Authority: Adjudicating Officer, Securities and Exchange Board of India (Medha Jeevan Sonparote)

Order Date: July 14, 2026

Order No.: Order/MS/KS/2026-27/32482

Case Overview

The Securities and Exchange Board of India (SEBI) initiated adjudication proceedings against Ms. Anju Rani (PAN: AJCPR9744F) for alleged violations of regulations 3(a), (b), (c), (d), 4(1) and 4(2)(a) of the SEBI (Prohibition of Fraudulent and Unfair Trade Practices) Regulations, 2003 (PFUTP Regulations).

The case originated from a SEBI investigation into trading activities in Illiquid Stock Options (ISO) on BSE Ltd. for the period from April 1, 2014 to September 30, 2015. The investigation revealed that 81.41% of all trades in BSE's stock options segment (2,91,744 trades) involved reversal of buy and sell positions by clients and counterparties in a contract. These trades were alleged to be non-genuine as they lacked basic trading rationale and created a false or misleading appearance of trading, leading to artificial volume.

Among 14,720 entities identified for executing such non-genuine trades, the Noticee, Anju Rani, was alleged to have executed 2 non-genuine reversal trades in 1 Stock Options contract, resulting in artificial volume of 20,000 units.

A Show Cause Notice (SCN) dated August 31, 2021 was issued to the Noticee. The SCN was served via Speed Post Acknowledgement Due and email, but no response was received. Subsequent Post SCN Intimations regarding Settlement Schemes in 2022 and 2024 were also issued, with emails successfully delivered but physical mail returned undelivered.

On February 20, 2025, Mr. Nitin Agarwal, son of the Noticee, informed SEBI via email that his mother had been unwell for 10 years and submitted her death certificate. Verification from the website of Birth & Death Registration, Office of the Registrar General & Census Commissioner, India, Ministry of Home Affairs confirmed that Anju Rani passed away on January 12, 2025.

The Adjudicating Officer considered legal precedent, including the Supreme Court judgment in Girijanandini Devi v. Bijendra Narain Choudhary (AIR 1967 SC 1124) and the Securities Appellate Tribunal decision in Chandravadan J. Dalal v. SEBI (Appeal No. 35/2004). These established that for personal actions where relief is personal to the deceased, the right to sue does not survive to or against representatives, applying the maxim 'actio personalis moritur cum persona' (personal action dies with the death of the person).

Final Outcome

The adjudication proceedings against Anju Rani were abated without going into the merits of the case. The Show Cause Notice dated August 31, 2021 was disposed of accordingly. The penalty that could have been imposed under section 15HA of the SEBI Act was abated as it was personal in nature.

A copy of the order was sent to SEBI, the last known addresses of the deceased Noticee, and to Mr. Nitin Agarwal who provided the death certificate.

Topics: SEBI Enforcement, Illiquid Stock Options, Legal Abatement