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

Order Date: September 09, 2026

Case Overview

The adjudication proceedings were initiated against Sanjay S. Achharya HUF (PAN: AAGHA7452L) for alleged violations in dealing with Illiquid Stock Options (ISO) on BSE. SEBI's investigation covering April 1, 2014 to September 30, 2015 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. These trades were deemed non-genuine as they lacked basic trading rationale and created false or misleading appearance of trading, leading to artificial volumes.

The Noticee was identified as one of 14,720 entities that executed such non-genuine reversal trades. Specifically, the Noticee executed 2 non-genuine trades in 1 Stock Options contract, resulting in artificial volume of 100,000 units. SEBI 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.

A Show Cause Notice (SCN No. SEBI/HO/IVD/ID10/P/OW/2021/32899/1) was issued on November 16, 2021, but no response was received from the Noticee. Subsequently, a Post SCN Intimation regarding the SEBI Settlement Scheme, 2022 (applicable from August 22, 2022 to January 21, 2023) was issued, but the Noticee did not apply for settlement.

During hearings, it was revealed that the Karta of the HUF, Sanjay S. Achharya, had passed away on September 09, 2015, and the HUF was formally dissolved on April 10, 2018, as evidenced by a death certificate issued by the Municipal Corporation of Greater Mumbai and a deed of dissolution submitted by the authorized representative, Shri Rajesh Achharya.

Final Outcome

The adjudication proceedings were disposed of as infructuous since the Noticee, Sanjay S. Achharya HUF, ceased to exist as a legal entity on April 10, 2018, before the proceedings could be concluded. The SCN dated November 16, 2021 was accordingly disposed of without imposition of penalty.

Topics: SEBI enforcement, Illiquid stock options, HUF dissolution