Case Overview
The Securities and Exchange Board of India (SEBI) initiated adjudication proceedings against Ms. Sudha V Thakkar (PAN: AEUPT7605Q) for alleged violations in dealing with Illiquid Stock Options (ISO) on BSE Ltd.
SEBI's investigation covered the period from April 1, 2014 to September 30, 2015, during which it observed large-scale reversal of trades in BSE's stock options segment. The investigation revealed that 2,91,744 trades, comprising 81.41% of all trades in the segment, 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 volumes.
Among 14,720 entities identified for executing such non-genuine trades, the noticee was alleged to have indulged in execution of reversal trades that were manipulative and deceptive in nature. SEBI initiated proceedings for alleged violation of regulations 3(a), (b), (c), (d), 4(1) and 4(2)(a) of SEBI (Prohibition of Fraudulent and Unfair Trade Practices) Regulations, 2003.
A Show Cause Notice dated August 02, 2022 was issued to the noticee, followed by a Post SCN Intimation dated March 06, 2024 regarding settlement schemes offered by SEBI (Settlement Scheme 2022 and Settlement Scheme 2024). The case was transferred to the current Adjudicating Officer, who provided a hearing opportunity on July 02, 2026.
Final Outcome
On June 30, 2026, Mr. Jayesh Thakkar, son of the noticee, submitted a death certificate verifying that Sudha V Thakkar passed away on February 15, 2024. The certificate was verified from the website of Health and Family Welfare Department, Government of Gujarat.
The Adjudicating Officer applied the legal maxim actio personalis moritur cum persona (personal action dies with the death of the person), citing 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).
The proceedings were abated without going into the merits of the case, and the Show Cause Notice dated August 02, 2022 was disposed of accordingly. The order was sent to SEBI, the last known addresses of the deceased noticee, and to Mr. Jayesh Thakkar as required under rule 6 of SEBI (Procedure for Holding Inquiry and Imposing Penalties) Rules, 1995.
Topics: SEBI enforcement, Legal proceedings abatement, Market manipulation