SEBI v. Combine Holding Limited and others (settlement, promoter holdings shown as public, 2022)
Settled
Checked against the primary document on October 9, 2026. The library's summary, tags and figures for this record were compared with the regulator's own document by an AI model (Claude) following written instructions, in a single reading of the order; an independent second reading of 60 SEBI records agreed on every field for 56, the four misses being penalty amounts; a later sample of 50 of the SEBI records added on 9 October agreed on every field for 46. No lawyer has reviewed them. A checked record can still contain errors, and checked does not mean endorsed. See how we check records or report a correction.
In September 2022 two SEBI whole time members settled enforcement proceedings against six related applicants for Rs 11.60 crore in total, with undertakings. SEBI had alleged that promoter holdings in Combine Holding Limited were presented as public shareholding, with fraud charges against the company and the individuals.
The record
| Agency | SEBI (India) |
|---|---|
| Date filed | 2022-09-07 |
| Date resolved | 2022-09-07 |
| Court | SEBI whole time members |
| Status | settled |
| Asset class | equities |
| Instruments | Combine Holding Limited shares |
| Criminal parallel | No |
| Defendants | Combine Holding Limited ; Samir Jain ; Meera Jain ; Punjab Mercantile & Traders Limited ; Ashoka Viniyoga Limited ; Camac Commercial Company Limited |
| Also named elsewhere | Ashoka Viniyoga Limited ; Camac Commercial Company Limited ; Combine Holding Limited ; Punjab Mercantile & Traders Limited |
| Techniques | Misleading issuer disclosure |
What was ordered
- Civil penalty
- —
- Disgorgement
- —
- Prejudgment interest
- —
- Total relief
- —
- Alleged gain
- —
- Penalty as published
- 116m INR
What is alleged to have happened
Two SEBI whole time members issued this settlement order on 7 September 2022. It belongs to a group of orders of the same date involving the same promoter network and the same investigation period. The six applicants were Combine Holding Limited, Samir Jain, Meera Jain, Punjab Mercantile & Traders Limited, Ashoka Viniyoga Limited and Camac Commercial Company Limited.
SEBI investigated 2013 to 2019 for misrepresentation of promoters' holdings as public shareholding and breaches of the minimum public shareholding norms. The show cause notice of October 2020 alleged that Combine Holding broke listing rules and shareholding circulars and committed fraud under section 12A of the SEBI Act and Regulations 3(b), 3(c) and 4(1) of the PFUTP Regulations. The other applicants were charged with takeover and insider-trading disclosure failures, the shareholding norms and the same fraud provisions.
The applicants asked to settle on a neither-admit-nor-deny basis, as the settlement regulations allow. SEBI's advisory committee deferred the matter until the Delhi High Court, where related writ petitions were pending, said SEBI was free to consider it, and recommended terms in June 2022.
The amounts were Rs 2,43,10,000 for Combine Holding, Rs 1,12,01,300 each for Samir Jain and Meera Jain, Rs 2,24,21,300 each for Punjab Mercantile and Camac Commercial, and Rs 2,43,99,650 for Ashoka Viniyoga, Rs 11,59,54,850 in total. Combine Holding and Ashoka Viniyoga undertook not to raise money from the public for 24 months, and Punjab Mercantile undertook to extend an exit offer to the remaining public shareholders of Combine Holding at the earlier price, subject to any increase the High Court directs.
The order disposes of the proceedings and bars further action for the same defaults, though SEBI may restore them if representations prove false or undertakings are broken. It makes no finding of violation. The record does not show the outcome of the exit offer or the High Court petitions.
This library tags the matter as misleading issuer disclosure (alleged misrepresentation of promoter holdings as public shareholding). The tagging is ours, not the regulator's.
For the regulator's own account of the facts, read the primary document linked above. This page deliberately summarises the structured record rather than reproducing the order.
What technique is this, and how does it work?
This action is tagged with one technique in our taxonomy. The tagging is ours: regulators charge statutory provisions, not technique names, so the mapping is an editorial judgement described in our editorial policy.
- Misleading issuer disclosure — see how it works, what statute it engages, and every other action tagged the same way.
Timeline
- 2022-09-07 SEBI settlement order
Primary documents
Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.
Related actions
Other actions in the library sharing at least one technique tag with this one.