Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE- August 13, 2026

WTM/KV/ISD/ISD-SEC-6/32673/2026-27 SECURITIES AND EXCHANGE BOARD OF INDIA EX-PARTE INTERIM ORDER UNDER SECTIONS 11(1), 11(4) AND 11B(1) OF THE SECURITIES AND EXCHANGE BOARD OF INDIA ACT, 1992 IN THE MATTER OF MANIPULATIVE TRADES DURING CAS ON SENSEX EXPIRY AT BSE– AUGUST 13, 2026. In respect of: Sr. No. Names of Noticees PAN 1. Copthall Mauritius Investment Limited AAACC4303M 2. Mansi Share and Stock Broking Private Limited AADCM6645D (The entities mentioned above are individually referred to by their respective names or Noticee No. and collectively referred to as “Noticees”, unless the context specifies otherwise)1 TABLE OF CONTENTS TABLE OF CONTENTS ............................................................................................................................... 1 A. BACKGROUND ................................................................................................................................ 2 B. BRIEF FINDINGS OF THE EXAMINATION BY SEBI ........................................................................... 3 C. ANALYSIS OF TRADING PATTERN IN CAS ON BSE .........................................................................

5 C.1 Spike 1 (15:20:41 to 15:20:43) ............................................................................................... 8 C.2 Spike 2 (15:24:08 to 15:24:20) ............................................................................................. 12 C.3 Spike 3 (15:25:49 to 15:26:17) ............................................................................................. 14 C.4 Drawdown by Mansi (15:21:03 to 15:26:00) ....................................................................... 17 D. OBSERVATIONS ON UNUSUAL TRADING PATTERN OF THE NOTICEES....................................... 19 D.1.1 Activity of Copthall Mauritius Investment Limited ..................................................... 22 D.1.2 Activity of Mansi Share and Stock Broking Private Limited ........................................ 22 D.2 F&O position vis-a-vis cash trading pattern ........................................................................ 23 D.3 Consideration of issues and prima facie findings................................................................ 26 D.4 Calculation of Wrongful gains ..............................................................................................

36 D.4.1 Calculation of Wrongful gains of Copthall Mauritius Investment Limited: ................ 36

1 Some names who are not Noticees are anonymised and actual name would be supplied to Noticees during inspection and to Hon’ble Securities Appellate Tribunal and Courts, during court proceedings. Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026

D.4.2 Calculation of Wrongful gains of Mansi Share and Stock Broking Private Limited.... 38 E. Need for Interim Order ................................................................................................................ 41 F. DIRECTIONS .................................................................................................................................. 43

A. BACKGROUND 1. Securities and Exchange Board of India (“SEBI”) vide Circular (“SEBI Circular”) dated January 16, 2026 introduced Closing Auction Session (“CAS”) on the platform of stock exchanges. The framework for CAS as prescribed in the aforesaid SEBI Circular became effective from August 03, 2026. The CAS was made applicable in a phased manner and initially, the closing price of the stocks in the cash segment on which derivative contracts are available are to be determined based on the prescribed framework of CAS.

2. As per provisions of the said SEBI Circular, the normal trading in the covered scrips in cash segment halts at 15:15 and a reference price for these scrips is calculated between 15:15 to 15:20. Thereafter, the CAS begins at 15:20 and continues till 15:30 subject to random closure by stock exchanges between 15:28 and15:30. The price band applicable during CAS is +/-3% from the reference price of the stock. Thereafter, by 15:35, a single equilibrium price is discovered where maximum quantity of the shares is executable.

3. The methodology for computation of the closing price for index is paraphrased here from para 4.9 from the SEBI Circular and the same is as follows: “…. 1.1.9. The settlement price shall be the closing price of the underlying index on the day of expiry. The closing price of the underlying index shall be based on the closing price of the constituents of the underlying index. …”

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026

4. Further as per para 4.12 of the SEBI Circular, the following information shall be disseminated during CAS: “… 4.12.1. Indicative equilibrium price of the stock 4.12.2. Indicative cumulative buy and sell quantity of the stock 4.12.3. Indicative imbalance quantity of the stock at equilibrium price 4.12.4. Indicative imbalance quantity based on market orders of the stock 4.12.5. Indicative Index ….” 5. After implementation of CAS, SEBI surveillance has been monitoring it on every day. CAS is designed to improve price discovery and transparency. It provides SEBI with greater ability to identify potential manipulation compared to the earlier system based on volume weighted average price (“VWAP”). SEBI surveillance noted abnormal spikes in the Indicative Equilibrium Price (“IEP”) of Sensex on August 13, 2026, Thursday which was also a BSE Sensex weekly expiry day for derivative contracts. The broad concerns seen were in respect of the recovery of 113.61 points in Sensex, sharp price movement in options etc. Accordingly, a detailed examination of the trading activity in the CAS of BSE on August 13, 2026 was carried out by SEBI.

B. BRIEF FINDINGS OF THE EXAMINATION BY SEBI

6. During the CAS (15:20 to 15:30) on August 13, 2026 which was a Sensex weekly expiry day on BSE, it was observed that the reference price of the Sensex was 77829.6 at 15:15. The CAS started at 15:20 and the closing price of Sensex arrived through CAS was 78079.96 (rounded off to 78080 for calculations) based on the constituents of the Sensex. However, abrupt

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026 changes in the movement of IEP were noted during the CAS. The movement of the IEP is depicted in the chart given below: Figure 1 Indicative SENSEX Equilibrium Price

7. August 13, 2026 was the weekly expiry day of Sensex options and the settlement price of the said options was to be based on the closing price of the Sensex determined during the CAS.

8. As can be seen from the above chart that there were 3 substantial price spikes along with one gradual drawdown during the CAS. The spikes are summarized in the table below. Table 1 Parameter Spike 1 Spike 2 Spike 3 Time Window 15:20:41 to 15:20:43 (2 15:24:08 to 15:24:20 15:25:49 to 15:26:17 sec) (12 sec) (28 sec) Sensex 77,661.40 to 78,023.42 77,707.84 to 77,840.51 77,787.94 to 78,193.02 Movement Sensex Point +362.02 points +132.67 points +405.08 points Spike

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026

9. Thus, a significant price spike (“Spike 1”) was observed in the BSE SENSEX, where the SENSEX IEP rose from 77,661.40 to 78,023.42 (+362.02 points) within a two-second interval (15:20:41 to 15:20:43), indicating an abrupt surge. In addition to the first spike, a second significant movement (“Spike 2”) occurred between 15:24:08 and 15:24:20, where the BSE SENSEX appreciated by 132.67 points, moving from 77,707.84 to 77,840.51 in a span of 12 seconds.

10. Furthermore, a third instance of abnormal price movement (“Spike 3”) was recorded shortly thereafter. Between 15:25:49 and 15:26:17, the BSE SENSEX IEP witnessed a sharp rise from 77,787.94 to 78,193.02. This movement, represented an increase of 405.08 points within a brief window of 28 seconds.

11. Also, it is observed that during the interval from 15:21:03 to 15:26:00, the BSE SENSEX exhibited a general downward trajectory, declining from 77,991.05 to 77,893.61. It is pertinent to note that this drawdown was intermittently interrupted by one of the aforementioned price spikes, which caused a temporary deviation from the prevailing downward trend in this period.

12. The correlation between the aforesaid spikes and the trading activity of Noticees are analysed in the subsequent sections of this order.

C. ANALYSIS OF TRADING PATTERN IN CAS ON BSE

13. The top 10 entities on Gross Buy Basis at PAN level as on August 13, 2026 in CAS in SENSEX constituents are as given in the table below: Table 2 Gross Buy Gross value Client Name Value (₹ in % Crs.) COPTHALL MAURITIUS INVESTMENT LIMITED 191.29 86.60 Other buyer #2 12.24 5.54

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026

Other buyer #3 6.63 3.00 Other buyer #4 2.17 0.98 Other buyer #5 0.84 0.38 Other buyer #6 0.25 0.11 Other buyer #7 0.22 0.10 Other buyer #8 0.22 0.10 Other buyer #9 0.20 0.09 Other buyer #10 0.20 0.09

14. From the table above, it may be noted that the 86.6% of the gross buy value was traded by a single entity, i.e., Copthall Mauritius Investment Limited (“Copthall”/“Noticee No. 1”).

15. The top 10 entities on Gross Sell Basis at PAN level as on August 13, 2026 in CAS in SENSEX constituents are as given in the table below: Table 3 Gross Sell Client Name value (₹in Gross Sell % Crs.) seller #1 76.03 34.42 seller #2 25.87 11.71 seller #3 19.85 8.99 seller #4 10.09 4.57 seller #5 9.63 4.36 seller #6 8.39 3.80 seller #7 6.13 2.78 seller #8 5.43 2.46 seller #9 5.15 2.33 seller #10 4.53 2.05

16. The top 10 entities on Gross buy order quantity cancelled at PAN level as on August 13, 2026 in CAS are as given in the table below:

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026

Table 4 Gr. Buy Order Gr. Buy quantity Placed Order Client Name quantity cancelled COPTHALL MAURITIUS INVESTMENT LIMITED 31,66,651 10,38,201 Entity #2 2,71,125 1,97,796 Entity #3 1,49,901 1,06,900 Entity #4 1,00,000 1,00,000 Entity #5 26,02,268 72,368 Entity #6 8,94,708 67,465 Entity #7 60,000 60,000 Entity #8 1,77,993 50,100 Entity #9 50,000 50,000 Entity #10 45,000 45,000 17. From the table above, it can be observed that Copthall cancelled the highest number of buy orders worth ₹98.11 Crore. The entity cancelled a total of 10,38,201 out of the order quantity of 31,66,651, i.e., a cancellation percentage of 32.79%.

18. The top 10 entities on Gross Sell order quantity cancelled at PAN level as on August 13, 2026 in CAS are as given in the table below: Table 5 Gr. Sell Gr. Sell Order Order Client Name quantity quantity Placed cancelled MANSI SHARE AND STOCK BROKING PRIVATE LIMITED 12,77,000 12,65,000 Entity #2 5,15,180 5,15,000 Entity #3 34,80,702 3,08,589 Entity #4 3,00,000 3,00,000

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026

Gr. Sell Gr. Sell Order Order Client Name quantity quantity Placed cancelled Entity #5 2,98,758 2,98,758 Entity #6 4,23,625 2,52,300 Entity #7 3,72,119 1,71,522 Entity #8 1,50,000 1,50,000 Entity #9 2,25,800 1,44,900 Entity #10 6,86,353 1,08,003 19. From the table above, it may be observed that Mansi Share and Stock Broking Private Limited (“Mansi”/“Noticee No. 2”) cancelled the highest number of sell orders. The entity cancelled a total of 12,65,000 out of the sell order quantity of 12,77,000, i.e., a cancellation percentage of 99.06%.

20. The nature of buy concentration, order placement and order cancellation by the entities mentioned above appeared to warrant a detailed examination of the nature of the orders placed by these entities and the impact of the said order placement and cancellation on the IEP on August 13, 2026. Accordingly, a detailed examination has been conducted into the price movement of the constituents of SENSEX for the spikes and drawdown mentioned in the preceding paragraphs. C.1 Spike 1 (15:20:41 to 15:20:43) 21. It was observed that between 15:20:41 and 15:20:43 in the CAS, there was a spike of around 362.02 points in SENSEX IEP abruptly from 77661.4 to 78023.42. In order to ascertain the cause of such abrupt spike, the IEP change in the underlying constituents during the period 15:20:41 to 15:20:43 was examined. It was also examined as to which entity(s) had caused this price spike. The movement in the IEP of constituents during the period (15:20:41 to 15:20:43) was examined. The details of the IEP movement of SENSEX

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026 constituent scrips, with significant change above reference price during the aforesaid period is as given below: Table 6 Scrip Code Symbol % Change in IEP 539448 INDIGO 2.62 532755 TECHM 2.44 500251 TRENT 1.91 532978 BAJAJFINSV 1.60 543320 ETERNAL 1.26 532921 ADANIPORTS 1.19 532215 AXISBANK 1.06 500247 KOTAKBANK 1.00 532555 NTPC 0.91 532898 POWERGRID 0.88 500520 M&M 0.86 500820 ASIANPAINT 0.84 532538 ULTRACEMCO 0.82 500470 TATASTEEL 0.82 500875 ITC 0.81 500049 BEL 0.71 524715 SUNPHARMA 0.50 500510 LT 0.50 532540 TCS 0.50 500696 HINDUNILVR 0.50 500034 BAJFINANCE 0.50 532281 HCLTECH 0.49 532500 MARUTI 0.47 500209 INFY 0.21

22. An analysis of the trade log and Order log of the period was conducted and summarised as follows: Table 7 Parameter Value Time Window 15:20:41 to 15:20:43 (2 seconds) Total Sell Orders 14 orders Total Buy Orders 88 orders (86 Limit, 2 Market) Total Buy Order Value ₹66,63,96,390 (~₹66.64 Cr) Total Sell Order Value ₹ 17,64,468.4 (~₹ 17.64 Cr)

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026

23. From the table above, it is observed that during the period 15:20:41 to 15:20:43 (2 seconds) 88 buy orders were placed and out of that, 86 buy orders were limit orders. These orders aggregate to a value of approx. ₹66.64 crores. Further, the Order log of the entity, Copthall, who appeared at the top both in terms of gross buy value and gross buy order cancelled, was examined and summarised as follows: Table 8 Particulars PAN: AAACC4303M Other Market Participants Total / Market Copthall Mauritius Investm Impact ent Limited Limit Buy Orders 32 54 86 Order Value ₹ 66,57,90,274 ₹6,06,115 ₹ 66,63,96,390 % Share of Value 99.91% 0.09% 100.00% Price where limit +3.0% above reference Below +2.0% (0 orders > Extreme orders placed price +2%) divergence Scrip Coverage Placed across all Sensex Distributed and varied Concentrated scrips market-wide impact 24. From the table above, it is observed that 32 of the 86 total limit buy orders were placed by Copthall. Further, the gross order value of the orders placed by Copthall was approx. ₹66.57 Crore in comparison to total market gross order value of ₹66.64 Crore i.e., 99.91% of the total order value. The table given below shows the summary of the orders placed by Copthall that prima facie has caused this spike. The table clearly shows that the buy orders were placed by Copthall at a range of 2.7% to 3% above reference price and all the orders were entered at the same time. Table 9 Symbol Scrip Name Order Avg. Buy Sum of Sum of Order Max of Deviation time Order Order Value Reference from RP price Quantity price (RP) 532755 TECHM 15:20:42 1688.05 3898 65,80,019 1638.9 2.999% 524715 SUNPHARMA 15:20:42 1996.35 4591 91,65,243 1938.25 2.998% 500696 HINDUNILVR 15:20:42 2150.9 1738 37,38,264 2088.3 2.998% 500510 LT 15:20:42 4178.95 8120 3,39,33,074 4057.25 3.000% 532454 BHARTIARTL 15:20:42 1998.65 31493 6,29,43,484 1940.45 2.999% 532281 HCLTECH 15:20:42 1405.45 5628 79,09,873 1364.55 2.997% 500520 M&M 15:20:42 3503.05 3077 1,07,78,885 3401.05 2.999% 500049 BEL 15:20:42 421.55 20397 85,98,355 409.3 2.993%

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026

Symbol Scrip Name Order Avg. Buy Sum of Sum of Order Max of Deviation time Order Order Value Reference from RP price Quantity price (RP) 500470 TATASTEEL 15:20:42 189.25 26536 50,21,938 183.75 2.993% 500251 TRENT 15:20:42 3083 1278 39,40,074 2993.25 2.998% 500875 ITC 15:20:42 285.6 17959 51,29,090 277.3 2.993% 532898 POWERGRID 15:20:42 275.55 10831 29,84,482 267.55 2.990% 532540 TCS 15:20:42 2438.8 5241 1,27,81,751 2367.8 2.999% 500180 HDFCBANK 15:20:42 748.6 157556 11,79,46,422 726.8 2.999% 500034 BAJFINANCE 15:20:42 1120.5 14394 1,61,28,477 1087.9 2.997% 543320 ETERNAL 15:20:42 327.6 38611 1,26,48,964 318.1 2.986% 532174 ICICIBANK 15:20:42 1452.65 74112 10,76,58,797 1410.35 2.999% 500112 SBIN 15:20:42 1108.5 42939 4,75,97,882 1076.25 2.997% 500114 TITAN 15:20:42 5188.75 4221 2,19,01,714 5037.65 2.999% 532555 NTPC 15:20:42 352.6 9948 35,07,665 342.35 2.994% 532500 MARUTI 15:20:42 14278.05 913 1,30,35,860 13862.2 3.000% 500325 RELIANCE 15:20:42 1352.5 69944 9,45,99,260 1313.15 2.997% 532978 BAJAJFINSV 15:20:42 2080.9 2759 57,41,203 2020.3 3.000% 500247 KOTAKBANK 15:20:42 402.95 20424 82,29,851 391.25 2.990% 532921 ADANIPORTS 15:20:42 1701 2387 40,60,287 1651.5 2.997% 539448 INDIGO 15:20:42 5498.95 1227 67,47,212 5338.8 3.000% 500209 INFY 15:20:42 1201.45 14464 1,73,77,773 1166.5 2.996% 532215 AXISBANK 15:20:42 1255.85 7472 93,83,711 1219.3 2.998% 500820 ASIANPAINT 15:20:42 2816.7 918 25,85,731 2734.7 2.999% 532538 ULTRACEMCO 15:20:42 12011.25 261 31,34,936 11661.45 3.000% Total 6,03,337 66,57,90,275

25. Further, in comparison to other market participants, it is observed that the orders placed by Copthall were limit orders with limit near the upper permissible limit under the CAS regulation (3% above reference price), whereas orders of other participants varied between 0% to 2%. Further, Copthall placing buy orders across all the constituents of SENSEX at the same time in a coordinated manner, especially at higher prices indicates a prima facie intent to manipulate the closing price by increasing the IEP of SENSEX in CAS.

26. Even though it was short lived, in the initial seconds of 15:20:03 to 15:20:06 there was a dip in the Sensex IEP by 451 points. The same drawdown is also under further examination by SEBI.

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026

C.2 Spike 2 (15:24:08 to 15:24:20)

27. After the spike at 15:20:43 Sensex gradually fell down from 78023.42 to 77707.84 by 15:24:07 due to sell orders placed by the Noticee No. 2 (the details of analysis of the sell orders is explained in subsequent sections of this order).

28. Also prior to Spike 2, during the period 15:23:47 to 15:24:06 there was a sudden dip in Sensex of 127.26 points, upon analysis it is observed that during the period, the biggest fall was in the scrip of LT and it may be noted that during the exact same period the Noticee No. 2 had placed sell orders worth ₹39.5 crores at -2.52%. This apparently had caused the dip in Sensex.

29. Moving to Spike 2, it is seen that between 15:24:08 to 15:24:20 there was a rise in Sensex IEP of 132.67 points from 77707.84 to 77840.51. An analysis of the trade log and order log of the period was conducted and is summarised as follows: Table 10 Parameter Market Total Time Window 15:24:08 to 15:24:20 (12 seconds) Total Sell Orders 37 orders Total Buy Orders 189 orders (165 Limit, 24 Market) Total Buy Order Value ₹131,74,23,873 (~₹131.74 Cr) Total Sell Order Value ₹2,97,11,083.8 (~₹ 2.97 Cr) 30. From the table above, it is observed that during the period 15:24:08 to 15:24:20 (12 seconds) 189 buy orders were placed and out of that 165 were limit orders. These orders aggregate to a value of approx. ₹131.74 crores. The nature of order placement of Copthall in this spike period is also examined and is summarised as follows:

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026

Table 11 Particulars PAN: AAACC4303M Other Market Total / Market Impact Copthall Mauritius Invest Participants ment Limited Limit Buy Orders 108 57 165 Order Value ₹126,58,69,574.00 ₹5,15,54,299.00 ₹ 1,31,74,23,873 (~₹126.59 Cr) (~₹5.16 Cr) % Share of Value 96.09% 3.91% 100.00% Price where limit +3% above reference < +1.0% (All 57 orders Aggressive price orders placed price below +1%) markup Scrip Coverage Placed across all Sensex Distributed across Systematic index-wide scrips market impact 31. From the table above, it is observed that 108 of the 165 total limit buy orders were placed by Copthall. Further, the gross order value of the orders placed by Copthall is approx. ₹126.59 Crore in comparison to total market gross order value of ₹131.74 Crore i.e., 96.09% of the total order value. The table given below shows the summary of the orders placed by Copthall that caused this spike. The table clearly shows that the buy orders were placed at a range of 2.7% to 3% above the reference price. Table 12 Symbol Scrip Name Order Order Buy Order Sum of Sum of Max of Deviati time start time end Price Order Order Value Referen on Quantity ce price from (RP) RP 500034 BAJFINANCE 15:24:08 15:24:12 1120.5 40954 4,58,88,957 1087.9 2.997% 500049 BEL 15:24:08 15:24:17 421.55 66835 2,81,74,294 409.3 2.993% 500112 SBIN 15:24:08 15:24:08 1108.5 42938 4,75,96,773 1076.25 2.997% 500114 TITAN 15:24:08 15:24:08 5188.75 4222 2,19,06,903 5037.65 2.999% 500180 HDFCBANK 15:24:08 15:24:08 748.6 157556 11,79,46,42 726.8 2.999% 2 500209 INFY 15:24:08 15:24:08 1201.45 36055 4,33,18,280 1166.5 2.996% 500247 KOTAKBANK 15:24:08 15:24:17 402.95 111631 4,49,81,711 391.25 2.990% 500251 TRENT 15:24:08 15:24:20 3083 6483 1,99,87,089 2993.25 2.998% 500325 RELIANCE 15:24:08 15:24:08 1352.5 69945 9,46,00,613 1313.15 2.997% 500470 TATASTEEL 15:24:08 15:24:17 189.25 152703 2,88,99,043 183.75 2.993% 500510 LT 15:24:08 15:24:08 4178.95 14319 5,98,38,385 4057.25 3.000% 500520 M&M 15:24:08 15:24:17 3503.05 17290 6,05,67,735 3401.05 2.999% 500696 HINDUNILVR 15:24:08 15:24:18 2150.9 16721 3,59,65,199 2088.3 2.998% 500820 ASIANPAINT 15:24:08 15:24:18 2816.7 8402 2,36,65,913 2734.7 2.999% 500875 ITC 15:24:08 15:24:13 285.6 139150 3,97,41,240 277.3 2.993% 524715 SUNPHARMA 15:24:08 15:24:12 1996.35 17730 3,53,95,286 1938.25 2.998% 532174 ICICIBANK 15:24:08 15:24:08 1452.65 74113 10,76,60,24 1410.35 2.999% 9 532215 AXISBANK 15:24:08 15:24:18 1255.85 51669 6,48,88,514 1219.3 2.998% 532281 HCLTECH 15:24:08 15:24:13 1405.45 18037 2,53,50,102 1364.55 2.997%

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026

Symbol Scrip Name Order Order Buy Order Sum of Sum of Max of Deviati time start time end Price Order Order Value Referen on Quantity ce price from (RP) RP 532454 BHARTIARTL 15:24:08 15:24:08 1998.65 31494 6,29,45,483 1940.45 2.999% 532500 MARUTI 15:24:08 15:24:18 14278.05 2248 3,20,97,056 13862.2 3.000% 532538 ULTRACEMC 15:24:08 15:24:17 12011.25 2239 2,68,93,189 11661.4 3.000% O 5 532540 TCS 15:24:08 15:24:17 2438.8 19486 4,75,22,457 2367.8 2.999% 532555 NTPC 15:24:08 15:24:20 352.6 79214 2,79,30,856 342.35 2.994% 532755 TECHM 15:24:08 15:24:12 1688.05 9271 1,56,49,912 1638.9 2.999% 532898 POWERGRID 15:24:08 15:24:18 275.55 83388 2,29,77,563 267.55 2.990% 532921 ADANIPORTS 15:24:08 15:24:13 1701 12855 2,18,66,355 1651.5 2.997% 532978 BAJAJFINSV 15:24:08 15:24:12 2080.9 8822 1,83,57,700 2020.3 3.000% 539448 INDIGO 15:24:08 15:24:12 5498.95 3409 1,87,45,921 5338.8 3.000% 543320 ETERNAL 15:24:08 15:24:08 327.6 74818 2,45,10,377 318.1 2.986% Total 13,73,997 1,26,58,69,5 74 32. Further, in comparison to other market participants, it is noted that the orders placed by Copthall were limit orders with limit near the upper permissible limit under the CAS regulation (3% above reference price), whereas, orders of other participants varied between 0% to 1%. Further, Copthall placing buy orders across all the constituents of SENSEX around the same time in a coordinated manner, especially at higher prices indicates a prima facie intent to manipulate the closing price by increasing the IEP of SENSEX in CAS. C.3 Spike 3 (15:25:49 to 15:26:17) 33. During the period between 15:25:49 and 15:26:17 (28 seconds) another significant spike of 405.8 points was observed, wherein SENSEX moved from 77787.94 to 78193.02. The price movement in the constituents during the period (15:25:49 to 15:26:17) was examined. The details of the IEP movement of SENSEX constituent scrips, with significant change above reference price during the aforesaid period is as given below: Table 13 Scrip Code Name % Change in IEP 500510 LT 2.89 543320 ETERNAL 1.60 500875 ITC 1.01

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026

500251 TRENT 0.86 500114 TITAN 0.63 532174 ICICIBANK 0.50 500325 RELIANCE 0.50 500112 SBIN 0.50 500209 INFY 0.50 500180 HDFCBANK 0.50 539448 INDIGO 0.45 532281 HCLTECH 0.30 500520 M&M 0.18 532215 AXISBANK 0.10 500049 BEL 0.10 500247 KOTAKBANK 0.09 532454 BHARTIARTL 0.04

34. An analysis of the trade log and order log of the period was conducted and the same is summarised as follows: Table 14 Parameter Market Total Time Window 15:25:49 to 15:26:17 (28 seconds) Total Sell Orders 118 orders Total Buy Orders 176 orders (All 176 Limit) Total Buy Order Value ₹115,14,87,476 (~₹115.15 Cr) Total Sell Order Value ₹ 84,22,14,315.5 (~₹ 84.22 Cr) 35. From the table above, it is observed that during the period 15:25:49 to 15:26:17 (28 seconds) 176 buy orders were placed and out of that all 176 were limit orders. These orders aggregate to a value of approx. ₹115.15 crores. The nature of order placement of Copthall in this spike period was also examined and the same is summarised as follows: Table 15 Particulars PAN: AAACC4303M Other Market Participants Total / Market Copthall Mauritius Investme Impact nt Limited Limit Buy Orders 32 144 176 Order Value ₹98,11,70,665 (~98.12 Cr) ₹17,03,16,810 (~17.03 Cr) ₹115,14,87,476 (~115.14 Cr) % Share of Value 85.21% 14.79% 100.00% Price where limit orders +3% above reference price < +2.0% (143 of 144 Aggressive price placed Orders) markup

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026

Scrip Coverage Placed across all Sensex Only 1 Order in ICICI Systematic index-scrips placed above 2% for a wide impact value of Rs. 4.23 Cr. 36. From the table above, it is observed that 32 of the 176 total limit buy orders were placed by Copthall. Further, the gross order value of the orders placed by Copthall is approx. ₹98.12 Crore in comparison to total market gross order value of ₹115.15 Crore i.e., 85.21% of the total order value.

37. Further, in comparison to other market participants, it is seen that the orders placed by Copthall were limit orders with limit near the maximum permissible limit under the CAS regulation (3% above reference price), whereas, orders of other CAS participants (143 of the 144 orders) varied between 0% to 2%. The only exception being one order in ICICI placed above 2% for a value of ₹4.23 Crore.

38. The price rise in Spike 3 period is further accentuated by the bulk order cancellations of pending sell orders across 8 scrips by the Noticee No. 2. The cancellation of the said high value sell orders completely changed the order matching and caused a sudden spike in SENSEX IEP due to the presence of aggressive buy orders of Copthall. The details of the nature of order placement by the Noticee No. 2 has been discussed in detail in the subsequent sections of this order.

39. Sequence of events in Spike 3: The Noticee No. 2 cancelled its sell orders by 15:26:05 and the SENSEX IEP rose sharply because of the sudden order imbalance i.e., presence of aggressive buy orders of Copthall and the lack of counteraction by a large sell order. At 15:26:14, Copthall again placed buy orders across all 30 Sensex scrips at higher prices and caused an additional jump in the SENSEX IEP. Subsequently, at 15:26:21, Copthall cancelled all its latest buy orders (placed at 15:26:14) worth ₹98,11,70,665.40 across 30 Sensex scrips. It appears that the cancellation was done because an upward move in Sensex closing price had already taken place. Since the upward move was already caused and carried

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026 forward by Copthall’s initial aggressive buy orders and the subsequent sell order cancellation by Mansi, Copthall appear to have cancelled the latest buy orders to prevent additional investments.

40. Further, it may be noted that the last set of buy orders at 15:26:14 by Copthall had increased the Sensex IEP by 66 points only. Since the additional aggressive buy orders was only increasing the IEP by 66 points, this could also be the reason for cancellation. This also shows that the buy orders worth ₹98 Crore of Copthall were with an intent to artificially inflate the IEP of Sensex.

41. Hence, it is prima facie established that such aggressive buy orders by Copthall had caused a sustained upward move in IEP of SENSEX constituents and ultimately resulted in SENSEX closing at 78080, whereas, equivalent move based on Nifty movement would have resulted in SENSEX closing at 77840. The close of Sensex was 77,966 on August 12, 2026. Nifty closed on August 13 at -0.16% compared to August 12, 2026. Hence, the equivalent Sensex value is ~ 77840. C.4 Drawdown by Mansi (15:21:03 to 15:26:00) 42. During the period between 15:21:03 and15:26:00 (~5 minutes) Mansi placed sell orders at lower prices with the sell order value being ₹145.65 crores and cancelled them between 15:26:02 to 15:26:05. This cancellation created an immediate surge in SENSEX IEP by 232.96. By using inverse logic, it can be inferred that the sell orders of Mansi were causing an artificial suppression of IEP by at least 232.96 points in Sensex.

43. It is also observed that during the period, Mansi placed large sell orders at prices lower than reference prices. Mansi had placed sell orders worth ₹105.04 Crores in scrips of RELIANCE, SBIN, ETERNAL, ICICIBANK, LT, INFY at prices in the range of -1.5% to -3% of reference price. The details of sell orders placed by Mansi in CAS are given in the table below.

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026

Table 16 Symbol Scrip Name Sum of Order Sell Order Average Reference Deviation Order time Value Sell price (RP) from RP Quantity Order price 500325 RELIANCE 100000 15:22:38 12,75,00,000 1,275.00 1313.15 -2.91% 500112 SBIN 100000 15:23:17 10,45,00,000 1,045.00 1076.25 -2.90% 543320 ETERNAL 255000 15:21:17 7,90,50,000 310.00 318.1 -2.55% 532174 ICICIBANK 152000 15:22:58 20,90,60,000 1,375.39 1410.35 -2.48% 500510 LT 105000 15:21:03 41,53,00,000 3,955.24 4057.25 -2.51% 500209 INFY 100000 15:23:09 11,50,00,000 1,150.00 1166.5 -1.41% 500114 TITAN 55000 15:24:56 27,59,85,000 5,017.91 5037.65 -0.39% 532454 BHARTIARTL 10000 15:26:51 1,93,40,000 1,934.00 1940.45 -0.33% 500875 ITC 400000 15:21:35 11,08,00,000 277.00 277.3 -0.11% Total 1277000* 1,45,65,35,000 *Includes 10,000 Bharti Airtel and 2,000 ICICI shares ordered after cancellation. 44. Details of sell orders cancelled by Mansi during 15:26:02 to 15:26:05 are given in the table below. Table 17

45. It can be seen from the table above that Mansi cancelled 12,65,000 sell orders worth ₹143,43,85,000 during the CAS. It has cancelled all the 12,65,000 sell orders placed prior to 15:26:00. This also shows that the sell orders for 5 minutes were prima facie meant to suppress the IEP rather than performing a legitimate sell transaction.

46. Scrips which showed the maximum upward movement during the time of cancellation of orders by Mansi were the ones that contributed most to the Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026 P AAAAAAAAAAAA A AAAAAAAAAAAA N DDDDDDDDDDDD CCCCCCCCCCCC MMMMMMMMMMMM 666666666666 666666666666 444444444444 555555555555 DDDDDDDDDDDD S

T y o m ta b o l 5 0 0 5 0 0 5 0 0 5 0 0 5 0 0 5 0 0 5 0 0 5 0 0 5 3 2 5 3 2 5 4 3 5 4 3 l 112355881133 110211777722 249500554400 S c rip N S B IN T IT A N IN F Y R E L IA N L T L T IT C IT C IC IC IB A IC IC IB A

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1 u 1 111 12 12 2 a 05000 55505 6 n 0500050000055 tity 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 C a n c e lle

1 d 12113

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4 v a lu 0 4 5 0 7 5 9 8 1 5 0 0 2 7 5 0 9 5 0 0 2 0 3 0 4 1 5 5 6 9 2 5 6 8 7 5 3 7 5 0 7 7 5 0 1 5 5 3 4 3 8 e 0 0 5 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 5 0 0000000000000 0000000000000 suppression of SENSEX IEP. It can be seen in the table below clearly that the price of the below given 7 scrips was suppressed because of sell orders of Mansi and upon cancellation of sell orders, they showed a sudden rise in price. Table 18

Scrip Name Sum of % Upward Change Whether Mansi after sell order cancelled Cancelled Order by Mansi LT 2.89% Yes ETERNAL 1.08% Yes ITC 0.90% Yes TITAN 0.63% Yes INFY 0.50% Yes RELIANCE 0.34% Yes SBIN 0.27% Yes

47. Hence, it is clearly established that the sell orders by Mansi at lower limits were causing the suppression of the SENSEX IEP and these sell orders that were cancelled during 15:26:02 to 15:26:05 prima facie reveals the intention of Mansi to never legitimately sell these shares but to knowingly suppress the IEP.

D. OBSERVATIONS ON UNUSUAL TRADING PATTERN OF THE NOTICEES

48. As per the economic behavioural science, a participant seeking to purchase securities would generally seek to purchase at the prevailing market price or at a price lower than the prevailing market price. In the same way, a participant seeking to sell securities would ordinarily seek to sell at the prevailing market price or at a price higher than the prevailing market price. Such conduct is broadly consistent with the standard economic theory which states that businesses try to maximise their profits, leading market forces to natural balance through supply and demand.

49. In this regard, the fact that a participant places a buy order at a high price away from the prevailing reference price/IEP, by itself, would not

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026 necessarily be indicative of any misconduct. However, when participants repeatedly place large buy orders at prices substantially above the prevailing reference price/IEP, it warrants an examination of conduct of the participants. In other case, if a participant places large sell orders at prices substantially below the prevailing reference price/IEP, particularly when such orders are subsequently cancelled or such orders have a significant concentration the trading activity warrants examination as to its intent, economic rationale and purpose.

50. The trading pattern of Copthall placing large buy orders at significantly higher prices at three times and Mansi placing large sell orders at lower prices and then subsequently cancelling them is prima facie highly unusual and needs to be examined with their possible positions in F&O.

51. Observations on the trading pattern of Copthall: a. As a buyer, there does not appear to be any economic rationale for Copthall to place large buy orders across the Sensex constituents at prices 3% above the reference price, particularly when the prevailing IEP was much lower. b. Buy orders were placed by Copthall across all Sensex constituents within very short intervals and in 2 instances at the exact same time. c. The pattern also indicated that Copthall did not intend to acquire the securities under its last buy order because it cancelled that buy order aggregating to an amount approx. ₹98.12 crore across 30 Sensex constituents which was 32.79% of its outstanding buy orders. d. The placement of buy orders at higher prices prima facie appear to have been done with an intent to influence upward movement of the IEP of the underlying securities and, consequently, the Sensex. e. One economic rationale for such trading could prima facie be that the F&O position of the entity provided an economic incentive for engineering such movements in SENSEX IEP and consequently, the closing price.

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026

52. Observations on the trading pattern of Mansi: a. There does not appear to be any economic rationale for Mansi placing sell orders aggregating 12.65 lakh shares across eight Sensex constituents at prices substantially below the reference price. The aforesaid sell orders of Mansi remained in the system until 15:26:01 and then subsequently were cancelled across all 8 scrips within short interval of 4-5 seconds. b. The placement and cancellation of the sell orders prima facie appear to have been done with the intent to influence the IEP of the underlying securities downward and consequently, the Sensex. c. One economic rationale for such trading could prima facie be that the F&O position of the entity provided an economic incentive for engineering such movements in SENSEX IEP until their sell orders remained in the system.

53. The trading pattern of the entities was therefore, examined not merely on the basis of the individual orders, but also having regard to their size, price, timing, concentration across constituent securities, effect on the IEP and subsequent cancellations, as well as the concurrent F&O positions of the concerned participants.

54. On August 13, 2026, the Sensex was scheduled for weekly expiry at BSE. The reference price of the Sensex at 15:15 was 77,829.60, following which the CAS commenced at 15:20. During the CAS, three significant price movements were observed. The following table depicts those price movements: Table 19 Price Time Sensex movement Change movement +362.02 Spike 1 15:20:41–15:20:43 77,661.40 → 78,023.42 points +132.67 Spike 2 15:24:08–15:24:20 77,707.84 → 77,840.51 points

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026

Price Time Sensex movement Change movement +405.08 Spike 3 15:25:49–15:26:17 77,787.94 → 78,193.02 points 55. The magnitude and extremely short duration of these movements assume significance when viewed along with the order activity of these entities in the underlying Sensex constituents. D.1.1 Activity of Copthall Mauritius Investment Limited 56. During the first spike, in a period of merely two seconds, there were 88 buy orders having an aggregate value of approximately ₹66.64 crore. Copthall alone accounted for approximately ₹66.58 crore, or 99.91% of the entire buy order value. All 32 of Copthall's limit buy orders were placed at a price 3% above the reference price and were spread across all Sensex constituents.

57. The pattern was not confined to the first spike. During the second spike Copthall accounted for approx. ₹126.59 crores or 96.09% of total buy orders. Similarly, during third spike Copthall accounted for approximately ₹98.12 crore, or 85.21% of the total buy-order value, with all 32 of its limit buy orders again being placed at a price 3% above the reference price across all Sensex scrips.

58. Further, at 15:26:21, Copthall simultaneously cancelled its latest buy orders having an aggregate value of approximately ₹98.12 crore across 30 Sensex scrips. D.1.2 Activity of Mansi Share and Stock Broking Private Limited 59. Following the initial upward movement, Mansi placed aggressive sell orders between 15:21:03 and 15:24:59 across eight Sensex constituents aggregating 12.65 lakh shares. Of these, approximately 7.05 lakh shares were placed at a price 2.5% below the reference price, while only 4.6 lakh shares were within 1% below the reference price.

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026

60. The entire quantity of 12.65 lakh shares across the eight scrips was subsequently cancelled between 15:26:02 and 15:26:05.

61. Copthall pushed the IEP of SENSEX higher by placing aggressive buy orders at +3%. They also contributed to 85% of the gross buy value.

62. Mansi pushed the IEP of SENSEX lower for certain time period of ~4 to 5 minutes by placing sell orders at prices much lower than reference price and this downward pressure by Mansi was released when they cancelled their sell orders.

63. It is pertinent to note that the examination or the evidence does not prima facie indicate that the entities acted in concert. It is prima facie noted that both have tried to push the market in directions favourable to them as discussed in the later sections of this order.

64. The role of the two entities is distinguishable from the nature and direction of their respective order placements. Table 20 Principal observed Price Subsequent Apparent Entity activity placement conduct Effect Large buy orders Upward Copthall Mauritius +3% of Partial across Sensex movement in Investment Limited reference price cancellation constituents IEP/Sensex Downward Mansi Share and Large sell orders Cancellation pressure on -1% to -3% of Stock Broking Private across 8 Sensex of entire sell IEP/Sensex until reference price Limited constituents block cancellation of sell orders. 65. It is observed that the two participants adopted opposite but highly aggressive price-impacting strategies during the same CAS session. D.2 F&O position vis-a-vis cash trading pattern 66. As discussed earlier, one economic rationale to such behaviour by Noticees could be their positions in F&O segment, which is discussed as under:

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026

Copthall Mauritius Investment Limited a. The trading activity of Copthall on major exchanges (NSE and BSE) was as under: Table 21 Exchange Client Name Gr Buy Value (in ₹) Gr Sell Value (in ₹) BSE COPTHALL MAURITIUS INVESTMENT LIMITED 220,79,71,646 9,82,37,257 NSE 1,030,43,18,051 49,69,43,024 Total 12,51,22,89,697 59,51,80,281 b. The F&O position of Copthall for the relevant period shows that they had certain outstanding expiry-day Sensex option positions that were open as at 15:20 on August 13, 2026. The outstanding position is given in the table below: Table 22 Contract Name Net Buy Net Sell Remarks Qty. Qty. SENSEX2681377500CE 26560 0 carried forward from previous days SENSEX2681377500PE 0 26560 carried forward from previous days SENSEX2681378000CE 84200 0 position built during the day SENSEX2681378000PE 0 84200 position built during the day SENSEX2681378500CE 12640 0 carried forward from previous days SENSEX2681378500PE 0 12640 carried forward from previous days c. The above table shows that Copthall had net buy call positions and net sell put positions for each of 77500, 78000, 78500 strike prices of the expiry day. d. It may be seen that the payoff of the above strategy is known as the Synthetic Long Asset Position or Synthetic Factor. Any upward movement in the Sensex above the strike price would generate unlimited profit or help avoid significant pay-out to the put buyers for Copthall. e. Hence, it is seen that the aggressive buy orders of Copthall in SENSEX constituents were entered with the prima facie intention to keep the index value at higher level so as to generate prima facie wrongful gains from the outstanding expiry day option positions.

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026 f. Thus, the cash-market/CAS activity of Copthall cannot be viewed in isolation from its contemporaneous positions in expiry day Sensex options. The timing and direction of the underlying trading activity and the corresponding Sensex Options warrant consideration together.

67. Mansi Share and Stock Broking Private Limited a. The trading activity of Mansi on major exchanges (NSE and BSE) was as under: Table 23 Exchange Client Name Gr Buy Value (in ₹) Gr Sell Value (in ₹) BSE MANSI SHARE AND STOCK BROKING 274,91,76,408 292,71,29,490 PRIVATE LIMITED NSE 657,59,60,746 637,66,63,720 Total 932,51,37,154 930,37,93,209 b. The F&O position of Mansi for the relevant period shows that they had certain outstanding expiry-day Sensex option positions that were open as at 15:20 on August 13, 2026. The outstanding position is given in the table below. Table 24 Contract Name Buy Net Qty Sell Net Qty Remarks SENSEX2681377800CE 5000 0 Position built during the day SENSEX2681377800PE 42020 0 Position built during the day SENSEX2681377900PE 83320 0 Position built during the day SENSEX2681378000PE 44000 0 Position built during the day c. The above table shows that other than the 77800 CE, Mansi had open position of net buy in Put options of 77800 PE, 77900 PE and 78000 PE for the expiry day August 13, 2026. d. Any downward movement in the SENSEX would generate wrongful gains for Mansi.

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026 e. Hence, the aggressive sell orders should be seen as a prima facie intentional activity by Mansi to suppress the SENSEX IEP and generate wrongful gains. f. It is pertinent to note that, during 15:21:03 to 15:26:00 Mansi placed aggressive sell orders and suppressed the SENSEX IEP and in the same 5 minutes exited all their outstanding put option positions at a profit which otherwise would have expired worthless. The summary of the transactions is given in detail in the subsequent sections of the order. g. Thus, the cash-market/CAS activity of Mansi cannot be viewed in isolation from its contemporaneous positions in expiry day Sensex options. The timing and direction of the underlying trading activity and the corresponding F&O positions warrant consideration together.

D.3 Consideration of issues and prima facie findings 68. At this stage, it is essential to examine if the acts of Noticees are prima facie in violation of provisions of regulations 3(a), (b), (c), (d), 4(1), 4(2)(a), (b), (d), (e) and (g) of the SEBI (Prohibition of Fraudulent and Unfair Trade Practices Relating to Securities Markets) Regulations, 2003 (“PFUTP Regulations”) and section 12A(a), (b) and (c) of the SEBI Act, 1992. In case the answer to the above is in affirmative, it is required to be examined whether facts of the matter warrant an urgent action in exercising powers bestowed upon SEBI under provisions of sections11 and 11B of the SEBI Act. The relevant provisions have been reproduced below for reference:

“SEBI Act, 1992 Functions of Board. Section 11 (1) Subject to the provisions of this Act, it shall be the duty of the Board to protect the interests of investors in securities and to promote the development of, and to regulate the securities market, by such measures as it thinks fit

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026 (4) Without prejudice to the provisions contained in sub-sections (1), (2), (2A) and (3) and section 11B, the Board may, by an order, for reasons to be recorded in writing, in the interests of investors or securities market, take any of the following measures, either pending investigation or inquiry or on completion of such investigation or inquiry, namely: — (a) suspend the trading of any security in a recognised stock exchange; (b) restrain persons from accessing the securities market and prohibit any person associated with securities market to buy, sell or deal in securities; (c) suspend any office-bearer of any stock exchange or self-regulatory organisation from holding such position; (d) impound and retain the proceeds or securities in respect of any transaction which is under investigation; (e) attach, for a period not exceeding ninety days, bank accounts or other property of any intermediary or any person associated with the securities market in any manner involved in violation of any of the provisions of this Act, or the rules or the regulations made thereunder: Provided that the Board shall, within ninety days of the said attachment, obtain confirmation of the said attachment from the Special Court, established under section 26A, having jurisdiction and on such confirmation, such attachment shall continue during the pendency of the aforesaid proceedings and on conclusion of the said proceedings, the provisions of section 28A shall apply: Provided further that only property, bank account or accounts or any transaction entered therein, so far as it relates to the proceeds actually involved in violation of any of the provisions of this Act, or the rules or the regulations made thereunder shall be allowed to be attached; (f) direct any intermediary or any person associated with the securities market in any manner not to dispose of or alienate an asset forming part of any transaction which is under investigation:

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026

Provided that the Board may, without prejudice to the provisions contained in sub-section (2) or sub-section (2A), take any of the measures specified in clause (d) or clause (e) or clause (f), in respect of any listed public company or a public company (not being intermediaries referred to in section 12) which intends to get its securities listed on any recognised stock exchange where the Board has reasonable grounds to believe that such company has been indulging in insider trading or fraudulent and unfair trade practices relating to securities market: Provided further that the Board shall, either before or after passing such orders, give an opportunity of hearing to such intermediaries or persons concerned.

Power to issue directions and levy penalty. Section 11B (1) Save as otherwise provided in section 11, if after making or causing to be made an enquiry, the Board is satisfied that it is necessary, — (i) in the interest of investors, or orderly development of securities market; or (ii) to prevent the affairs of any intermediary or other persons referred to in section 12 being conducted in a manner detrimental to the interest of investors or securities market; or (iii) to secure the proper management of any such intermediary or person, it may issue such directions, — (a) to any person or class of persons referred to in section 12, or associated with the securities market; or (b) to any company in respect of matters specified in section 11A, as may be appropriate in the interests of investors in securities and the securities market. Explanation. —For the removal of doubts, it is hereby declared that the power to issue directions under this section shall include and always be Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026 deemed to have been included the power to direct any person, who made profit or averted loss by indulging in any transaction or activity in contravention of the provisions of this Act or regulations made thereunder, to disgorge an amount equivalent to the wrongful gain made or loss averted by such contravention.

Prohibition of manipulative and deceptive devices, insider trading and substantial acquisition of securities or control. Section 12A. No person shall directly or indirectly— (a) use or employ, in connection with the issue, purchase or sale of any securities listed or proposed to be listed on a recognized stock exchange, any manipulative or deceptive device or contrivance in contravention of the provisions of this Act or the rules or the regulations made thereunder; (b) employ any device, scheme or artifice to defraud in connection with issue or dealing in securities which are listed or proposed to be listed on a recognised stock exchange; (c) engage in any act, practice, course of business which operates or would operate as fraud or deceit upon any person, in connection with the issue, dealing in securities which are listed or proposed to be listed on a recognised stock exchange, in contravention of the provisions of this Act or the rules or the regulations made thereunder;

Delegation. Section 19. The Board may, by general or special order in writing delegate to any member, officer of the Board or any other person subject to such conditions, if any, as may be specified in the order, such of its powers and functions under this Act (except the powers under section 29) as it may deem necessary.

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026

PFUTP Regulations, 2003 Definitions Regulation 2 (1).... (b) “dealing in securities” includes: (i) an act of buying, selling or subscribing pursuant to any issue of any security or agreeing to buy, sell or subscribe to any issue of any security or otherwise transacting in any way in any security by any persons including as principal, agent, or intermediary referred to in section 12 of the Act, either by themselves or through mule accounts; (ii) such acts which may be knowingly designed to influence the decision of investors in securities; and (iii) any act of providing assistance to carry out the aforementioned acts. (c) “fraud” includes any act, expression, omission or concealment committed whether in a deceitful manner or not by a person or by any other person with his connivance or by his agent while dealing in securities in order to induce another person or his agent to deal in securities, whether or not there is any wrongful gain or avoidance of any loss, and shall also include— (1) a knowing misrepresentation of the truth or concealment of material fact in order that another person may act to his detriment; (2) a suggestion as to a fact which is not true by one who does not believe it to be true; (3) an active concealment of a fact by a person having knowledge or belief of the fact; (4) a promise made without any intention of performing it; (5) a representation made in a reckless and careless manner whether it be true or false; (6) any such act or omission as any other law specifically declares to be fraudulent,

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026 (7) deceptive behavior by a person depriving another of informed consent or full participation, (8) a false statement made without reasonable ground for believing it to be true. (9) the act of an issuer of securities giving out misinformation that affects the market price of the security, resulting in investors being effectively misled even though they did not rely on the statement itself or anything derived from it other than the market price. And “fraudulent” shall be construed accordingly;

Prohibition of certain dealings in securities Regulation 3 No person shall directly or indirectly— (a) buy, sell or otherwise deal in securities in a fraudulent manner; (b) use or employ, in connection with issue, purchase or sale of any security listed or proposed to be listed in a recognized stock exchange, any manipulative or deceptive device or contrivance in contravention of the provisions of the Act or the rules or the regulations made there under; (c) employ any device, scheme or artifice to d fraud in connection with dealing in or issue of securities which are listed or proposed to be listed on a recognized stock exchange; (d) engage in any act, practice, course of business which operates or would operate as fraud or deceit upon any person in connection with any dealing in or issue of securities which are listed or proposed to be listed on a recognized stock exchange in contravention of the provisions of the Act or the rules and the regulations made there under.

Prohibition of manipulative, fraudulent and unfair trade practices Regulation 4

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026 (1) Without prejudice to the provisions of regulation 3, no person shall indulge in a manipulative, fraudulent or an unfair trade practice in securities markets. Explanation.– For the removal of doubts, it is clarified that- (i)any act of diversion, misutilisation or siphoning off of assets or earnings of a company whose securities are listed or any concealment of such act or any device, scheme or artifice to manipulate the books of accounts or financial statement of such a company that would directly or indirectly manipulate the price of securities of that company, or (ii)transactions through mule accounts for indulging in manipulative, fraudulent and unfair trade practice shall be and shall always be deemed to have been included in sub-regulation (1). (2) Dealing in securities shall be deemed to be a manipulative fraudulent or an unfair trade practice if it involves any of the following:— (a) knowingly indulging in an act which creates false or misleading appearance of trading in the securities market; (b) dealing in a security not intended to effect transfer of beneficial ownership but intended to operate only as a device to inflate, depress or cause fluctuations in the price of such security for wrongful gain or avoidance of loss; (d) inducing any person for dealing in any securities for artificially inflating, depressing, maintaining or causing fluctuation in the price of securities through any means including by paying, offering or agreeing to pay or offer any money or money's worth, directly or indirectly, to any person; (e) any act or omission amounting to manipulation of the price of a security including, influencing or manipulating the reference price or bench mark price of any securities;

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026 (g) entering into a transaction in securities without intention of performing it or without intention of change of ownership of such security; .....”

69. I note that section 12A(a), (b) and (c) of the SEBI Act, 1992 and furthermore, regulation 3(a), (b), (c) and (d) of the PFUTP Regulations inter alia prohibit, buying, selling or otherwise dealing in securities in a fraudulent manner, employment of any manipulative/deceptive device, scheme or artifice to defraud in connection with dealing in securities including in connection with issue, purchase or sale of any securities listed or proposed to be listed, engaging in any act, practice, course of business which operates or would operate as fraud or deceit upon any person in connection with dealing in securities, directly or indirectly.

70. Further, regulation 2(1)(c) of the PFUTP Regulations provides an inclusive and broad definition of the term fraud, which also includes any act or omission as any other law specifically declares to be fraudulent. I note that section 12A(a), (b) and (c) of the SEBI Act, 1992 and regulations 3 and 4 of the PFUTP Regulations quoted above, inter alia, prohibit: i. dealing in securities which is manipulative, fraudulent or an unfair trade practice; ii. use of or employment of any manipulative or deceptive device or contrivance, in contravention of the provisions of the SEBI Act or rules or regulations made thereunder; iii. employment of any device scheme or artifice to defraud; iv. engagement in any act, practice, course of business which operate/would operate as fraud or deceit upon any person in contravention of the provisions of the SEBI Act or rules or regulations made thereunder;

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026 v. knowingly indulging in an act creating false or misleading appearance of trading in the securities market; vi. dealing in securities while not intending to effect transfer of beneficial ownership of securities but to operate only as a device to inflate, depress or cause fluctuations in price of such security; vii. inducing any person for dealing in securities for artificially inflating and/or causing fluctuation in price of security; viii. any act to manipulate the price of a security which shall include influencing or manipulating the reference price or bench mark price; and ix. entering into transactions in securities with no intention of performing them. 71. In the facts of the present case, I note from the facts and circumstances highlighted during the preliminary examination by SEBI that the modus operandi adopted by Noticees was to prima facie involve/employ the use of large and aggressive buy/sell orders in the underlying constituents of Sensex during the CAS to influence the IEP/closing price of the Sensex to enrich themselves with wrongful gains. To achieve an advantageous pay-off factor from the positions held by Noticees in the Sensex options expiring on the same day which is prima facie manipulative in nature.

72. In the case of Copthall, large buy orders were placed across the Sensex constituents at prices materially above the reference price and within short intervals, resulting in sharp upward movements in the IEP and ultimately closing at a higher value. At the same time, Copthall had outstanding long call and short put positions which derived benefits from the prima facie artificial upward price movement in Sensex constituents engineered by Copthall.

73. In the case of Mansi, it had open positions in expiry day put options at the start of CAS. The payoff from these put options benefitted from the artificial

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026 suppression of IEP for 5 minutes which was prima facie engineered by Mansi by placing aggressive sell orders in 8 constituent scrips of Sensex at significantly lower prices than the reference price. Once the existing positions in put options were squared off to its advantage, Mansi cancelled sell orders, clearly showcasing prima facie that the intent of placing sell orders was prima facie not bonafide but to artificially suppress the IEP and benefit from their outstanding put options position.

74. The aforesaid sequence, when considered together with the F&O positions of Noticees, prima facie indicates that the underlying cash-market activity was not undertaken as an independent trading strategy but had a direct economic relevance to the Noticees positions in Sensex options.

75. It is not prima facie being alleged that Noticees acted in concert. However, the material available on record highlights that each of the Noticees tried to create a favourable move for themselves in the Sensex constituents to enrich themselves with wrongful gains in their expiry day Sensex Option positions.

76. The preliminary findings show that the activity of Noticees in the underlying securities during the CAS had a corresponding impact on their expiry-day Sensex option positions. These large buy orders and large sell orders which were placed and then cancelled, allowed Noticees to avoid losses or wrongfully profit themselves from positions in derivatives trades that otherwise would have expired worthless.

77. The economic linkage may therefore be represented as follows: Figure 2 Modus Operandi of Noticee No.1 Large / aggressive orders in Sensex constituent securities │ ▼ Change in IEP of Sensex constituents │

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026

▼ Consequent movement in IEP of Sensex │ ▼ Sensex closing at a higher value │ ▼ Change in expiry value of Sensex option positions / Squaring off Sensex option positions │ ▼ Additional F&O profit / avoidance of F&O loss 78. In case of the Noticee No. 2, modus operandi was to benefit from temporary dip by squaring off position in options. D.4 Calculation of Wrongful gains D.4.1 Calculation of Wrongful gains of Copthall Mauritius Investment Limited: 79. Upon perusal of the trade and order log at BSE, it is observed that on August 13, 2026 at 15:20 the number of outstanding contracts in Sensex Options expiring on August 13, 2026 for Copthall were as follows: Table 25 Contract Name Net Buy Net Sell Remarks Qty. Qty. SENSEX2681377500CE 26560 0 carried forward from previous days SENSEX2681377500PE 0 26560 carried forward from previous days SENSEX2681378000CE 84200 0 position built during the day SENSEX2681378000PE 0 84200 position built during the day SENSEX2681378500CE 12640 0 carried forward from previous days SENSEX2681378500PE 0 12640 carried forward from previous days

80. The calculation of wrongful gains for the entity Copthall entails the consideration of additional profit generated from affecting the closing price of Sensex and the additional payments avoided, which would otherwise have been payable to buyers of the put options because of the Sensex ending higher and put options expiring worthless. For the purpose of calculation of the wrongful gains it is reasonable to consider the fair

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026 settlement price of Sensex based on Nifty 50 closing value as 77840. The close of Sensex was 77,966 on August 12, 2026 which is achieved through prima facie manipulation as discussed earlier. Nifty closed on August 13 at -0.16% compared to August 12, 2026. Hence, the equivalent Sensex value is ~ 77840. Table 26 Wrongful gains to Copthall - August 13, 2026 - Expiry day Contract Name Net Net Strike Sensex Payoff Sensex Payoff Unlawful Wrongful Total Buy Sell Ending for actual for gain Pay Pay-out Wrongful Qty. Qty. as per option Ending option Off per Avoidance gains or Nifty buyer buyer Qty. for per Qty. by loss levels Sensex Sensex Copthall Copthall avoided (in at 77840 at 78080 ₹)

SENSEX2681377500CE 26560 0 77500 77840 340 78080 580 240 0 63,74,400 SENSEX2681377500PE 0 26560 77500 77840 0 78080 0 0 0 - SENSEX2681378000CE 84200 0 78000 77840 0 78080 80 80 0 67,36,000 SENSEX2681378000PE 0 84200 78000 77840 160 78080 0 0 160 1,34,72,000 SENSEX2681378500CE 12640 0 78500 77840 0 78080 0 0 0 - SENSEX2681378500PE 0 12640 78500 77840 660 78080 420 0 240 30,33,600 Total 2,96,16,000

81. The detailed calculation of wrongful gains for each outstanding expiry day contract of Copthall, is as follows:

a. SENSEX2681377500CE: If the Sensex had a closing value of 77840 the pay-off for Copthall would have been 340*26560= ₹90,30,400. But the Sensex closed at 78080 because of buying pressure by Copthall and the actual pay-off is ₹1,54,04,800. The wrongful gains are ₹63,74,400. b. SENSEX2681377500PE: This option was deep out of the money and it doesn’t make a difference whether Sensex Expires at 77840 or 78080. Hence, no wrongful gain is attributed here. c. SENSEX2681378000CE: If the Sensex had a closing value of 77840 the pay-off for Copthall would have been 0 because the call option would

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026 have expired worthless. But the Sensex closed at 78080 because of buying pressure by Copthall and the actual pay-off is 80*84200= ₹67,36,000. The wrongful gains are ₹67,36,000. d. SENSEX2681378000PE: If the Sensex had a closing value of 77840 the buyer of the put option would have a pay-off of 160*84200= ₹1,34,72,000 and Copthall would have had to pay the same to the buyer of the option. But the Sensex closed at 78080 because of buying pressure by Copthall and the put option expired worthless and because of which Copthall did not have to make any pay out. Hence, they avoided loss (avoiding paying the option buyer) of ₹1,34,72,000. e. SENSEX2681378500CE: This option was deep out of the money and it doesn’t make a difference whether Sensex Expires at 77840 or 78080. Hence, no wrongful gains are attributed here. f. SENSEX2681378500PE: If the Sensex had a closing value of 77840 then Copthall would have had to make a pay-out of 660*12640= ₹83,42,400. But the Sensex closed at 78080 because of buying pressure by Copthall and the actual pay-out they made is 420*12640= ₹53,08,800. The wrongful gains are ₹30,33,600.

82. The Sensex closed at 78080 and the unlawful gain made by Copthall is ₹2.9616 Crores. While Copthall incurred a nominal price variance of ₹57 Lakhs in the cash segment, this represented a deliberate expenditure to manufacture a terminal index level benefit that generated an asymmetric, irreversible wrongful gain of ₹2.9616 Crores in the derivatives segment, which prima facie could not have been feasible without these prima facie manipulative transactions as detailed above in the order.

D.4.2 Calculation of Wrongful gains of Mansi Share and Stock Broking Private Limited 83. Upon perusal of the trade and order logs it is observed that on August 13, 2026 at 15:20 the number of outstanding contracts in Sensex Options expiring on August 13, 2026 for Mansi is as follows:

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026

Table 27 Buy Net Sell Net Contract Name Remarks quantity quantity Position built during the SENSEX2681377800CE 5000 0 day Position built during the SENSEX2681377800PE 32000 0 day Position built during the SENSEX2681377900PE 75460 0 day Position built during the SENSEX2681378000PE 32000 0 day

84. Unlike in the case of Copthall which had made wrongful gains through settlement prices, Mansi was observed to have placed aggressive sell orders in certain constituents of Sensex at prices lower than the reference price for suppressing the IEP. During this period of artificial suppression of IEP, Mansi exited the put options of 77800, 77900 and 78000 strikes at certain values before they expired worthless when Sensex closed at 78080. However, even during the period from 15:21 to 15:26 Mansi was observed to have purchased more put options and squared them off along with the outstanding contracts as on 15:20. Accordingly, the wrongful gains of Mansi is given in the tables below.

85. Wrongful gains from squaring off of the outstanding contracts are shown in the table below: Table 28

Actual Quantity of Average Value of ending Wrongful Contract Name outstanding value of Sell value of Gain sold sell option SENSEX2681377800CE 5000 - - - - SENSEX2681377800PE 32000 16.39 5,24,480 0 5,24,480

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026

SENSEX2681377900PE 75460 42.05 31,73,093 0 31,73,093

SENSEX2681378000PE 32000 108.35 34,67,200 0 34,67,200 Total 71,64,773 Table 29

86. It may be noted that after the cancellation of sell orders by Mansi, the above put options would have expired worthless. Had the sell orders of Mansi at lower than reference price in Sensex constituents not been there to artificially suppress the IEP, Mansi would not have been able to sell the put options at prices as mentioned above. Hence, the entire sale value may prima facie be considered as wrongful gains.

87. As discussed above, Mansi also purchased put options during 15:21 to 15:26. Squared-off difference made from additional purchase and sale of expiry day puts during 15:21 to 15:26 by Mansi is as under:

Table 30 Contract Extra Extra Average Average Square-off Name Buy Net Sell Net buy price sell price difference Qty. Qty. (in ₹) (in ₹) (in ₹) SENSEX 25980 25980 32.48 16.39 -4,18,018 2681377800PE SENSEX 9360 9360 73.81 42.05 -2,97,274 2681377900PE 88. Other than the outstanding positions as at 15:20, during 15:21 to 15:26 Mansi further purchased and sold put options as shown in table above and had a negative square-off difference of ₹7,15,292. However, considering

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026 that Mansi dealt in these contracts while prima facie manipulating the underlying, the wrongful gains made by Mansi in Sensex options is prima facie considered to be ₹71,64,773 without adding the negative square-off difference.

89. As of August 17, 2026, Mansi had net outstanding position in index options and futures.

90. Accordingly, the total wrongful gains made by both Noticees can be summarised as follows: Table 31 Entity Name Entity PAN Wrongful gains (in ₹) Copthall Mauritius Investment AAACC4303M 2,96,16,000 Limited Mansi Share and Stock AADCM6645D 71,64,773 Broking Private Limited

E. Need for Interim Order 91. It is to be seen that the CAS is a mechanism for determining the closing price of securities through the interaction of orders submitted by the market participants. The integrity of such price discovery is fundamental to the fair and orderly functioning of the securities market and for maintaining the ideal price equilibrium in the securities. The price so discovered in CAS is used for settlement of option contracts, Mutual Fund Net Asset Value (“NAV”) determination, etc.

92. In the present matter, three sharp movements in the Sensex during the CAS on August 13, 2026, including movements of 362.02 points, 132.67 points and 405.08 points within periods ranging from two seconds to 28 seconds were recorded. The order log further shows substantial concentration of the relevant orders two participants, including Copthall accounting for 99.91% and 96.09% of the buy-order value during the first two-second spike and 85.21% during another relevant period. Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026

93. Any manipulation or unfair practices employed to disturb the fair discovery of prices in CAS has to be dealt with sternly by the regulator. Such conduct, if permitted to continue or replicated by other participants in the securities markets, has the potential to undermine the integrity of the CAS mechanism, affect the fair discovery of price through such mechanism and moreover, completely disrupt the orderly functioning of the securities markets. It is imperative to note that such manipulative practices have huge ramifications on participants who trade in F&O segments including retail investors.

94. With the introduction of CAS, volatility and manipulation is expected to reduce, as the system is more efficient and transparent. The design of CAS is such that it provides SEBI with greater ability to identify manipulation as compared to earlier VWAP system.

95. Such conduct, particularly when undertaken prima facie with a malafide intention to manipulate the payoff from the outstanding Sensex options of expiry-day, presents a serious concern from the perspective of market integrity and fair price discovery and undermines the functioning of the securities markets. It is also unfair to other investors who invest in mutual funds and take positions in options based on trust.

96. The need for immediate and urgent directions is further strengthened by the fact that Noticees are found to have created outstanding positions in the coming weekly Sensex options on August 20, 2026. In such circumstances, allowing Noticees to continue participating in the CAS, pending completion of further examination by SEBI in the matter, may expose the securities markets to the risk of recurrence of blatant misconduct observed in the present case.

97. Immediate interim directions are necessitated in the interest of maintaining the integrity of the securities market, fair price discovery and preventing

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026 further possible misuse of the CAS mechanism in the securities markets by entities adopting manipulative practices.

F. DIRECTIONS 98. In view the aforesaid discussions surrounding the misconduct of Noticees and after analysing prima facie evidence available on record about the violations committed by Noticees, I hold that this is a fit case to exercise powers of passing an interim order, pending further examination, so as to insulate the securities market and to protect the wrongful gains made by Noticees from being siphoned off, which may go beyond the regulatory reach. Accordingly, I, in exercise of powers conferred upon me under sections 11(1), 11(4) and 11B(1) read with section 19 of the SEBI Act, hereby, by way of the present ex-parte interim order, issue the following directions, which shall remain in force until further orders: i. The bank accounts of Noticee Nos. 1 and 2 are impounded to the extent of amount as mentioned below, and they are directed to open fixed deposit account(s) in their names so as to credit or deposit the aforesaid impounding amount as per the following table with a lien marked in favour of SEBI and the amount kept therein shall not be released without permission from SEBI; Table 32 Entity Amount (in ₹) Copthall Mauritius Investment Limited 2,96,16,000 Mansi Share and Stock Broking Private Limited 71,64,773 Total 3,67,80,773 ii. Noticee Nos. 1 and 2 shall be restrained from accessing the securities markets (In case of the Noticee No. 2, this direction applies to its proprietary trading account only); iii. Noticee Nos. 1 and 2 are further prohibited from participating in the Call Auction Session (CAS) in the equity segment, whether

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026 directly or indirectly, including by placing, modifying or cancelling orders during the CAS, until further orders (In case of the Noticee No. 2, this direction applies to its proprietary trading account only); iv. Banks, where Noticees are holding bank accounts, are directed that no debits shall be made, without permission of SEBI, in respect of the bank accounts held by Noticees, except for the purposes of transfer of funds to the fixed deposit account(s) as stipulated above. Further, this direction shall not apply to those bank accounts of Noticee No. 2 which deal with clients’ funds, since Noticee No. 2 is a stock broker registered with SEBI and deals with funds of clients; v. Depositories shall also be directed that no debit shall be made, without permission of SEBI, in respect of the demat accounts held by Noticees (In case of the Noticee No. 2 this direction applies to its proprietary account). However, credits, if any, into the accounts may be allowed; vi. Banks and the Depositories are directed to ensure that all the aforesaid directions are strictly enforced.

Further, debits in the bank accounts may also be allowed for amounts available in the account in excess of the amount to be impounded. Banks are allowed to debit the accounts for the purpose of complying with this Order; vii. The Registrar and Transfer Agents shall ensure that, they neither permit any transfer nor redemption of securities, including Mutual Funds units, held by Noticees; viii. Noticees shall not dispose of or alienate any of their assets/properties, except with the prior permission of SEBI; ix. Noticees are further directed to provide a full inventory of all their assets whether movable or immovable, or any interest or investment or charge in any of such assets, including property, details of all their bank accounts, demat accounts, holdings of Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026 shares/securities if held in physical form and mutual fund investments and details of companies in which they hold substantial or controlling interest immediately but not later than 15 days of this Order; x. The directions stipulated in clauses (ii), (iv), (v), (vi), (vii) and (viii) shall cease to apply upon crediting of the impounding amount as per clause (i); xi.

If Noticees have any open position in any exchange traded derivative contracts, as on the date of the order, they can close out/square off such open positions within 3 months from the date of order or at the expiry of such contracts, whichever is earlier. The Noticees are permitted to settle the pay-in and pay-out obligations in respect of transactions, if any, which have taken place before the close of trading hours on the date of this order. Banks are allowed to debit the accounts for the purpose of complying with this direction. xii. Noticees are directed to co-operate with SEBI during the examination/investigation in the instant matter.

99. A detailed investigation/examination by SEBI is required to be done in the instant matter, with respect to violations committed by Noticees and other suspects. The same may be completed expeditiously without being influenced by the prima facie findings in this order.

100. The foregoing prima facie observations contained in this Ex-Parte Interim Order are made on the basis of the material available on record. The Noticees may, within 21 days from the date of receipt of this Order, file their reply/objections, if any, to this Order and may also indicate whether they desire to avail an opportunity of personal hearing on a date and time to be fixed in that regard.

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026

101. This order is without prejudice to the rights of SEBI to take any other action that may be initiated against Noticees in accordance with law, including but not limited to levy of penalty and issuance of directions. This order is further without prejudice to the rights of SEBI to take any action against other persons/entities, not made Noticees in this order.

102. A copy of this order shall be served upon the Noticees, Exchanges, Depositories, RTAs and Banks for necessary action and compliance with the above directions.

103. The concerned stock exchange(s) and market intermediaries shall take necessary steps to give effect to the aforesaid directions.

104. The aforesaid restriction shall apply to any trading account or arrangement through which either of the aforesaid entities may seek to circumvent the direction contained herein.

PLACE: MUMBAI KAMLESH CHANDRA VARSHNEY DATE: AUGUST 19, 2026 WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA

Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE– August 13, 2026