{"id":189807,"date":"2007-07-13T00:00:00","date_gmt":"2007-07-12T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/sebi-vs-kunvarji-finstock-pvt-ltd-on-13-july-2007"},"modified":"2019-03-09T03:34:52","modified_gmt":"2019-03-08T22:04:52","slug":"sebi-vs-kunvarji-finstock-pvt-ltd-on-13-july-2007","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/sebi-vs-kunvarji-finstock-pvt-ltd-on-13-july-2007","title":{"rendered":"Sebi vs Kunvarji Finstock Pvt. Ltd. on 13 July, 2007"},"content":{"rendered":"
Securities Appellate Tribunal<\/div>\n
Sebi vs Kunvarji Finstock Pvt. Ltd. on 13 July, 2007<\/div>\n
Bench: V Chopra<\/div>\n<\/p>\n
<\/pre>\n
ORDER<\/p>\n
V.K. Chopra, Member<\/p>\n
1. BACKGROUND<\/p>\n
1.1 M\/s MOH Ltd, an Ahmedabad based company was incorporated in February 1993 in the name of M\/s MOH Granites Ltd and was engaged in business of granites Page 1 of 14 processing, mining and exporting. The name of the company was changed to M\/s MOH Ltd. in the year 2000 when they entered into the information technology area. The company came out with public issue of 67,00,000 shares at par in August 1996 to part finance granite project located at Mahesana in Gujarat. However, after the issue, information about the implementation of the project was not available.\n<\/p>\n
1.2 The MOH shares are listed at Bombay Stock Exchange Ltd. (BSE) and  Ahmedabad Stock Exchange (ASE). The price of MOH scrip started increasing  from a level of Rs. 240.50 on August 01, 2000 to a level of Rs. 799\/- on September  19, 2000 with trading volumes ranging between 100 to 10,000 shares. Prior to  this, the price of the scrip had fallen to Rs 223\/- from Rs 270 during June 01,  2000 to July 26, 2000 with daily trading volume ranging between 12,500  to 1,23,000 shares.\n<\/p>\n
1.3 After an internal investigation in the matter, BSE concluded that the price and  volume of the scrip were manipulated by certain connected entities by entering  into fictitious transactions in the nature of circular trading. It was also observed  that there was no reason for the price of the scrip to go up considering the  financial performance of the company. BSE imposed a special margin of 25%  w.e.f. August 10, 2000 which was subsequently increased to 50% w.e.f.  September 04, 2000. The daily circuit filter was reduced from normal 8% to 4%  from August 10, 2000 in view of abnormal increase in price of the scrip.\n<\/p>\n
1.4 In view of the above, Securities and Exchange Board of India (hereinafter referred  to as “SEBI”) conducted investigation in the matter. Investigation inter alia  revealed that M\/s Kunvarji Finstock Pvt. Ltd., (hereinafter referred to as  “Noticee”), a Sub-broker (SEBI Registration No. INS011043937) of SVS  Securities Pvt. Ltd. (broker of BSE) had facilitated its client M\/s Kajol Impex to  manipulate MOH scrip. The Noticee was also registered as a sub-broker (SEBI  Registration No INB02548214) of Active Finstock Pvt. Ltd. till October 28, 2002. Further, Noticee is also registered as broker of Ahmedabad Stock Exchange  (SEBI Registration No. INB02548214) and by virtue of being member of ASE, it  is also registered as sub-broker of ASE Capital Markets Ltd. (SEBI Registration.  No. INS 011449233) at BSE.\n<\/p>\n
2. ENQUIRY PROCEEDINGS<\/p>\n
2.1 After considering the Investigation Report, an Enquiry Officer was appointed by  SEBI vide Order dated July 24, 2003 under Securities and Exchange Board of  India (Procedure for holding Enquiry by Enquiry Officer and Imposing penalty)  Regulations, 2002 (hereinafter referred to as “Enquiry Regulations”) to enquire  into the affairs of the Noticee in regard to his dealing in MOH scrip and possible  violation of the provisions of SEBI (Stock Brokers and Sub-Brokers) Regulations,  1992 (hereinafter referred to as “Stock Brokers Regulations”).\n<\/p>\n
2.2 The Enquiry Officer issued a notice of enquiry dated October 07, 2003 to the  Noticee who in turn vide letter dated November 08, 2003 submitted its reply.  Thereafter, Shri Nayan Thakkar attended the hearing before the Enquiry Officer  on December 17, 2003.\n<\/p>\n
2.3 The Enquiry Officer, after conducting an enquiry in accordance with the  provisions of Enquiry Regulations submitted a report dated December 14, 2004  wherein he found that the Noticee had violated the code of conduct as specified in  Schedule II of provisions as stated in the above paragraph. He recommended  suspension of certificate of registration of the Noticee for a period of three  months.\n<\/p>\n
3. SHOW CAUSE NOTICE<\/p>\n
3.1 Pursuant to the receipt of the said enquiry report, a show cause notice dated May  31, 2005 was issued to the Noticee, along with a copy of the said Enquiry Report,  advising it to show cause as to why the action, as recommended by the Enquiry Officer or such other action as may be deemed appropriate should not be imposed on the Noticee.\n<\/p>\n
4. REPLY OF THE NOTICEE TO THE SHOW CAUSE NOTICE<\/p>\n
4.1 The Noticee submitted its reply to the said show cause notice, vide letter dated July 5, 2005, brief details whereof are given below:\n<\/p>\n
4.1.1 It had more than 475 clients registered with them and their turnover was 205 crores. They had proper system in place to ensure that the clients are properly registered and their positions monitored at the end of each day. No client is allowed to trade beyond his financial capacity.\n<\/p>\n
4.1.2 They have been in the business for over 15 years and till date there has been no investor compliant against them either with their main brokers or with the exchange.\n<\/p>\n
4.1.3 They had not violated any provisions of the Code of Conduct for the sub-brokers. They have impeccable track record in the conduct of their  business and they maintained high standard of integrity, promptitude and  fairness in the conduct of their business.\n<\/p>\n
4.1.4 They had exercised due skill, care and diligence in the conduct of their  business and had obtained KYC form as prescribed duly filled in. Further,  it is not practically feasible to get in to the details as to why a particular  client was trading in particular scrip and with what intention. That at the  relevant time when the client was trading with them, they were not aware  who the counterparty broker \/ client was and they had no means to know  also and as such they had not violated Clause A (2) of the Code of  Conduct of the Stock Brokers Regulation.\n<\/p>\n
4.1.5 They had no intention to commit any manipulation or malpractice in the  MOH scrip and not violated Clause D (4) and D (5) of the Code of  Conduct of the Stock Brokers Regulation.\n<\/p>\n
4.1.6 The decision to buy sell is of the client and there is no way a sub-broker  can stop a client from placing an order for purchase of any scrip. It is not  for a broker to determine whether the scrip is liquid or illiquid and  whether the share price is justified by the financials of the scrip or  whether the client should trade in that particular scrip at the said price.  Their role is to ensure that client does not place an order which is not in  conformity with the prevailing market prices and that it honours delivery  and payment obligations at all points of time.\n<\/p>\n
4.1.7 There is not even a shred of evidence to indicate that the trades were not  executed at the prevailing market price and that there is only a bald  allegation that an order used to be placed 8% above the previous day’s  closing price. The allegation that sub broker had permitted the client to  buy shares when the scrip was rising is incorrect. The share price was  moving irrespective of whether the client was buying, selling or was not  active. The price movement of the scrip does not suggest that the trades  done by the client had an impact on the prices.\n<\/p>\n
4.1.8 Since the delivery was directly to the pool account of the broker, they  were not aware that the shares have been delivered by a third party.  Further, they had denied that they had delivered shares to third party  account without written instruction, as alleged.\n<\/p>\n
4.1.9 There was no reason for them to believe that the client was indulging in circular trading with other entities.\n<\/p>\n
5. HEARING<\/p>\n
5.1 The Noticee also sought for a personal hearing and accordingly, an opportunity of  personal hearing was granted to the Noticee. The Noticee was advised to attend  the personal hearing before me at SEBI’s Head Office at Mumbai on 9th February  2007. Shri Atul M. Choksi and Shri Nayan K. Thakkar, director appeared on  behalf of the Noticee when they filed a post hearing written submissions dated  February 19, 2007. The sum and substance of submissions of the Noticee are  hereunder:\n<\/p>\n
? It cannot be established that the rise in price was organized by them and  that the intent and design of a group of person even before their act cannot  be measured by anyone.\n<\/p>\n
? The Noticee was not aware of any such design or intent on part of their client Kajol Impex or anyone else.\n<\/p>\n
? The solitary instance of delivery from third party account is projected as a big game plan and the percentage contribution in scrip volume of 16% cannot be held against a market participant.\n<\/p>\n
? Whenever a broker placed order on the exchange trading system, it was at the instruction of the client and the broker could not ask or understand rationale for orders.\n<\/p>\n
? The price movements in different scrip over a day or over a period were regular phenomena. Merely because others acted with malicious intentions, cannot be held against them.\n<\/p>\n
6. CONSIDERATION OF ISSUES & FINDINGS<\/p>\n
6.1 After having carefully examined the enquiry report, show cause notice and  submissions of the Noticee, I observe that the price of the scrip of MOH started  increasing from a level of Rs. 240.50 on August 01, 2000 to a level of Rs. 799 on  September 19. 2000. It was noticed that the following brokers had contributed  89% of the volumes in the scrip during this period.\n<\/p>\n
  ——————————————————————————\n<\/p>\n
Name of the              Qty      % to the total   Qty sold    % to the total\nBroker                  bought     buy volume at                sell volume at\n                                   the exchange                  the exchange\n------------------------------------------------------------------------------ \nKantilal Mangaldas     18,939        25.43%         18,939         25.43%\nSec Pvt Ltd.\n------------------------------------------------------------------------------ \nSVS Securities Ltd.    16,248        21.82%         18,807         25.25%\n------------------------------------------------------------------------------ \nPrabhudas Lilladher    15,134        20.32%         12,970         17.42%\n------------------------------------------------------------------------------ \nBD Shah Sec Pvt Ltd.    8,451        11.35%          5,002          6.72%\n------------------------------------------------------------------------------ \nActive Finstock         3,800         5.10%              0             0%\n------------------------------------------------------------------------------ \nAcme Shares Pvt Ltd.    3,275         4.40%         10,650         14.30%\n------------------------------------------------------------------------------ \n                       65,847        88.42%         66,368         89.12%\n------------------------------------------------------------------------------ \n\n \n\n6.3 The aforesaid brokers had dealt for their ultimate clients through their sub brokers, whose details are also given.\n  Name of the broker         Name of the sub broker           Ultimate Client\nKantilal Mangaldas         Abhilasha Securities            Tannya Securities \nSVS Securities              Kunvarji Finstock                Kajol Impex \nPrabhudas Lilladher         Jyotish Bhogilal          Stk Brk Shri Parshwa Finance \nBD Shah Sec. Pvt Ltd.       Royal Investments              A.M. Investments \n(Ms. Alpa Shah\/Bijal Mehta) Active Finstock Kunvarji     Finstock Kajol Impex \nAcme Shares Pvt Ltd.        M.M. Consultancy             Mahavir Investments\n\n \n\n<\/pre>\n
6.4 It is observed that Noticee had purchased 12,248 shares (approx. 16% of the total  purchases) and sold 15,107 shares through the broker, SVS Securities Ltd. It may  be pointed out here that Noticee had also traded on behalf of Kajol Impex  through BSE broker Active Finstock when they had only purchased 3500 shares  on August 18, 2000 and August 25, 2000. It was noticed that Noticee had  received delivery of 3500 shares on behalf of Kajol Impex in their pool account,  out of which they had delivered 1685 shares against the sale position of Kajol  Impex (sold through broker SVS Securities).\n<\/p>\n
6.5 Shri Hemrajsinh Vaghela, Director of Kajol Impex Ltd. in his statement  recorded on November 18, 2002 stated that he is a Director in Kajol Impex as  well as Ambica Seeds Pvt. Ltd. He had acquired in all 1,29,900 shares of MOH  Ltd. in the public issue, in his name and in the name of his family  members\/related entities as per the following details:\n<\/p>\n
  —————————————————\n<\/p>\n
Hemrajsinh Vaghela                  25,000 shares \nPooja Vaghela (wife)                25,000 shares \nAmbica Seeds                        59,900 shares \nShailesh Patel (partner in \nKajol Impex)                        20,000 shares \n---------------------------------------------------\n\n \n\n<\/pre>\n
6.6 I observe that Shri Vaghela, his family members\/related entities, Kajol Impex  Pvt Ltd., and Ambica Seeds did not appear among the top 50 share holders (at  the time of allotment). However, from the copy of distribution schedule  submitted by BSE, it is noticed that Kajol Impex and Ambica Seeds were among  the top 50 shares holders as on September 1999 and September 2000 and were  holding 99,000 shares each (of face value of Rs. 10\/- each).\n<\/p>\n
6.7 From the details submitted by Noticee, the net position in the scrip, settlement wise of Kajol Impex is given below:\n<\/p>\n
  ————————————————————————–\n<\/p>\n
St 20 (-) 5,335    shares Received from the a\/c of Shri Jitendra J. Shah \n--------------------------------------------------------------------------\nSt 21 (+) 3,000    shares Received in the pool a\/c of sub broker \n--------------------------------------------------------------------------\nSt 22 (+)   900    shares Received in the pool a\/c of sub broker \n--------------------------------------------------------------------------\nSt.23 (+)   261    shares Received in the pool a\/c of sub broker \n--------------------------------------------------------------------------\nSt.24 (-) 1,685    shares Delivered out of the purchased made above \n--------------------------------------------------------------------------\n\n \n\n<\/pre>\n
6.8 From the above, it is clear that Kajol Impex had a net sale position of 5,335  shares in Settlement No. 20 of 2000 and they were asked to clarify regarding  the source of these shares delivered by them. Since, Kajol Impex did not  respond with the details, information was collected from Stock Holding  Corporation of India Ltd. when it was observed that 5,335 shares were  delivered directly to the broker – SVS Securities on behalf of Kajol Impex from  the DP account of one Shri Jitendra J. Shah (Client ID 30079275).  Analysis of the demat account of Shri Jitendra J. Shah revealed that, on August  01, 2000 (the day from which the price started moving up), Shri Jitendra J.  Shah had converted 43,000 shares from physical form to demat form and these  shares were off loaded in the market through these clients.\n<\/p>\n
6.9 It was also observed that the shares moved from the demat account of Shri  Jitendra J. Shall directly to the pool account of the main broker, against the sale  position of the clients of the broker and not through the account of the respective  clients. This way, Shri Jitendra J. Shall delivered 5335 shares directly to the pool  account of broker SVS Securities against the sale position of their client – Kajol  Impex Ltd.\n<\/p>\n
6.10 Apart from the above, Shri Jitendra Shah transferred MOH shares to the demat  account of Shri Anil Mistry of Tanya Securities and Shri Parshwa Profin Pvt.  Ltd. Thus, it is very clear that the clients of the Noticee and others who  transacted in MOH scrip during the relevant period in connivance with Shri  Jitendra J. Shah, artificially manipulated the price of the scrip, which in fact  caused the price of MOH to move upto unrealistic levels. Further, all other  deliveries for purchase of shares, on behalf of Kajol Impex, were received in the  pool account of Noticee and the shares were delivered from this pool account  towards the sale position of Kajol Impex. The shares were not transferred to the  individual DP account of Kajol Impex.\n<\/p>\n
6.11 It is also seen from the analysis of the trade log and Order log during the period,  August 01, 2000 to August 21, 2000 that on most of the days, the clients of the  Noticee had purchased and sold shares at 8% higher than the previous day’s  closing trades and that too among themselves in such a way that the buy orders of  one client were getting matched with the sell order of another client in the same  group giving thereby an indication of circular trading. This was possible because  the scrip was illiquid. Once the trade was executed at this rate, the clients then  traded among themselves to ensure that the price of the level is maintained at this  rate. In this way, they managed to take the price to a level of Rs. 799  continuously. There was no basis or fundamentals to support such a hike in price  as the profit and loss account of MOH for the financial year 2001-2002 had  fallen drastically compared to previous financial year 2000-2001. By executing  such artificial trades and giving an appearance of genuine trading in this scrip,  the innocent investors were induced to start trading in this scrip. It has been  observed from the price and volume data after the investigation period that the  price came down to Rs 36.45 on March 2001 (face value Re 1\/-), Rs 22.65 in  April 2001, Rs.  10.40 in May 2001, Re 1 in August 2001 and went down further  to Re 0.20 in December 2001. The genuine investors obviously must have  suffered loss during this period. It clearly reveals that the above clients including  the client of the Noticee, in connivance with Shri Jitendra J. Shah, artificially  manipulated the price of the scrip to reach unrealistic levels. The Noticee had  aided and abetted his client to execute manipulative trades. In view of the fact  that the fundamentals of the scrip were not strong and since the scrip was  considerably illiquid, any prudent stock broker\/sub-broker could have doubted  the intentions of the clients and stopped trading for them. On the other hand, the  Noticee continued trading for number of settlements which resulted in building  up of artificial market in the MOH scrip.\n<\/p>\n
6.12 The Noticee stated that the show cause notice did not talk of the closing price of  the previous day and does not state whether such orders resulted in a trade. This  contention of the Noticee is not tenable as the Noticee being a sub-broker should  get the details of volume, price and circuit filter level of a scrip etc. at least after  the market time. Since the Noticee had executed trades for its client on several  days, they should have been aware of its trade. It is pertinent to mention that at  the relevant time BSE was taking many steps like levying special margins and  consistently reversing circuit filter levels which ought to have sent a strong signal  to the market that there is some thing suspicious in the trading in the scrip. The  client Kajol Impex of the Noticee was trading only in this particular scrip and the  pattern of trading was also suspicious. These details are enough to raise concern  for a prudent and responsible sub-broker like Noticee. The stock market system  depends a lot on such prudence of the intermediaries. The brokers\/sub-brokers are  the first line of monitoring and surveillance in the market. The failure at this level  will weaken the fundamentals of the system and will harm its development as a  safe market of international standards. In the instant case the Noticee did not  exercise the due skill and diligence expected from them and failed to take any  action even though there were enough and repeat indications suggesting clearly  that the trading in the scrip by the client was not above board. Further, instead of  stopping suspicious dealings of its client, the Noticee in fact tried to benefit out of  the artificial market.\n<\/p>\n
6.13 The Enquiry Officer observed that the client had started dealing in MOH shares in  Settlement No. 20 and had sold a total quantity of 6,712 shares and purchased  1,377 shares. Therefore, the client had short sold 5,335 shares and delivery for  the same was directly made to SVS Securities Ltd. by third party namely Shri  Jitendra Shah. This lapse on behalf of the client should have also alarmed the  Noticee and they should have asked his client to stop trading in the scrip. The  Noticee in their reply stated that they were unaware of the same and admitted that  they had advised their client that the said practice was unacceptable to them and  the client should deliver shares to their account only and no sale transactions  would be undertaken if the shares were first not delivered to their account. If in  fact they had stopped the trade after they knew about this aspect, one could  understand their good intentions. However on the contrary, it continued  executing the transactions in MOH scrip on behalf of the client in subsequent  settlements also.\n<\/p>\n
6.14 The Noticee stated that they were not willing to monitor the trades executed by  the clients as they have mentioned that no client would like his transactions to be  monitored by the broker \/ sub-broker. The Enquiry Officer has also observed that  no financial details of Kajol Impex were given in the client introduction form. I  am of the view that a stock broker or sub broker has to compulsorily obtain  financial details of their clients so as to satisfy that they are bonafide. The very  purpose of such practice is to enable the stock brokers to evaluate client before  they take up trading on their behalf. In this connection, it would be relevant to  refer the following extracts of the order dated September 18, 2003 passed by the  Hon’ble Securities Appellate Tribunal in the matter of Madhukar Sheth v. SEBI  (Appeal No. 46 of 2002):\n<\/p>\n
Before executing series of transactions for his client, any prudent broker  would have gone a bit far to ascertain the goings around and also would  have normally assessed the financial capability of the person for whom he  was trading….\n<\/p>\n
…The Appellant’s submission that he had taken client registration form,  entered into agreement etc. by itself was not sufficient. Exercise of due  diligence in ongoing transactions is a continuous process and it is not a one  time measure to be adhered to while taking up the first transaction. The   appellant’s submission that it was B’s dishonesty that created the problem  did not absolve him of his failure to discharge his duties as a prudent  broker….\n<\/p>\n
…On the basis of the material available on record, it was difficult to  conclude that the appellant had exercised due skill and care in dealing with  ‘B’. It was not that the appellant had carried on only few trade transactions  for ‘B’ for a short period. He had transacted in huge volumes for ‘B’ and the  association dated back to August 2000. If the appellant could not see any  design or pattern in the transactions which ‘B’ was executing through the  appellant during the period, then the appellant certainly deserved to be  blamed for being indifferent and unconcerned and for that reason he was at  fault for the failure to exercise due skill and diligence….\n<\/p>\n
…It is true that a broker cannot act of his own against the instructions of  the client. But no one can compel him to be a party to manipulate the  market. No doubt a broker is supposed to protect the interest of his client,  but he is also expected to protect the interest of the securities market in  which he operates. It is his duty to ensure not to be a party to any market  manipulation and that the market in which he operates is run on a health and  non-manipulative basis.\n<\/p>\n
6.15 The Enquiry Officer has observed from the trading pattern of the Noticee for its  client as also from the settlement of transactions in various settlements that   Noticee had allowed the client to deal in an illiquid scrip like MOH in large   quantity contributing approx. 16% of the trading volumes on the exchange. He   further observed that the quantity traded by Noticee would have distorted the   market equilibrium in the scrip.\n<\/p>\n
6.16 Further, in the process of perpetuating these artificial trades, Noticee has also  failed to exercise proper skill, care and diligence, required of a broker as already   discussed earlier. The Noticee further failed to verify the bonafides and financial   worthiness of the client, Kajol Impex as even admitted by them. As a registered   sub-broker, Noticee was fully aware of the Rules and Regulations of SEBI. I find   that Noticee had failed to observe the clauses of Code of Conduct by not   maintaining the standards of integrity, promptitude and fairness required of a sub-  broker. Further by entering such manipulative transactions on behalf of its client,   Notice created artificial market which led to interference with the fair and smooth  functions of the market mechanism of the stock exchanges. In view of all above  issues of serious magnitude, it is clear that the Noticee violated the provisions of  Clause A (1) & (2) and D (4) & (5) of code of conduct specified under Regulation  15(1)(b) of SEBI (Stock Brokers and Sub brokers) Regulations, 1992 which are  extracted hereunder:\n<\/p>\n
A. GENERAL<\/p>\n
(1) INTEGRITY: A sub-broker, shall maintain high standards of integrity, promptitude and fairness in the conduct of all investment business.\n<\/p>\n
(2) EXERCISE OF DUE SKILL AND CARE: A sub-broker, shall act with due skill, care and diligence in the conduct of all investment business.\n<\/p>\n
D. SUB-BROKERS VIS-\u00c0-VIS REGULATORY AUTHORITIES.\n<\/p>\n
(4) MANIPULATION: A sub-broker shall not indulge in manipulative, fraudulent or deceptive transactions or schemes or spread rumours with a view to distorting market equilibrium or making personal gains.\n<\/p>\n
(5) MALPRACTICES : A sub-broker shall not create false market either singly or in concert with others or indulge in any act detrimental to the  public interest or which leads to interference with the fair and smooth  functions of the market mechanism of the stock exchanges. A sub-broker  shall not involve himself in excessive speculative business in the market  beyond reasonable levels not commensurate with his financial soundness.\n<\/p>\n
6.17 Under Section 11 of the SEBI Act, SEBI can take steps to protect the interests of  investors and to regulate the securities market inter alia by registering and  regulating the working of stock brokers. If the regulatory requirements are  violated by the stock brokers without attracting any action, the measures initiated  by SEBI for regulation of the stock brokers would be rendered meaningless and  the regulatory function would be jeopardized. It is to be noted that indulgence of  the Noticee in the transactions which are prohibited can not be allowed as these  transactions had a detrimental effect on the functioning and integrity of the  securities market.\n<\/p>\n
6.18 I have noted that the enquiry officer has recommended imposition of a penalty of  suspension of three months on the Noticee. However, considering the submissions  made by the Noticee that the transactions were not substantial on gross basis at  BSE and also there is no charge under SEBI (Prohibition of Fraudulent and Unfair  Trade Practices Relating to Securities Market) Regulations, 1995, I feel a penalty  of one month, as against the three months suggested by the Enquiry Officer, will  meet the ends of justice.\n<\/p>\n
7. ORDER<\/p>\n
7.1 Taking into consideration all facts and circumstances of the matter and in exercise  of the powers conferred upon me in terms of Section 19 of the Securities and  Exchange Board of India Act, 1992 read with Regulation 13(4) of Securities and  Exchange Board of India (Procedure for Holding Enquiry by Enquiry Officer and  Imposing Penalty) Regulations, 2002, I hereby impose a minor penalty of  suspension of certificate of registration issued to M\/s Kunvarji Finstock Pvt. Ltd.  as a sub-broker of SVS Securities Pvt. Ltd. (SEBI Registration no. INS011043937  and PAN No. AAACK8760E), for a period of one month.\n<\/p>\n
7.2 This order shall come into force on the expiry of 21 days from the date of this order.<\/p>\n","protected":false},"excerpt":{"rendered":"
Securities Appellate Tribunal Sebi vs Kunvarji Finstock Pvt. Ltd. on 13 July, 2007 Bench: V Chopra ORDER V.K. Chopra, Member 1. BACKGROUND 1.1 M\/s MOH Ltd, an Ahmedabad based company was incorporated in February 1993 in the name of M\/s MOH Granites Ltd and was engaged in business of granites Page 1 of 14 processing, […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_lmt_disableupdate":"","_lmt_disable":"","_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[1],"tags":[],"class_list":["post-189807","post","type-post","status-publish","format-standard","hentry","category-judgements"],"yoast_head":"\nSebi vs Kunvarji Finstock Pvt. 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