SEBI v. Pankaj Kumar and others (Geodesic Ltd false accounts, 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.

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In December 2022 a SEBI whole-time member held that the three promoter-directors of Geodesic Ltd, a software company now in liquidation, presented a false 2011-12 balance sheet, with bogus purchases and funds diverted from a US$125 million bond issue. They were barred from the securities market for a year, and proceedings against two independent directors were dropped.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

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Total relief

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Alleged gain

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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.

What is alleged to have happened

SEBI whole-time member S.K. Mohanty issued this order on 19 December 2022 over Geodesic Limited, formerly Geodesic Information Systems, listed on BSE since 2001 and NSE since 2004 and by then under liquidation. The five noticees were directors: Pankaj Kumar (chairman), Prashant Mulekar (director and compliance officer), Kiran Kulkarni (managing director) and independent directors Vinod Sethi and Nitin Potdar.

SEBI acted after a Bombay High Court order of 22 December 2015, in a petition by HDFC Bank, directed it to take action against the directors, and after complaints from stakeholders. A forensic auditor, Sarath and Associates, examined the books for 2011-12 and earlier. According to the order, the company issued US$125 million of foreign currency convertible bonds in 2008, to be used for overseas acquisitions and ventures, but could not redeem them when they fell due in January 2013 and was ordered into liquidation.

The order finds that the funds raised were diverted through overseas subsidiaries as loans to entities connected to an outside consultant, Dinesh Jajodia, and onward to other entities, and that the company booked purchases from six bogus companies on fake bills. It finds the 2011-12 balance sheet contained false and misleading financial data, and holds the three executive directors guilty of violating section 12A of the SEBI Act and the PFUTP Regulations. The order notes that the directors did not rebut the forensic findings.

For the two independent directors, the member found that they were not given complete information, that losses from foreign-exchange trading were kept from them, and that they resigned once they sensed a lack of transparency, so the charges were dropped. The three executives were each restrained from the securities market for one year, with their holdings frozen during the restraint. No monetary penalty is stated in the order.

The record does not show whether this order was appealed, how much of the bond money was recovered in liquidation, or whether the criminal and enforcement agencies the High Court mentioned took any action. This library does not record a criminal case from this order.

This library tags the matter as misleading issuer disclosure. 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

1. 2022-12-19 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.