in stock options segment. However, for instances analysed, the exposures in stock options segment is significantly high to that of the stock futures segment. Further, hedging results in offsetting loss in one segment with about similar levels of gains in other related segment. However, it is noted that the futures trades consistently resulted in realized trading losses of lower quantum while the option positions generated substantially larger profits. Such repeated intraday losses of lower quantum in futures segment & substantially higher profit in other segment cannot per se be characterized as hedging activity. 197. The trading activity also cannot be construed as arbitrage intended to exploit temporary pricing inefficiencies in related asset classes while maintaining a near market-neutral exposure. In the present case, the entity incurred losses in futures positions consiste....
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....harge of, and were responsible to, the company for the conduct of its business during the examination period and the role played by them is provided below: Table 47 Sr. No. Company name Name DIN OR DPIN (PAN) DIN STATUS ADDRESS Designation (Category) 1 Prrsaar Sampada Private Limited Ved Parkash Gupta 01183298 Approved FLAT N. 36 POCKET B-8 SECTOR -4 ROHINI RAJA PUR KALAN DELHI 110085 INDIA Director (Promoter) 2 Priti Gupta 06893938 Approved B-8/36 SECTOR 4 ROHINI, SECTOR- 7 DELHI 110085 INDIA Director (Promoter) 3 Chaubara Eats Private Limited Saroj Gupta 07793920 Approved FLAT N. 36 POCKET B-8 SECTOR -4 ROHINI RAJA PUR KALAN DELHI 110085 INDIA Director (Professional) 4 Gaurav Tomar 10840529 Approved MUZAFFARNAGAR UTTAR PRADESH 251001 INDIA Director (Promoter) 5 $$$$$$$# ***** Approved ************** Director #Appointed on June 08, 2026 in the current designation. 203. The persons mentioned at Sr. No.1 and 2 in the above table were dire....
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....ade joint and several under Regulation 11B of the SEBI Act has same force. In this regard, the explanation to Section 11B is extracted hereunder: "Explanation. - For the removal of doubts, it is hereby declared that the power to issue directions under this section shall include and always be deemed to have been included the power to direct any person, who made profit or averted loss by indulging in any transaction or activity in contravention of the provisions of this Act or regulations made thereunder, to disgorge an amount equivalent to the wrongful gain made or loss averted by such contravention." 21. From the aforesaid, it is clear that a person can be directed to disgorge amount equivalent to the wrongful gain made by him. By such contravention, the liability to disgorge the amount is individual and not collective. Thus, we are of the opinion that the direction of the WTM directing the appellants to pay the amount jointly or severally is against the provisions of Section 11B and to that extent, it cannot be sustained. The order of the WTM is appellants in question except Rajesh Ranka to disgorge the amount is to the extent of the profit earned by them as calculated by....
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....d a signatory to the bank accounts of the Advik Textiles and, therefore, had a control over the funds of the company. Thus, it cannot be doubted that Navin Tayal and Jyotika Tayal conspired to make an illegal gain through Rohit Gupta. The findings given by the WTM cannot be faulted. 49. The contention that an order of disgorgement cannot be fastened upon the appellants jointly and severally cannot be accepted. Reliance in the case of Mahavir Chauhan vs. SEBI Appeal No. 393 of 2018 decided on October 18, 2019 is distinguishable. The findings of this Tribunal in the case of Mahavir Chauhan (supra) was based on the fact that the WTM had in that case separately quantified the profit made by each of the noticees and consequently, in that context this Tribunal held that there cannot be the order for joint and several liability." 209. In SRSR Holdings Pvt. Ltd. v. SEBI [A. No. 01 of 2019, decided on February 02, 2023], Hon'ble Securities Appellate Tribunal (SAT), while dealing with the issue of joint and several liability of Noticees, inter alia, held as under: "91. All persons who aid or direct or join in the committal of a wrongful act, are joint tort-feasors. T....
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....ributable to their own act. Further, even if no wrongful gain has accrued to a person, he may be made jointly and severally liable for disgorgement/impounding with other defaulters if his role is central to the fraud or if he acted concurrently or jointly with a common intention. Key ingredient required to be proved before making them liable jointly and severally is to prove that they joined together to do a wrongful act. In the instant matter, Noticee Nos. 1 and 4 are companies and not natural persons. It is settled law that directors are the controlling brain behind a company's operation and company acts through them. In terms of section 27 of the SEBI Act, 1992 they are vicariously liable for the acts of the Companies. Thus, the test laid down by Hon'ble Courts for fastening joint and several liability is satisfied in this case, since the Directors of Noticee Nos. 1 and 4 played central and key role in formulating and implementing the alleged fraudulent and manipulative scheme. 211. Therefore, I deem it appropriate to hold that Noticee Nos. 2 and 3 shall be jointly and severally liable for impounding of the wrongful gains of Prrsaar and Noticee Nos. 5 and 6 shall be j....
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.... entity Chaubara. Despite issuance of a letter by NSE, Prrsaar continued to indulge in prima facie unfair trade practice through related entity Chaubara as recent as in August 2026. It is clarified that in this interim order latest analysed instance is of June 2026 and subsequent instances are under examination. 217. I note that Prrsaar is a regulated market intermediary registered with SEBI as a Stock Broker, Depository Participant and Research Analyst. The entity & its directors are closely associated with the securities market and were duty bound to adhere to highest standards of integrity in the securities market. The actions of a broker/trading member ought to be measured by a higher yardstick while protecting the interests of the investors and integrity of the securities market, as the same can have broader consequential impact on the economy also. However, by carrying out such prima facie fraudulent and manipulative activities over an extended period of time at such a large scale, the entity has exhibited sheer disregard for regulatory laws. 218. The examination has also prima facie revealed that Prrsaar and Chaubara were also involved in possible coordinated/synchroni....
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....ate Limited 22,06,44,706 2 Ved Prakash Gupta 3 Priti Gupta 4 Chaubara Eats Private Limited 6,05,63,836 5 Saroj Gupta 6 Gaurav Tomar TOTAL 28,12,08,542 (In case of the Noticee No. 1, this direction applies to its proprietary bank account only) ii. Noticee Nos. 1 to 6 shall be restrained from accessing the securities markets (In case of the Noticee No. 1, this direction applies to its proprietary trading account only); iii. Banks, where Noticees are holding bank accounts, are directed that no debits shall be made, without permission of SEBI, in respect of the bank accounts held by Noticees, except for the purposes of transfer of funds to the fixed deposit account(s) as stipulated above. Further, this direction shall not apply to those bank accounts of Noticee No. 1 which deal with clients' funds, since Noticee No. 1 is a stock broker registered with SEBI and deals with funds of clients; iv. Depositories shall also be directed that no debit shall be made, without permission of SEBI, in respect of the demat accounts held by Noticees (In case of the Noticee No. 1 this direction applies to its ....
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....he examination/investigation in the instant matter. 222. A detailed investigation/examination by SEBI is required to be done in the instant matter, with respect to violations committed by Noticees and other suspects. The same may be completed expeditiously without being influenced by the prima facie findings in this order. 223. The foregoing prima facie observations contained in this Ex-Parte Interim Order are made on the basis of the material available on record. The Noticees may, within 21 days from the date of receipt of this Order, file their reply/objections, if any, to this Order and may also indicate whether they desire to avail an opportunity of personal hearing on a date and time to be fixed in that regard. 224. This order is without prejudice to the rights of SEBI to take any other action that may be initiated against Noticees in accordance with law, including but not limited to levy of penalty and issuance of directions. This order is further without prejudice to the rights of SEBI to take any action against other persons/entities, not made Noticees in this order. 225. A copy of this order shall be served upon the Noticees, Exchanges, Depositories, RTAs and B....
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....10:09 : 30.419970 90:09 :25.k. 30.10:00.403/71 10-10:27.749084 18 13:00.184127 30-14:06.349557 10:16:00.847002 30:17:06.316564 ID:17:06.344725 90:17:09.904707 30-17:10.560000 10:17:55.274 108 10-18:23.858322 12 18132.485839 50:18:33.400417 10:18|48. 000117 35-19:23.318054 30:20:47.644424 10:20:58.661163 35.21:44.310100 IP:21:52-431915 10:22:37.161335 30:24:25.515672 18 35-37.661849 10:26:03.372100 100% 1060 1005 1050 1065 Time patch between 10:02:17 AND 10:26:10 Contracts: KFINTECH_30-Dec-2025_FF_O KFINTECH_30-Dec-2025_CE_1080 Date: 03-Dec-2025 Pan: AAACK1089Q Options Sentire Mil Buy Ofy Option Trade Price Furtunis Traite Price Pan Dation Buy THE Price C 286 10-10:59.426434 30-12:02.467-543 IP:18 38.186055 Document 5 Sequence of orders and trades: Futures and 1080-strike Call (Expiry December 30, 2025) 18:12:41 Futures sell order rested above market 18,000 qty at Rs. 1,088.00 (Rs. 2.70 above LTP 1,085.30) - never trades; buy-side depth 2,39,400 concurrently, over the next -7 minutes 18:12:41 -10:20:07 57 further sell orders layered on the offer ....
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....:12 228973 11:18:28.983566 11:18:28.989166 11:18:29.793228 12:18:32.201/24 11:18:32.204223 11:18:32_206130 11:18:37-262020 11:18:51.735733 11:18:51.7506/1 11:18:51.804519 11:18:52.315917 11:18:56.452621 11:19:14.034454 11:19:58 489456 11:20:04.471801 11:20:08.031478 11:20:17.623703 11:21:21.194213 11:21:22.382797 11:21:53.013305 11:22:27.704605 11:23:52.165588 11:23:52.169128 11:24:38.560180 11:24:44.219238 11:24:44.725448 11:24:44.755706 11:24:44.776626 12:24:44.780014 11:24:44.797714 11:24:44.827880 11:24:44 888031 11:24:45.376815 11:24:48.063491 14:25:02.408111 11:26:03.905029 11:26:03.908401 11:26:07.305282 ::: 25:14.147781 12:27:05-500 11:27:15.906204 11:27:30.835083 11:27:32 705108 11:27:32 844955 11:27:42 642715 11:27:48.066207 11:28:04.802581 11:28:29.470870 11:28:33.921783 11:28:33.936294 11:28:32.991558 11:28:33.950302 11:28:33.953903 12:28:33.974609 11:28:34.012985 11128:34.019577 11:28:34.055816 11:28:34.088485 11:28:34.135681 11:28:34.672973 11:28:35.845932 12:28:38.066350 11:20:35.2074....