Hansraj Randhir Shah Huf & Others vs Sebi

IN THE SECURITIES APPELLATE TRIBUNAL AT MUMBAI Dated this the 10th day of August, 2026 CORAM : Justice P.S. Dinesh Kumar, Presiding Officer Ms. Meera Swarup, Technical Member Dr. Dheeraj Bhatnagar, Technical Member Appeal No. 007 of 2026 [Along with Misc. Application No. 474 of 2026] BETWEEN: 1. Dipesh Mehta HUF 2. Piyush Mehta HUF Kingston Tower, 3005, 30th Floor, G D Ambekar Marg, Parel, Mumbai - 400 033. ..... Appellants (Mr. Kunal Katariya and Ms. Ashmita Goradia, Advocates i/b SD & Associates for the Appellant) AND: Securities and Exchange Board of India SEBI Bhavan, Plot No. C-4A, G-Block, Bandra-Kurla Complex, Bandra (East), Mumbai - 400 051. ...Respondent (By Mr. Vishal Kanade and Ms. Prapti Kedia, Advocates i/b Agama Law Associates for the Respondent) AND Appeal No. 008 of 2026 [Along with Misc. Application No. 475 of 2026] BETWEEN: 1. Hansraj Randhir Shah HUF 2. Randhir Virji Shah HUF 3. Pinakin Hansraj Shah HUF 4. Punaiben Hansraj Shah 5. Raahul Hansraj Shah HUF 2 1 Veer Building, Ground Floor, 16 D Tagore Road, Santacruz (West), Mumbai - 400 054. ..... Appellants (Mr. Kunal Katariya and Ms. Ashmita Goradia, Advocates i/b SD & Associates for the Appellant) AND: Securities and Exchange Board of India SEBI Bhavan, Plot No. C-4A, G-Block, Bandra-Kurla Complex, Bandra (East), Mumbai - 400 051. ...Respondent (By Mr. Vishal Kanade and Ms. Prapti Kedia, Advocates i/b Agama Law Associates for the Respondent) THESE APPEALS ARE FILED UNDER SECTION 15T OF THE SECURITIES AND EXCHANGE BOARD OF INDIA ACT, 1992 TO QUASH AND SET ASIDE THE IMPUGNED ORDER DATED OCTOBER 23, 2025 PASSED BY THE QUASI JUDICIAL AUTHORITY OF SEBI.

THESE APPEALS COMING ON FOR HEARING THIS DAY, THE TRIBUNAL MADE THE FOLLOWING: ORDER Per: Justice P.S. Dinesh Kumar, Presiding Officer (Oral) These two appeals are directed against order dated October 23, 2025 passed by the QJA1, SEBI2. 2. Appeal No.7 of 2026 is filed by Noticee Nos.12 and 14 (Dipesh Mehta HUF3 and Piyush Mehta HUF respectively). Appeal No.8 of 2026 is filed by Noticee Nos.15,16, 19 to 21 (Hansraj Randhir Shah HUF, Hansraj Randhir Shah, Pinakin 1 Quasi Judicial Authority 2 Securities and Exchange Board of India 3 Hindu Undivided Family 3 Hansraj Shah HUF, Pinakin Hansraj Shah and Raahul Hansraj Shah respectively). 3. We have heard Mr. Kunal Katariya, learned Advocate for appellant and Mr. Vishal Kanade, learned Advocate for SEBI. 4. At the outset, Mr. Kunal Katariya, learned Advocate for the appellants submitted that appellants do not challenge the findings recorded against them by the QJA in the impugned order. They restrict their prayer only on the aspect of proportionality inasmuch as the QJA has not properly considered Section 15J of the SEBI Act, 19924; and prayed that this Tribunal may suitably reduce the quantum of penalty and debarment imposed against the appellants.

5. Mr. Vishal Kanade, learned Advocate for SEBI submitted that there is no error or legal infirmity in the impugned order. Appellants have accepted the findings. The QJA has properly considered the factors to be taken in account while adjudging the quantum of penalty under Section 15J of the SEBI Act, 1992 in paras 130 to 132 of the impugned order. Hence, no interference is called for. 6. We have carefully considered rival contentions and perused the records. 7. Brief admitted facts of the case are, one Jitendra Kewalramani ('Ramani' for short), an authorised person had used appellants' demat accounts in front running the trades of three big clients, namely Bharat Kanaiyalal Sheth Family Trust, Ravi Kanaiyalal Sheth Family Trust and Arjun Discretionary Trust. Securities and Exchange Board of India Act,1992 4 8. Ramani was Noticee No.2 in the SCN. Noticee Nos.1 to 5 and 25 vide order dated 19.12.2024 got their matters settled with the SEBI under SEBI (Settlement Proceedings) Regulations, 2018. 9. Mr. Katariya has submitted that the demat accounts of the appellants herein were used as 'mule' accounts.

Ramani has paid the entire disgorgement amount in terms of settlement. He relied upon the order dated 24.07.2026 passed by the SEBI in the case of Madhav Stock Vision Private Limited ('Madhav Stocks' for short) and others and submitted that the disgorgement ordered in that case was ₹2.51 Crore and the penalty imposed under Section 15HA of the SEBI Act was only ₹5 Lakh each on all noticees therein. He argued that SEBI as a Regulator cannot be permitted to treat the noticees in different cases in an arbitrary manner. 10. The appellants have accepted the findings. Therefore, the question that remains for consideration is, the quantum of debarment and penalty ordered against the appellants. 11. We have perused the order dated 24.07.2026 in Madhav Stocks. That was also a case of front running. Para 33.3 of that order reads thus: 12. Table 7 in para 33.4 of that order reads thus: Penalty Amount (in Noticee ₹) Name of the Noticee No. u/s 15HA of SEBI Act 1. Madhav Stock Vision Pvt. Ltd. 5,00,000 2. Jyotiswaroop Nandkishore Purohit 5,00,000 3. Pankit Bhagwati Jhaveri 5,00,000 4. Rajesh Bhagwati Jhaveri 5,00,000 5. Ajay Sampatraj Jain 5,00,000 6. Rajkumar Prabhu Damani 5,00,000