Authority: Adjudicating Officer, Securities and Exchange Board of India (Amit Kapoor)
Order Date: July 13, 2026
Order No.: Order/AK/GN/2026-27/32481
Case Overview
The adjudication proceedings were initiated against Excel Technovation Pvt Ltd (PAN: AAACE3703B) for alleged violations in the illiquid stock options segment of Bombay Stock Exchange (BSE). SEBI's investigation covered the period from April 1, 2014 to September 30, 2015, during which it was observed that 81.40% of all trades (2,91,744 trades) in BSE's stock options segment were non-genuine, creating artificial volumes.
The Noticee was specifically charged with executing 46 non-genuine reversal trades across 23 stock options contracts, generating artificial volume of 12,92,000 units. These trades involved buying and selling the same quantity of contracts with the same counterparty within short time intervals, demonstrating clear patterns of synchronization and prior meeting of minds. The trades showed significant price variations within minutes, indicating predetermined pricing rather than genuine market discovery.
Key evidence included trade logs showing the Noticee executed 100% non-genuine trades in several contracts, contributing 100% of the artificial volume in those contracts. For example, in contract EXID15APR165.00CEW4, the Noticee bought 26,000 units from Ashlar Securities Private Limited at Rs 9.2 per unit at 15:16:38 hours and sold the same quantity back to the same counterparty at Rs 19.9 per unit just 9 seconds later at 15:16:47 hours on March 30, 2015.
The Adjudicating Officer relied on Supreme Court precedents (SEBI Vs Bhavesh Pabari, SEBI v Kishore R Ajmera, and SEBI v Rakhi Trading Private Limited) and SAT judgments that established that synchronized trading with the same counterparty indicates prior meeting of minds and constitutes manipulative practices under PFUTP Regulations, even without direct evidence of collusion.
Final Outcome
Excel Technovation Pvt Ltd was found guilty of violating Regulations 3(a), (b), (c), (d), 4(1) and 4(2)(a) of the SEBI (Prohibition of Fraudulent and Unfair Trade Practices Relating to Securities Market) Regulations, 2003. A monetary penalty of ₹5,00,000 (Rupees Five Lakhs only) was imposed under Section 15HA of the SEBI Act, 1992.
The order serves to crystallize SEBI's claim against the company, which is currently under liquidation proceedings before the NCLT, Jaipur Bench, with a liquidator appointed on October 31, 2023. This enables SEBI to file its claim with the liquidator despite the expiration of the normal claims filing period.
Topics: SEBI Enforcement, Market Manipulation, Illiquid Options