SEBI v. Krupa Sanjay Soni and others (Parichay Investments, 2022)

Judgment entered

✓ Checked against the primary document on October 8, 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.

Report an error in this record (sebi-65662-wash-trading-2022) by email

On remand from the Securities Appellate Tribunal, a SEBI adjudicating officer found in November 2022 that fifteen members of a connected 'Soni Group' used matched trades, self-trades and price-lifting orders to inflate Parichay Investments shares in 2010-11, with some selling out at the higher price. Penalties of Rs 5 lakh or Rs 10 lakh each, Rs 1.15 crore in all, were imposed.

The record

What was ordered

Civil penalty

—

Disgorgement

—

Prejudgment interest

—

Total relief

—

Alleged gain

—

Penalty as published

11.5m INR

A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars. This regulator states penalties in INR. The figure is recorded as published and is not converted, so it does not appear in the USD totals or medians used elsewhere on this site.

What is alleged to have happened

Adjudicating officer G. Ramar of SEBI issued this order on 30 November 2022. It was a fresh decision after the Securities Appellate Tribunal on 29 August 2022 set aside an earlier order of 31 July 2020 on natural-justice grounds and sent the matter back. The fifteen noticees included Krupa Sanjay Soni, Sanjay Jethalal Soni, his proprietorship J M Soni Consultancy, Dhirenkumar Agarwal, Shweta Agrawal, Krunal Rana, Amul Desai, Mahesh Desai and several relatives and associates. The shares were those of Parichay Investments Ltd, listed on BSE.

SEBI's investigation covered 21 July 2010 to 30 August 2011. It identified a group of 63 connected entities called the Soni Group which traded 266 scrips in a sample period and accounted for 20 per cent or more of trading in five of them, including Parichay. Eighteen of these were charged over Parichay; fifteen were before this officer. SEBI alleged violations of section 12A of the SEBI Act and regulations 3 and 4 of the PFUTP Regulations 2003.

The officer found that all fifteen had traded extensively as a group in matched trades, and that some also did repeated matched trades, self-trades and price-raising trades through last-traded-price contributions, new highs and first trades. Share-holding charts in the order show that some noticees sold a large part of their holdings after the price had been raised. The order concludes that the conduct needed a meeting of minds, created artificial volume and a misleading appearance of trading, and that the scheme was manipulative and fraudulent.

Under section 15HA the officer imposed Rs 10,00,000 each on eight noticees (including Krupa Soni, Sanjay Soni, J M Soni Consultancy, Dhirenkumar Agarwal, Shweta Agrawal, Krunal Rana, Amul Desai and Mahesh Desai) and Rs 5,00,000 each on the other seven, a total of Rs 1,15,00,000. The order says the record does not quantify gain or investor loss.

The record does not show whether these penalties were paid or taken to the tribunal again. The three other charged members of the group, not before this officer, are not addressed. No criminal case is described.

This library tags the matter as matched orders, wash trading and price manipulation. 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 3 techniques 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.

• Matched orders — see how it works, what statute it engages, and every other action tagged the same way.
• Wash trading — see how it works, what statute it engages, and every other action tagged the same way.
• Price manipulation — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2022-11-30 SEBI 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.

• SEBI order

The linked release is published by the issuing regulator under its own terms. Our summary and narrative above are our own writing.

Related actions

Other actions in the library sharing at least one technique tag with this one.

Record added October 8, 2026. submit a correction.