Case Details

Entity Involved: M/s Veerkrupa Jewellers Limited (VJL) and 16 other noticees including individuals and companies

Order Details: SEBI Order dated May 29, 2026 issued by Quasi-Judicial Authority Santosh Shukla

Investigation Period: June 20, 2022 to May 31, 2024

Financial Impact: Total wrongful gains of ₹6,22,81,526 to be disgorged by Noticees 3, 10, 11, 12, 13, and 14 with 12% simple interest from May 31, 2024. Monetary penalties totaling ₹2.65 crore imposed on various noticees.

Persons Involved

Key Entities and Their Roles:

  • Noticee 1: M/s Veerkrupa Jewellers Limited - Issuer company
  • Noticee 2: Mr. Chirag Arvind Shah - Managing Director of VJL
  • Noticee 3: M/s Vivid Mercantile Limited - Major public shareholder holding 19.84% pre-issue capital
  • Noticee 4: Mr. Satishkumar Ramanlal Gajjar - MD of Noticee 3
  • Noticee 5: Mr. Rakshit Mahendra Shah - Chartered Accountant assisting with IPO process
  • Noticee 6: M/s First Overseas Capital Limited - Merchant Banker and Lead Manager
  • Noticee 7: Mr. Rushabh Shroff - President Operations of Noticee 6
  • Noticee 8: Mr. Satish Vadilal Sheth - President of Noticee 6
  • Noticee 9: M/s Stockk Seva Marketing Private Limited - IPO marketing company
  • Noticee 10: Mr. Meghkumar Mahendrakumar Shah - Key person associated with Noticee 9
  • Noticee 11: Mr. Bhavya Dhiman - Director/Promoter of Noticee 9
  • Noticee 12: Mr. Dipak Mathurbhai Salvi - Mule account of Noticee 10
  • Noticee 13: M/s Bhavesh A Vora HUF - Acquaintance of Noticee 10
  • Noticee 14: Mr. Dharmesh Maldevbhai Godhania - Acquaintance of Noticee 10
  • Noticee 15: Mr. Akshay Rajendrabhai Oswal - Connected to Noticee 10 through fund transfers
  • Noticee 16: M/s NNM Securities Private Limited - Market maker appointed from March 23, 2023
  • Noticee 17: M/s Miker Financial Consultants Private Limited - Group entity of Noticee 16

Violations and Allegations

Summary of Violations:

  • Noticees 1 to 11 were part of a fraudulent scheme to publish misleading information about VJL's SME IPO that was likely to influence investor decisions
  • The scheme involved publishing a paid Zee News article on June 23, 2022 and YouTube videos promoting a false Grey Market Premium (GMP) of ₹7
  • Noticee 6 (Merchant Banker) violated ICDR Regulations and Merchant Bankers Regulations by failing to ensure proper disclosures and due diligence
  • Noticees 10, 11, 12, 13, and 15 created misleading appearance of trading and contributed significantly to volume and price rise during Patch-1 (July 18-August 29, 2022) and Patch-2 (December 14, 2022-February 14, 2023)
  • Noticee 14 purchased shares immediately upon listing and sold during Patch-2, making wrongful gains
  • Noticees 15, 16, and 17 created misleading appearance of trading during Patch-3 and Patch-4 (price fall periods)
  • Noticee 10 violated Regulation 8(1)(a) of PFUTP Regulations by failing to respond to summons
  • Noticee 11 violated Regulation 8(1)(b) of PFUTP Regulations by failing to appear before Investigating Authority

Regulations Cited:

  • Sections 12A(a), (b), (c) of SEBI Act, 1992
  • Regulations 3(a), (b), (c), (d), 4(1), 4(2)(a), (e), (f), (k), (r) of PFUTP Regulations, 2003
  • Regulation 263 read with Schedule IX of ICDR Regulations, 2018
  • Regulation 13 read with Schedule III of Merchant Bankers Regulations, 1992
  • Sections 11C(3), (5), (7) of SEBI Act

Penalties, Settlement Terms & Rulings

Monetary Penalties Imposed:

  • Noticee 2: ₹20 lakh under Section 15HA
  • Noticee 4: ₹10 lakh under Section 15HA
  • Noticee 5: ₹10 lakh under Section 15HA
  • Noticee 6: ₹20 lakh under Section 15HA + ₹10 lakh under Section 15HB
  • Noticee 7: ₹20 lakh under Section 15HA
  • Noticee 8: ₹20 lakh under Section 15HA
  • Noticee 9: ₹20 lakh under Section 15HA
  • Noticee 10: ₹50 lakh under Section 15HA + ₹30 lakh under Section 15HA + ₹20 lakh under Section 15A(a)
  • Noticee 11: ₹10 lakh under Section 15HA + ₹10 lakh under Section 15HA + ₹10 lakh under Section 15A(a)
  • Noticee 12: ₹10 lakh under Section 15HA
  • Noticee 13: ₹10 lakh under Section 15HA
  • Noticee 14: ₹10 lakh under Section 15HA
  • Noticee 15: ₹10 lakh under Section 15HA
  • Noticee 16: ₹20 lakh under Section 15HA
  • Noticee 17: ₹10 lakh under Section 15HA

Wrongful Gains Calculation:

  • Noticee 10: ₹2,92,96,300
  • Noticee 11: ₹2,09,88,900
  • Noticee 12: ₹12,46,771 (attributed to Noticee 10)
  • Noticee 13: ₹6,94,199
  • Noticee 14: ₹59,70,800
  • Noticee 3: ₹40,84,556
  • Total: ₹6,22,81,526

Actions, Compliance and Future Obligations

Corrective Actions Required:

  • All noticees are restrained from accessing securities market and prohibited from buying/selling/dealing in securities for periods of 3-5 years
  • Noticees must close any open derivative positions within 3 months from order date
  • Noticees 3, 10, 11, 12, 13, and 14 must disgorge wrongful gains with 12% interest to Investor Protection and Education Fund within 45 days
  • Noticees are prohibited from selling assets except for penalty payment purposes
  • Banks are directed to allow debit only for disgorgement/penalty payments

Market Restraint Periods:

  • 5 years: Noticees 1, 2, 3, 4, 7, 8, 9, 10, 11
  • 3 years: Noticees 12, 13, 14, 15, 16, 17

Final Ruling and Enforcement

Final Decision:

  • SEBI found all charges substantiated against the noticees
  • The order comes into effect immediately
  • Restraint periods for Noticees 6, 16, and 17 will run consecutively after existing restraint periods from previous SEBI orders

Enforcement Actions:

  • Recovery proceedings under Section 28A of SEBI Act may be initiated for non-payment within 45 days
  • Order to be served on all noticees, SEBI, stock exchanges, banks, depositories, and RTA for compliance
  • Payments to be made through SEBI's online payment portal

Key Findings:

  • The scrip price rose 250% within 29 trading days post-listing due to manipulative activities
  • Noticees 10, 11, and 12 were key persons behind the misleading publicity and manipulative trading
  • Form SH-4 used to support share transfer between Noticee 2 and 3 was invalid and factually inconsistent
  • Bonus shares issued to Noticee 3 were invalid as they were not properly registered as member
  • The merchant banker failed in due diligence obligations and was part of the fraudulent scheme