IN THE MATTER OF EXTENDED FRONT RUNNING BY ROHIT SALGAOCAR, KETAN PAREKH AND OTHERS

WTM/KV/ISD/ISD-SEC-7/31103/2024-25 SECURITIES AND EXCHANGE BOARD OF INDIA EX-PARTE INTERIM ORDER CUM SHOW CAUSE NOTICE UNDER SUB-SECTION (1) OF SECTION 11, SUB-SECTION (4) OF SECTION 11, SUB-SECTION (4A) OF SECTION 11 AND SECTION 11B OF THE SECURITIES AND EXCHANGE BOARD OF INDIA ACT, 1992 READ WITH REGULATION 11 OF THE SECURITIES AND EXCHANGE BOARD OF INDIA (PROHIBITION OF FRAUDULENT AND UNFAIR TRADE PRACTICES RELATING TO SECURITIES MARKET) REGULATIONS, 2003 IN THE MATTER OF EXTENDED FRONT RUNNING BY ROHIT SALGAOCAR, KETAN PAREKH AND OTHERS In respect of: Sr. No. NOTICEES PAN Information Carriers 1. Rohit Salgaocar Not Available (Singapore Citizen) Passport No. - XXX51057B 2. Ketan Vinaychandra Parekh AADPP1505A Front Runners (FRs) 3. GRD Securities Limited AABCG7534M 4. Salasar Stock Broking Limited AADCS8020Q 5. Anirudh Damani AFMPD0253P 6. Ashok Kumar Damani ACXPD6089R 7. Basukinath Properties Private Limited AABCB4123D 8. APR Properties Private Limited AAJCA9378H Facilitators 9. Sanjay Taparia ABLPT6566E 10. Ashok Kumar Poddar AFTPP2389D 11. Sumit Sonthalia ALAPS2324Q Directors 12. Pramod Kumar Drolia ADGPD7175A 13. Bimal Kumar Drolia ACQPD3084M 14. Priya Saraf (also Facilitator) AFDPD9286M 15. Anita Drolia BZYPD8214M 16. Kiran Kumar Sonthalia ALHPS3335E 17. Shyam Saraogi (also Facilitator) AQZPS7213E 18. Pradeep Saraogi (also Facilitator) AIXPS9818F 19. Rachit Poddar (also Facilitator) BDIPP6530J 20. Manoj Kumar Agarwal ACLPA9844P 21. Mahendra Kumar Agarwal ACMPA5091M 22. Renu Agarwal ADAPA2672D (The entities mentioned above are individually known by their respective names or Noticee no. and collectively referred to as “Noticees”) Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

TABLE OF CONTENTS

A. BACKGROUND .............................................................................................................................. 3 B. SUSPECTED MODUS OPERANDI .............................................................................................. 10 C. VARIOUS MOBILE NUMBERS USED BY KETAN PAREKH ..................................................... 11 D. CONNECTION AMONGST NOTICEES AND SHARING OF NPI AND NPI-BASED TRADING INSTRUCTIONS ................................................................................................................................... 26 D.1 CONNECTION BETWEEN ROHIT SALGAOCAR AND KETAN PAREKH AND FLOW OF NPI ................... 26 D.2 FLOW OF NPI-BASED TRADING INSTRUCTIONS FROM KETAN PAREKH TO FRS ............................. 29 D.3 FLOW OF NPI-BASED TRADING INSTRUCTIONS FROM KETAN PAREKH TO GRD SECURITIES LIMITED AND DAMANIS ...................................................................................................................................... 30 D.4 FLOW OF NPI-BASED TRADING INSTRUCTIONS FROM KETAN PAREKH TO SALASAR STOCK BROKING LIMITED 39 D.5 FLOW OF NPI-BASED TRADING INSTRUCTIONS FROM KETAN PAREKH TO APR PROPERTIES PRIVATE LIMITED AND BASUKINATH PROPERTIES PRIVATE LIMITED......................................................................

42 E. COMPARISON OF TRADING VOLUME AND PROFITS OF FRS .............................................. 44 F. ROLE OF ROHIT SALGAOCAR IN OBTAINING AND SHARING NPI ...................................... 53 F.1 ARRANGEMENT BETWEEN SCPL/ROHIT SALGAOCAR AND THE BIG CLIENT ................................. 54 F.2 AGREEMENTS BETWEEN SCPL/ROHIT SALGAOCAR AND TRADING MEMBERS ............................. 59 F.3 MISLEADING AND FALSE INFORMATION PROVIDED BY ROHIT SALGAOCAR TO TRADERS OF THE BIG CLIENT 67 G. ILLUSTRATIONS OF NPI-BASED TRADING ACTIVITIES IN THE ACCOUNTS OF FRS ....... 71 G.1 ILLUSTRATION OF NPI-BASED TRADES BY FR1 AND FR2 IN THE SCRIP OF TITAN COMPANY LIMITED (TITAN/500114) ON APRIL 05, 2023 ................................................................................................... 73 G.2 ILLUSTRATION OF NPI-BASED TRADES BY FR2 IN THE SCRIP OF HDFC LIMITED (HDFC/500010) ON SEPTEMBER 19, 2022 ......................................................................................................................... 82 G.3 ILLUSTRATION OF NPI-BASED TRADE BY FR1, FR2 AND FR3 IN THE SCRIP OF POLICY BAZAR LIMITED (PB FINTECH/ 543390) ON NOVEMBER 11, 2022 ..................................................................................

89 G.4 ILLUSTRATION OF NPI-BASED TRADES BY FR 2 AND FR5 IN THE SCRIP OF CHOLAMANDALAM INVESTMENT AND FINANCE COMPANY LIMITED (CHOLAFIN / 511243) ON JANUARY 09, 2023 ............. 105 G.5 ILLUSTRATION OF NPI-BASED TRADES BY FR 2 AND FR6 IN THE SCRIP OF TUBE INVESTMENTS OF INDIA LIMITED (TIINDIA/540762) ON MAY 18, 2022 ........................................................................... 114 H. CALCULATION OF TOTAL UNLAWFUL GAINS MADE BY NOTICEES FROM TRADING BASED ON NPI AND COMMISSION INCOME OF ROHIT SALGAOCAR....................................... 124 I. ILLUSTRATION OF PROFIT SHARING FROM FR TRADES .................................................. 125 J. FACT FINDING TO SUPPORT ALLEGATION OF MODUS OPERANDI ................................. 140 K. EXAMINATION OF LEGAL ISSUES TO DETERMINE IF THERE IS A VIOLATION ............... 141 L. LIABILITY OF DIRECTORS OF FR1, FR2, FR5 AND FR6....................................................... 158 M. NEED FOR INTERIM EX-PARTE ORDER ................................................................................ 174 N. BASIS OF DISGORGEMENT AND JOINT AND SEVERAL LIABILITY ...................................

177 O. INTERIM ORDER ....................................................................................................................... 180 LIST OF FIGURES MENTIONED IN THE ORDER ............................................................................ 185 LIST OF TABLES MENTIONED IN THE ORDER ............................................................................. 186

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

A. BACKGROUND 1. The present proceedings are emanating from an investigation conducted for the period of January 01, 2021 to June 20, 2023 (hereinafter “Investigation Period”) by the Securities and Exchange Board of India (hereinafter “SEBI”) involving abovementioned Noticees.

2. Considering the prima facie pattern of trades in common scrips by some of Noticees with various funds of an overseas entity which are engaged in the business of Foreign Portfolio Investment (hereinafter collectively referred to as “Big Client”)1, further examination was conducted in order to ascertain whether acts of the above Noticees were in violation of provisions of the Securities and Exchange Board of India Act, 1992 (hereinafter “SEBI Act”), and the Rules/Regulations framed thereunder.

3. SEBI appointed Joint Investigating Authorities under section 11C of the SEBI Act to carry out investigation in the matter. Subsequently, after obtaining due permission of the Competent Court, a search and seizure operation was carried out over a period of three days starting on June 22, 2023 at the premises of 17 entities wherein various documentary and electronic evidences were gathered and statements of various Noticees were recorded on oath. Out of the 17 entities, no case has been made out against 4 entities and these 4 entities have not been named as Noticees in this order. The details of the entities whose premises were searched are as follows:

Table no. 1 Details of entities whose premises were searched by SEBI Sr. Name/Description Address No. Entities who are Noticees in this order pursuant to search and seizure operation

1 Note: Name of the Big Client has not been used and would be supplied to Noticees during inspection of documents and to Hon’ble SAT and Courts during court proceedings. It is further clarified that in the statements/chats used in this order, the term ‘Big Client’ is used in place of the actual name appearing in such statements/chats. Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Sr. Name/Description Address No. 1. Salasar Stock Broking Limited Clive Row, Kolkata, West Bengal – 700001 2. Kiran Kumar Sonthalia New Alipore, Kolkata - 700053 Old Chaurangi Road, Kolkata, West Bengal – 3. Shyam Rajkumar Saraogi 700071 4. Pradeep Kumar Saraogi Alipore Road, Kolkata, West Bengal - 700027 5. Rachit Poddar Alipore H O, Kolkata, West Bengal - 700027 6. Manoj Kumar Agarwal Simla Road, Kolkata, West Bengal – 700006 7. Sanjay Taparia Alipore H O, Kolkata, West Bengal – 700027 Bhowanipore, Kolkata, West Bengal, India – 8. Anirudh Damani 700020 9. Ashok Kumar Damani Bhowanipore, Kolkata, West Bengal - 700021 A.J.C. Bose Road, Kolkata West Bengal - 10. GRD Securities Limited 700020 11. Bimal Kumar Drolia Ballygunj, Kolkata West Bengal – 700019 12. Pramod Kumar Drolia Ballygunj, Kolkata West Bengal -700019 13. Priya Saraf Hazra Road, Kolkata, West Bengal - 700019 Entities who are not Noticees in this order pursuant to search and seizure operation 14. Director of an FR company Alipore, Kolkata West Bengal - 700027 Walkeshwar, Mumbai, Maharashtra - 400006 15. Proprietary trader Vidyavihar West, Mumbai, Maharashtra - 16. Trader of Motilal 400086 17. Trader of Nuvama Borivali East, Mumbai, Maharashtra-400066

4. Based on the evidence collected during the search and seizure operation, it was prima facie suspected that, in addition to traditional front-running, the Frontrunners (hereinafter ‘FRs’) used complex trading strategies to take advantage of the prior knowledge of the impending trades of the Big Client as explained in detail in paragraph 182.

5. A brief description of Noticees and their alleged role is mentioned herein below:

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others i Rohit Salgaocar/Noticee no. 1: A person, residing in Singapore who is the director and authorized signatory of a company called Strait Crossing Pte Limited (hereinafter “SCPL”), who entered into a Memorandum of Understanding (MoU)/referral agreement with Motilal Oswal Financial Services Limited (hereinafter “Motilal”) and Nuvama Wealth Management Limited (hereinafter “Nuvama”) (erstwhile Edelweiss Securities Limited) to refer trades of the Big Client to them. The traders of the Big Client used to consult Rohit Salgaocar prior to placing orders in Indian markets and thus Rohit Salgaocar allegedly had access to the non-public information (hereinafter “NPI”) with respect to substantial impending transaction in various scrips;

ii Ketan Vinaychandra Parekh/ Ketan Parekh/ Noticee no. 2: A person who allegedly obtained NPI from Rohit Salgaocar and orchestrated the whole scheme to communicate trading instructions based on NPI to other Noticees. In the past, Ketan Parekh and his group entities were prohibited from dealing in the securities and debarred from associating with the securities market for a period of 14 years vide SEBI order dated December 12, 2003;

iii GRD Securities Limited/Noticee no. 3/FR1: A registered stock broker who lent access to its proprietary trading account to Sanjay Taparia who used the account for executing trades allegedly based on NPI. The directors of GRD Securities Limited, who were in charge of and responsible to the company for the conduct of its business during the Investigation Period, namely, Pramod Kumar Drolia, Bimal Kumar Drolia, Priya Saraf and Anita Drolia, are also alleged to have contravened the provisions of securities laws;

iv Salasar Stock Broking Limited/Noticee no. 4/FR2: A registered stock broker whose proprietary trading account was used for executing trades allegedly based on NPI. The directors of Salasar Stock Broking Limited

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others who were in charge of and responsible to the company for the conduct of its business during the Investigation Period, namely, Kiran Kumar Sonthalia, Shyam Saraogi and Pradeep Kumar Saraogi, are also alleged to have contravened the provisions of securities laws;

v Anirudh Damani/Noticee no. 5/FR3: A person who executed trades allegedly based on NPI through his trading account. He is also a nephew of Ashok Kumar Damani;

vi Ashok Kumar Damani/Noticee no. 6/FR4: A person who executed trades allegedly based on NPI through his trading account. He is the uncle of Anirudh Damani;

vii Basukinath Properties Private Limited/Noticee no. 7/FR5: A company whose trading account was used by its director, Rachit Poddar, through the computer system placed at his residence for executing trades allegedly based on NPI. The directors of Basukinath Properties Private Limited who were in charge of and responsible to the company for the conduct of its business during the Investigation Period, namely, Rachit Poddar, Manoj Kumar Agarwal and Mahendra Kumar Agarwal, are also alleged to have contravened the provisions of securities laws;

viii APR Properties Private Limited/Noticee no. 8/FR6: A company whose trading account was used by its director Rachit Poddar, through the computer system placed at his residence for executing trades allegedly based on NPI. The directors of Basukinath Properties Private Limited who were in charge of and responsible to the company for the conduct of its business during the Investigation Period, namely, Rachit Poddar, Manoj Kumar Agarwal, Mahendra Kumar Agarwal and Renu Agarwal, are also alleged to have contravened the provisions of securities laws;

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others ix Sanjay Taparia/Noticee no. 9: A person who received trade related instructions allegedly based on NPI from Ketan Parekh and arranged trading accounts for executing such trades;

x Ashok Kumar Poddar/Noticee no. 10: A person who allegedly received trade related instructions based on NPI from Ketan Parekh and passed such information to his son, Rachit Poddar, for executing trades through trading accounts of APR Properties Private Limited and Basukinath Properties Private Limited. Rachit Poddar is a director of both these companies;

xi Sumit Sonthalia/Noticee no. 11: A person who is a trader of Salasar Stock Broking Limited and facilitated execution of trades allegedly based on NPI in the proprietary trading account of Salasar Stock Broking Limited as per the instructions of Ketan Parekh;

xii Pramod Kumar Drolia/Noticee no. 12: A person who is the managing director and promoter of GRD Securities Limited and was in such capacity in charge of, and responsible to, the company for the conduct of its business at the time the alleged contravention was committed by the company;

xiii Bimal Kumar Drolia/Noticee no. 13: A person who is the whole-time director and promoter of GRD Securities Limited and was in such capacity in charge of, and responsible to, the company for the conduct of its business at the time the alleged contravention was committed by the company;

xiv Priya Saraf/Noticee no. 14: A person who is an independent director and promoter of GRD Securities Limited and facilitated trading in the Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others proprietary trading account of GRD Securities Limited through her CTCL ID and was in such capacity in charge of, and responsible to, the company for the conduct of its business at the time the alleged contravention was committed by the company;

xv Anita Drolia/Noticee no. 15: A person who is the director and promoter of GRD Securities Limited and was in such capacity in charge of, and responsible to, the company for the conduct of its business at the time the alleged contravention was committed by the company;

xvi Kiran Kumar Sonthalia/Noticee no. 16: A person who is director of Salasar Stock Broking Limited and was in such capacity in charge of, and responsible to, the company for the conduct of its business at the time the alleged contravention was committed by the company;

xvii Shyam Rajkumar Saraogi/Noticee no. 17: A person who is director of Salasar Stock Broking Limited and who facilitated execution of trades in the proprietary trading account of Salasar Stock Broking Limited upon receipt of trade related instructions allegedly based on NPI from Ketan Parekh;

xviii Pradeep Kumar Saraogi/Noticee no. 18: A person who is an independent director of Salasar Stock Broking Limited and facilitated execution of trades in the proprietary trading account of Salasar Stock Broking Limited upon receipt of trade related instructions allegedly based on NPI from Ketan Parekh;

xix Rachit Poddar/Noticee no. 19: A person who is director of APR Properties Private Limited and Basukinath Properties Private Limited who allegedly executed trades in the trading accounts of APR Properties Private Limited and Basukinath Properties Private Limited upon receipt of trade related instructions allegedly based on NPI from Ketan Parekh;

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others xx Manoj Kumar Agarwal/Noticee no. 20: A person who is director and promoter of APR Properties Private Limited and Basukinath Properties Private Limited and was in such capacity in charge of, and responsible to, the company for the conduct of its business at the time the alleged contravention was committed by the company;

xxi Mahendra Kumar Agarwal/Noticee no. 21: A person who is director of APR Properties Private Limited and Basukinath Properties Private Limited and was in such capacity in charge of, and responsible to, the company for the conduct of its business at the time the alleged contravention was committed by the company;

xxii Renu Agarwal/Noticee no. 22: A person who is director of APR Properties Private Limited and was in such capacity in charge of, and responsible to, the company for the conduct of its business at the time the alleged contravention was committed by the company.

6. The aforesaid FRs, namely FR1 to FR6, have allegedly traded on the basis of instructions received, directly or indirectly, from Ketan Parekh which were allegedly based on NPI with respect to substantial impending transaction of the Big Client in various scrips. The Big Client is a US based fund house which has various funds registered as Foreign Portfolio Investors with SEBI. These FPIs invest in the Indian securities markets through various registered Trading Members (hereinafter “TMs”).

7. It was observed that trades of the Big Client in India were spread across a large number of TMs during the Investigation Period. However, it was also observed that trades of the Big Client undertaken through Nuvama and Motilal matched with trades of FRs.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

8. In the course of the investigation, following information and evidence have been gathered: i Trading data; ii Data/ information gathered from electronic devices; iii Bank account statements; iv Details of IP addresses which were used for the trades executed through the account of some Noticees; v Statement of Noticees recorded on oath; vi KYC, Call Data Records (hereinafter “CDR”), etc.

B. SUSPECTED MODUS OPERANDI 9. After analysis of statements recorded, facts unearthed during the search and seizure operations, it is seen that Noticees have, prima facie, adopted the following modus operandi. Prior to execution of suspicious trades, FRs were receiving trade instructions through WhatsApp chats or calls from a person whose contact number(s) was saved in the devices as Jack/Jack New/Jack Latest New/Boss, etc. Upon analysis of these contact numbers, it was found that these numbers belonged to Ketan Parekh who was receiving NPI from one, Rohit Salgaocar. After receiving specific and timely instructions, directly or indirectly, from Ketan Parekh, the FRs used to execute orders and made unjust profits.

10. The investigation further revealed that the Big Client used to place orders containing the scrip name, buy/sell quantity and buy/sell price through their order messaging system called FIX. For orders routed through Motilal and Nuvama, traders of Nuvama and Motilal used to execute such orders. However, the instructions regarding execution of these orders such as details of the scrip, time quantity and price of the order, were dictated by Rohit Salgaocar. It was found that SCPL, the company owned by Rohit Salgaocar, had entered into a referral agreement with Nuvama and Motilal for revenue sharing of the brokerage earned on trades of the Big Client referred by SCPL.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

11. It was further found that traders of the Big Client used to discuss the amount and/or price of the scrip with Rohit Salgaocar prior to placing their orders and Rohit Salgaocar used to request these traders to place the order either through Nuvama or Motilal. Simultaneously, Rohit Salgaocar also used to interact with traders of Nuvama and Motilal through Bloomberg chat and used to provide trading instructions and seek updates on status of order execution through the same chat function.

12. A detailed analysis of orders placed by the Big Client and FRs revealed the recurrent matching of the scrip, price, quantity and timing of trades between the Big Client and FRs which would not have been possible unless FRs were in possession of NPI or NPI-based trading instructions relating to impending orders of the Big Client in various scrips. Hence, the matter was further investigated and it was observed that the NPI relating to impending orders of the Big Client was being passed from Rohit Salgaocar to Ketan Parekh who in turn used to communicate trading instructions based on such NPI, directly or indirectly, to the six FRs for execution in order to gain undue profits. The facts and evidences which prima facie establish the suspected modus operandi are discussed in the subsequent paragraphs.

C. VARIOUS MOBILE NUMBERS USED BY KETAN PAREKH 13. From the back-up of the mobile devices found and seized during the aforementioned search and seizure operations and the subsequent statement recordings of various entities, certain contact details of Ketan Parekh were gathered. It is noted that in none of the mobile phones, the contact numbers were saved in the name of Ketan Parekh and instead, various pseudo names such as, “Jack”, “John”, “Boss”, “Bhai”, “Wellwisher”, etc. were used to save these numbers. The details of these contact numbers along with the documentary proof are as follows:

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Table no. 2 Details of contact numbers as obtained from various devices Proof that Name of Ketan Parekh saved as pseudo name in mobile devices of various entities the mobile Ashok Ashok Rohit S. Mobile number Sanjay Sanjay Rachit Sumit Rakesh Kumar Kumar Salgaocar No. Numbers belongs to Taparia - Taparia - Rahul Saraf Poddar - Sonthalia Kathotia Poddar Poddar - (as per Ketan Android iPhone Iphone IPhone12 IPhone13 statement) Parekh2  Aadhaar Card of Ketan Parekh

 Night Mamta 1 XXX0308243 location at - - - - - - - - Bhabhi Residence of Ketan Parekh

 Hotel Location

2 Hotel Location means the proof of the fact that location of phone number allegedly possessed by Ketan Parekh matched with the location of Hotel where Ketan Parekh is had stayed. Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Proof that Name of Ketan Parekh saved as pseudo name in mobile devices of various entities the mobile Ashok Ashok Rohit S. Mobile number Sanjay Sanjay Rachit Sumit Rakesh Kumar Kumar Salgaocar No. Numbers belongs to Taparia - Taparia - Rahul Saraf Poddar - Sonthalia Kathotia Poddar Poddar - (as per Ketan Android iPhone Iphone IPhone12 IPhone13 statement) Parekh2  Night location at 2 XXX7623119 - - Jack Old - - Boss1 - - - Residence of Ketan Parekh  Same IMEI as mobile at WhatsApp Sr. No. 1 chats but  Night 3 XXX7049917 - number not - - - - - - -location at saved in Residence of mobile Ketan Parekh

 Night WhatsApp location at chats but Ketan 4 XXX6010390 Residence of - number not - - - - - - Bhai 1 Ketan Parekh saved in mobile

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Proof that Name of Ketan Parekh saved as pseudo name in mobile devices of various entities the mobile Ashok Ashok Rohit S. Mobile number Sanjay Sanjay Rachit Sumit Rakesh Kumar Kumar Salgaocar No. Numbers belongs to Taparia - Taparia - Rahul Saraf Poddar - Sonthalia Kathotia Poddar Poddar - (as per Ketan Android iPhone Iphone IPhone12 IPhone13 statement) Parekh2  Same IMEI WhatsApp as mobile at WhatsApp chats but Sr. No. 6 chats but number not  Night number not 900 saved in Jack. 5 XXX7571068 location at Jack New - saved in New.Boss - - -mobile - Personal Residence of mobile - 5 (Display Ketan Parekh (Display name3 -  Hotel name - Jola) Jola) Location  Statement recording of 6 XXX6562996 Ketan Parekh - - - - - - - - Rohit & Visitor Slip at SEBI

3 Though the said number is not saved in the contact list of the mobile phone, the display name shown in the table is the one which is saved by the owner of the number with WhatsApp. Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Proof that Name of Ketan Parekh saved as pseudo name in mobile devices of various entities the mobile Ashok Ashok Rohit S. Mobile number Sanjay Sanjay Rachit Sumit Rakesh Kumar Kumar Salgaocar No. Numbers belongs to Taparia - Taparia - Rahul Saraf Poddar - Sonthalia Kathotia Poddar Poddar - (as per Ketan Android iPhone Iphone IPhone12 IPhone13 statement) Parekh2  Night location at Residence of Ketan Parekh  Hotel Location WhatsApp chats but  Night Ketan number not location at Parekh saved in 7 XXX2522726 Jack New Jack. New Jack New Boss 3 - - - Residence of John mobile - Ketan Parekh Mobile (Display name - Boss) WhatsApp  Night JACK Jack 8 XXX5555484 955A Jack New chats but Boss 4 - - -location at Latest Ketan number not

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Proof that Name of Ketan Parekh saved as pseudo name in mobile devices of various entities the mobile Ashok Ashok Rohit S. Mobile number Sanjay Sanjay Rachit Sumit Rakesh Kumar Kumar Salgaocar No. Numbers belongs to Taparia - Taparia - Rahul Saraf Poddar - Sonthalia Kathotia Poddar Poddar - (as per Ketan Android iPhone Iphone IPhone12 IPhone13 statement) Parekh2 Residence of Bhai saved in Ketan Parekh Mobile mobile -  Hotel (Display Location name -  Birthday 955A) wish on WhatsApp (explained later) WhatsApp WhatsApp  Same IMEI chats but chats but as mobile at number not number not Sr. No. 5 Jack saved in Jack New Jack-saved in 9 XXX8527607  Night Latest. Boss New - Wellwisher. -mobile - M Mobile mobile -location at New (Display (Display Residence of name - name - Ketan Parekh JACK) JACK)

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Proof that Name of Ketan Parekh saved as pseudo name in mobile devices of various entities the mobile Ashok Ashok Rohit S. Mobile number Sanjay Sanjay Rachit Sumit Rakesh Kumar Kumar Salgaocar No. Numbers belongs to Taparia - Taparia - Rahul Saraf Poddar - Sonthalia Kathotia Poddar Poddar - (as per Ketan Android iPhone Iphone IPhone12 IPhone13 statement) Parekh2  Same IMEI as mobile at WhatsApp WhatsApp Sr. No. 5 chats but chats but Jack 10 XXX2928015  Night Jack number not number not - Boss 2 - - - Ketan location at saved in saved in Residence of mobile mobile Ketan Parekh

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Aadhaar details of Ketan Parekh 14. Ketan Parekh had visited SEBI Office on March 15, 2023, representing another entity (NH Securities Limited) in a different matter. As proof of identity, he had submitted copy of his Aadhaar Card having number “XXXXXXX32573” which also contained the mobile number “XXX0308243”. Further, in the visitor slip generated with respect to the aforesaid visit of Ketan Parekh to SEBI, the mobile number “XXX6562996” is hand-written along with the aforesaid mobile number.

15. The subscriber details of the aforesaid contact number as obtained from the Telecom Service Provider – Vodafone Idea are noted below: i Name of Subscriber: Ms. Mamta Parekh ii Address of Subscriber: Zaver Mahal, 19/b, Marine Drive, Marine Lines, Mumbai, Maharashtra - 400020 iii Number active since: May 28, 2001

16. In his statement dated December 12, 2023, Ketan Parekh, confirmed that the mobile number “XXX0308243” belongs to his wife, Ms. Mamta Parekh. Further, the address of Ms. Mamta Parekh is the same as mentioned in the Aadhaar card of Ketan Parekh. Thus, it is prima facie established that Ketan Parekh uses the phone number “XXX0308243” which belongs to his wife.

IMEI analysis of various phone numbers of Ketan Parekh 17. The IMEI (International Mobile Equipment Identity) number is a unique 15-digit serial number for identifying a particular mobile phone. On analysis of IMEI numbers associated with the contact numbers gathered above, it was found that various contact numbers were used in same mobile devices. The details of IMEI numbers of mobile devices and the corresponding contact number(s) which were used through such mobile devices are tabulated below:

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Table no. 3 IMEI analysis of various phone numbers of Ketan Parekh Mobile Nos/ IMEI XXX169320198069 XXX310700440194 XXX955052100791 XXX0308243  XXX7049917  XXX7571068   XXX6562996  XXX8527607  XXX2928015 

18. From the table above, it can be observed that the IMEI which was used for mobile number “XXX0308243” (number used by Ketan Parekh as explained above), was also used for mobile number “XXX7049917”, confirming that this number was also used by Ketan Parekh.

19. The contact number “XXX6562996” was confirmed by Ketan Parekh as his own number in his statement dated December 12, 2023. Further, Rohit Salgaocar also confirmed that the contact number “XXX6562996” belongs to Ketan Parekh. The IMEI number for the contact numbers “XXX6562996” and “XXX7571068” is the same i.e. “XXX6310700440194” which confirms that the contact number “XXX7571068” was also used by Ketan Parekh.

20. Further, the contact number “XXX7571068”, was also used through mobile device having IMEI number “XXX955052100791”. The same mobile device was also found to be used for the mobile numbers “XXX8527607” and “XXX2928015” which confirms that these mobile numbers were also used by Ketan Parekh.

21. From the aforesaid analysis, it can be inferred that contact numbers “XXX0308243”, “XXX7049917”, “XXX6562996”, “XXX7571068”, “XXX8527607” and “XXX2928015” were being used by Ketan Parekh. Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Location analysis of various phone numbers of Ketan Parekh 22. The CDRs of various contact numbers associated with Ketan Parekh were analysed to identify the location of the said numbers at the night time (i.e. from 9:00 pm to 6:00 am) during the investigation period. It is revealed that all the mobile numbers were located at the home address of Ketan Parekh on most occasions i.e. Zaver Mahal, 19/b, Marine Drive, Marine Lines, Mumbai, Maharashtra – 400020. The details of the same are as follows: Table no. 4 Location analysis of various phone numbers of Ketan Parekh Registered name & address as S. Mobile Period Latitude Longitude per Customer Acquisition No. Number in use Form Mamta Parekh 19-Jul-21 1 XXX0308243 18.93715 72.82472 to 30- Zaver Mahal, 19/B, Marine Drive Jun-23 N. S. Marg, Marine Lines, Mumbai 400020 20-Sep- 2 XXX7623119 18.93729 72.82475 21 to 16- CAF not shared by TSP Dec-21 Dhruv Jamnadas Shah 27-Sep- K-1 704 Neelyog Residency Gauri 3 XXX7049917 18.93714 72.82475 21 to 09- Shankar Wadi N0-1, Near Kanta Dec-21 Apartment Ghatkopar East, Pant Nagar, Maharashtra - 400075 27-Sep- 4 XXX6010390 18.93729 72.82475 21 to 07- CAF not shared by TSP Oct-21 20-Oct- 5 XXX7571068 18.9371 72.8249 21 to 30- Virendra Pareghi Jun-23

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Registered name & address as S. Mobile Period Latitude Longitude per Customer Acquisition No. Number in use Form 168 2015, Pratiksha Appartment, Opp Krk Varma School, Ahmedabad-380063, Gujarat Virendra Pareghi 20-Oct- 6 XXX2928015 18.93729 72.82475 21 to 11- 168 2015, Pratiksha Appartment, May-22 Opp Krk Varma School, Ahmedabad-380063 23-Dec- 7 XXX6562996 18.93729 72.82475 21 to 30- CAF not shared by TSP Jun-23 Manish Agrawal

10-Mar- B /502, Aster Tower, Vasant 8 XXX2522726 18.93715 72.82472 22 to 10- Valley Complex Oct-22 2,Gen. A. K. Vaidya Marg, Opposite Oberoi Mall, Malad East, Mumbai-400097 Ronak Dinesh Bhai Solanki 20-Sep- 9 XXX5555484 18.92721 72.82118 22 to 08- 6/ 372 C Colony Naroda Road, Jun-23 Ahmedabad - 382330 Kadiya Chhaganbhai 23-Nov- 10 XXX8527607 18.9371 72.8249 22 to 24- 11/248, Gujrat Hou Board, Jun-23 Meghaninagar, Ahmedabad -380016

23. It can be observed from the aforesaid table that Ketan Parekh had been using multiple contact numbers /SIM cards issued in the name of different persons in order to disguise his identity. This is also corroborated by Ketan Parekh in his statement made before SEBI wherein he admitted that he used to change his Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others contact number frequently and that such contact numbers were not obtained in his name.

Third party confirmation from Hotels and Airline

24. The CDRs of the aforesaid mobile numbers were analysed on sample basis to identify the location of the said numbers when the same were observed to be outside Mumbai. The analysis of the mobile numbers “XXX0308243”, “XXX7571068”, “XXX6562996” and “XXX5555484” revealed that the said numbers were found to be located together at different hotels during different periods, which is detailed below – Table no. 5 Details confirmed by Hotels S. No. Period Location Confirmation from Hotels 1. March 17, Hotel Grand Hotel authorities, vide email dated November 03, 2023 2023 to Hyatt Kochi confirmed the stay of Mr. & Mrs. Ketan Parekh in March 20, Bolgatty, Room No. 340, for attending a wedding. Mr. & Mrs. 2023 Kochi, Kerala Parekh has also shared their Aadhaar as identity proofs to the Hotel. 2. November Hotel Hotel authorities, vide email dated October 18, 2023 27, 2022 to Rambagh confirmed the stay of Mr. & Mrs. Ketan Parekh in November Palace, Room No. 340, for attending a wedding of the 29, 2022 Jaipur daughter of a family friend. Mr. & Mrs. Ketan Parekh have also shared their Aadhaar as identity proofs to the Hotel.

The same was also confirmed by Ketan Parekh and his family friend in their statements given to SEBI. 3. January 29, Hotel ITC Hotel officials, vide, email dated August 04, 2023 2023 to Sonar confirmed the stay of Mr. & Mrs. Ketan Parekh in their February 01, Bangla, hotels, in Room No.3007. Further, Hotel authorities, 2023 Kolkata vide email dated August 30, 2023 submitted that Mr. & Mrs. Ketan Parekh were part of a group booking

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

S. No. Period Location Confirmation from Hotels made for the purpose of a wedding. Mr. & Mrs. Ketan Parekh have also shared their Aadhaar as identity proofs to the Hotel.

The same was also confirmed by Ketan Parekh, his family friend (who attended the said wedding) and Sanjay Taparia (who also attended the said wedding) in their statements given to SEBI. They had also stated they attended the wedding of theirs friend’s son. 4. September Welcomhotel Hotel officials, vide, email dated October 20, 2023 30, 2022 till by ITC confirmed the stay of Mr. & Mrs. Ketan Parekh in October 02, Hotels, Room No.314. The address mentioned in the stay 2022 Alkapuri, invoice, as shared by the Hotel is “Ketan Parekh, NH Vadodara Securities Private Limited, 121, Radha Bhavan, N.M. Marg” which is the office address of Ketan Parekh and his cousin Kartik Parekh, the director of M/s. NH Securities Private Limited. The email address and mobile number mentioned at the time of checking in were xxx_6@yahoo.co.in and “XXX0308243” respectively. Mr. & Mrs. Ketan Parekh have also shared their Aadhaar as identity proofs to the Hotel.

25. Further, with respect to Ketan Parekh’s visit to Hotel Rambagh Palace, Jaipur, it was observed that Ketan Parekh took a flight from Mumbai to Jaipur on November 27, 2022 and then moved through Jaipur, Agra, Morena and Gwalior by road. He took a flight from Gwalior to Mumbai on December 01, 2022.

26. The details obtained from the airlines in this regard is as follows –

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Table no. 6 Flight Details of Ketan Parekh Email Flight Travel From Airline PNR Passenger Details date No. Date and To Air India October November Mumbai Ketan Parekh and Mrs. 611 QQJWP4 Limited 25, 2023 27, 2022 to Jaipur Mamta Parekh Ketan Parekh, Mrs. Gwalior October December Mamta Parekh, Ashita IndiGo 265 IJ71ML to 16, 2023 01, 2022 Parekh and Bhavin Mumbai Parekh

Whatsapp message containing birthday greeting for Ketan Parekh 27. From the WhatsApp chat available in the mobile device of Sanjay Taparia, it is seen that he wished birthday to “Jack Latest” (mobile number of Jack Latest being XXX5555484) on February 15, 2023 who responded by thanking him. It is noted that the birth date of Ketan Parekh as mentioned on his PAN Card is also February 15, 1962. This further proves that “Jack Latest” is none other than Ketan Parekh and mobile number XXX5555484 is used by Ketan Parekh. The screenshot of the aforesaid chat as retrieved from the device of Sanjay Taparia is placed below:

Figure no. 1 Screenshot of WhatsApp chat between Sanjay Taparia and Ketan Parekh

28. Considering the analysis of aforesaid evidences, it can be inferred that contact numbers mentioned in the preceding paragraphs were being used by Ketan Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Parekh and he used these contact numbers to, inter alia, communicate his instructions for execution of NPI-based trades to FRs. A diagrammatic representation of the analysis carried out in respect of various contact numbers of Ketan Parekh is as under: Figure no. 2 Establishing identity of Ketan Parekh

29. Having prima facie established that Ketan Parekh was using the contact numbers mentioned above, the trading activities in the accounts of FRs have been examined in subsequent paragraphs to ascertain how Ketan Parekh was communicating trading instructions based on NPI to various FRs for execution of NPI-based trades.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

D. CONNECTION AMONGST NOTICEES AND SHARING OF NPI AND NPI-BASED TRADING INSTRUCTIONS

30. Any information with respect to substantial impending transaction in securities of an entity which is not generally available to public is categorised as non-public information or NPI. An entity, who is in possession of such NPI and trades based on such NPI, can use this information to build a position in the market prior to the execution of the substantial impending transaction to benefit from the price movements caused in the market by such large orders.

31. The NPI pertaining to impending orders of the Big Client in various scrips was communicated by Rohit Salgaocar to Ketan Parekh. Thereafter, Ketan Parekh used to instruct other Noticees to execute orders through the trading accounts of FRs so as to take positions in the market to benefit from the impending orders in various scrips. The flow of information and evidence gathered relating to the same is elucidated in the ensuing paragraphs.

D.1 Connection between Rohit Salgaocar and Ketan Parekh and flow of NPI

32. In his statement dated March 7, 2024 and July 22, 2024, Rohit Salgaocar stated that for executing trades of the Big Client, he used to find counterparties through different market participants including foreign funds, Indian funds, other holders of the shares and Ketan Parekh. However, as per the statement of Rohit Salgaocar, around 90% of the Big Client trades were being fulfilled by Ketan Parekh alone. Rohit Salgaocar has also stated that his extent of due diligence, before engaging with Ketan Parekh for Big Client trades, was just to check that Ketan Parekh was not banned from dealing in Indian Securities Market. The relevant extracts from the statement of Rohit Salgaocar dated March 7, 2024 and July 22, 2024 is reproduced below: “Q 23. Explain how the trades for Big Client were executed by you?

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Reply-Dealer of the Big Client provides me with the name of the stock they are interested in. I will check the availability with different market participants including foreign funds, Indian funds, other holders of the shares etc. and lastly with Ketan Parekh. After confirming the availability from the counterparty, I get back to the dealer of the Big Client with the quantity and price on offer. Upon confirmation from the dealer of the Big Client, the deal goes through. The Big Client dealer sends the deal ticket to the broker in India. After execution of the trades, Indian broker used to confirm me on Bloomberg chat. Sometimes, I used to get confirmation from Big Client dealers as well.

Q 27. In the reply to Q. No. 23, you have mentioned that you used to source counterparties through Mr. Ketan Parekh. What percentage of Big Client trades were being fulfilled by Ketan Parekh? Reply- Around 90%

Q 28. How do you know Ketan Parekh and for how long? Reply- My ex-father-in-law Mr Dev Ahuja introduced me to Mr. Ketan Parekh sometime in the late 1990s. I re-contacted Ketan around 2 1/2 -3 years ago for trade in some illiquid stock of Big Client. That’s how I started contacting him for blocks.

Q 29. Is the Ketan Parekh, as you mentioned in your replies, the same Ketan Parekh whom SEBI had banned in 2001 and is infamously known as KP or K10? Reply- Yes

Q 30. What kind of due diligence did you undertake before engaging with Ketan Parekh for Big Client Trades? Reply-My extent of due-diligence was to check whether he was banned from dealing in Indian Securities Market.

Q 31. How did you interact with Ketan Parekh? Reply-Phone call over WhatsApp.

Q 32. Whether Ketan Parekh had only one mobile number or did he keep on changing numbers? Reply-He kept on changing his mobile numbers but his WhatsApp’s display picture remained the same. To my knowledge, he changed his mobile numbers half a dozen times.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Q 33. When Ketan Parekh used to change his numbers, how did you get to know about that? Reply- Most of the times, he would simply text me telling his new number. I used to save the new numbers and delete the old ones.

Q 34. Do you have any numbers of Ketan Parekh saved in your phone? Reply-I only have one number of Ketan Parekh i.e. +91 XXX65 62996.

Q 35. Do you have any idea how Ketan Parekh brings counterparties? Reply- We only talk about size and price. No other conversations.

Q 36. Was Ketan Parekh aware that you were bringing trades of Big Client? Reply- It was known in the market that I used to deal predominantly for Big Client. I have never explicitly revealed name of any of my clients. However, I believe that Ketan Parekh would have assumed that the trades were of Big Client.”

33. Further, the Internet Protocol Detail Records (hereinafter “IPDRs”) of the various mobile numbers of Ketan Parekh were also analysed and it was observed that two IP addresses based in Singapore were appearing consistently in these IPDRs which meant that Ketan Parekh was connecting with these IP addresses on a regular basis.

34. In order to ascertain the details of the aforementioned Singapore based IP address, a request was made to Monetary Authority of Singapore (hereinafter “MAS”). MAS, vide its letter dated January 09, 2024 informed that the IP address 218.212.174.201 is provided by Starhub Limited and the same was allocated to Rohit Salgaocar and the billing address of this IP is “57, Cairnhill Road #04-08 Elizabeth Height Singapore 229668”, which matches with the residential address of Rohit Salgaocar, as provided by him in his email dated August 21, 2024.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

35. Further, the IPDR of two mobile numbers of Ketan Parekh (XXX6562996 and XXX8527607), during the period between February 2023 and May 2023 shows 151 instances of interaction with the IP address 218.212.174.201, which belonged to Rohit Salgaocar. This prima facie establishes that Ketan Parekh and Rohit Salgaocar used to interact with each other through internet/whatsapp frequently. Further, both Ketan Parekh and Rohit Salgaocar, in their statements have also admitted that they used to interact with each other over WhatsApp.

36. Thus, there are clear evidences of connection between Rohit Salgaocar and Ketan Parekh through matching of IPDR as well as their independent deposition. In view of the same, considering that Ketan Parekh was able to pre-empt the trade orders of the Big Client and take timely position in market through the trading accounts of FRs, there is a prima facie conclusion that the NPI pertaining to impending orders of the Big Client in various scrips were being communicated by Rohit Salgaocar to Ketan Parekh who was communicating trading instructions based on such NPI to other Noticees for execution of trades from the trading accounts of FRs.

D.2 Flow of NPI-based trading instructions from Ketan Parekh to FRs

37. From the backup of the mobile devices obtained during search and seizure operation from various Noticees, it was observed that the contact details of an individual, (which was saved under various names such as Jack/Jack New/955A/Boss, etc.) was providing the trade related instructions including scrip name, buy/sell, quantity, price, etc. to various Noticees. The aforesaid information was being provided over various WhatsApp groups viz. Jack-ST, Jack-Saro or through individual chat, in these mobile phones. From the analysis of aforesaid mobile devices, it was found that the individual who was providing these contact details was Ketan Parekh, as prima facie established in paragraph 28. Further, the manner in which different entities were receiving the Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others trade related instructions from Ketan Parekh is explained in the ensuing paragraphs.

D.3 Flow of NPI-based trading instructions from Ketan Parekh to GRD Securities Limited and Damanis 38. From the analysis of the computer systems found during the search and seizure operations at premises of Sanjay Taparia as provided in Table no. 9, it was seen that Sanjay Taparia and his employee Rahul Saraf had login access to the proprietary trading account of GRD Securities Limited and had arrangements for placing orders with Ashok Kumar Damani and Anirudh Damani (hereinafter collectively referred to as “Damanis”) in their trading accounts.

39. Sanjay Taparia and his employee Rahul Saraf, were part of a WhatsApp group called “Jack-ST” where they used to receive trade related instructions from Ketan Parekh (WhatsApp name - Jack/ Jack Latest New). A sample snapshot of the WhatsApp chat showing the instructions given by Ketan Parekh in the group Jack-ST is placed below: Figure no. 3 WhatsApp chat showing instructions given by Ketan Parekh in the group Jack- ST

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

40. The details of the WhatsApp group “Jack-ST”, as found from the backup of the mobile device of Rahul Saraf as obtained by SEBI during search and seizure operation, is given in the table below: Table no. 7 Details of the WhatsApp group “Jack-ST” Names found Names as Details as per the from devices provided by Customer Acquisition S. No. Mobile No. backed up Sanjay Taparia Form (CAF) of during Search during search Telecom Service and Seizure and seizure Providers (TSPs) Kartik Parekh, Surendra 1. XXX0657217 Maverick/680K brother of Ketan Subhashchandra Parekh Pandey Kartik Parekh, Surendra Maverick/Kartik 2. XXX9978591 brother of Ketan Subhashchandra ji Parekh Pandey Subhash 3. XXX1040895 - Subhas Joshi Latest/Subhashji Surendra 680A/ Akash. Staff of Ketan 4. XXX6308049 Subhashchandra New Parekh Pandey Surendra Sagar/ 680Ko/ Relative of 5. XXX6123307 Subhashchandra Kau.New Ketan Parekh Pandey Ketan 6. XXX8527607 Parekh/Jack/ Ketan Parekh Kadiya Chhaganbhai Jack Latest New Airtel Rahul/ Rahul Saraf, 7. XXX1040894 Rahul/Rahul employee of Rahul Saraf Latest Sanjay Taparia Harit Parekh, Surendra 8. XXX6436048 680H/ Harit Son of Kartik Subhashchandra Parekh Pandey

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Names found Names as Details as per the from devices provided by Customer Acquisition S. No. Mobile No. backed up Sanjay Taparia Form (CAF) of during Search during search Telecom Service and Seizure and seizure Providers (TSPs) Sanjay Taparia/719/ ST 9. XXX3006262 Sanjay Taparia Sanjay Taparia Bhaiya/ ST Latest

41. Further, the analysis of CDR of Sanjay Taparia and Damanis indicates that Damanis had frequent interactions with Sanjay Taparia. During the Investigation Period, Sanjay Taparia had 21 calls with Anirudh Damani and 1363 calls with Ashok Kumar Damani from two of his mobile numbers. The table below shows the details: Table no. 8 Details from CDR of Sanjay Taparia and Damanis Calls Between No of Calls Anirudh Damani Sanjay Taparia (XXX0291884) 21 (XXX0013991, Ashok Kumar Damani XXX8175000) (XXX9793390) 1363 Total No of Calls 1384

42. It is observed that Sanjay Taparia, either himself or through his employee Rahul Saraf, was executing the NPI-based trades, on the instructions of Ketan Parekh, in the trading accounts of GRD Securities Limited and Damanis as explained below.

43. Trading in the proprietary trading account of GRD Securities Limited - GRD Securities Limited had installed its trading terminal on the computer system of Sanjay Taparia at his office premises. The login credentials of the Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others proprietary trading account of GRD Securities Limited was available with Sanjay Taparia and Rahul Saraf (his employee) and they used to place various trades through this account, as per the instructions received from Ketan Parekh on the WhatsApp group “Jack-ST”.

44. The aforesaid details have been confirmed with the help of the IP address and Machine IDs gathered from connection logs of the trades and from the systems of Sanjay Taparia. An analysis with respect to the mode of placement of the NPI-based trades in trading accounts of GRD Securities Limited revealed the following: i Some of the NPI-based trades were executed in the proprietary trading account of the GRD Securities. To identify the locations/people who were executing these trades, connection logs4 from the GRD Securities Limited were sought and analysed. ii The aforesaid data was examined against the data so obtained from the analysis of computer systems found during the search and seizure operations at premises of Sanjay Taparia. Upon analysis following is observed:

Table no. 9 Placement of orders in the trading account of GRD Securities Limited CTCL Id Trader Name Period MAC Id Details matched with (of GRD physical inspection at the Securities) time of search and seizure 700020002078 Shreya June 16, 30-9C-23- Physical computer system Mehrotra 2021 - 0E-5A-57 found in the office of Sanjay June 21, Taparia 2023

4 Connection logs contains data pertaining to Terminal Id, MAC Ids and IP Addresses. A Media Access Control Id (MAC Id) is a hardware identifier that uniquely identifies each device on a network. Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

CTCL Id Trader Name Period MAC Id Details matched with (of GRD physical inspection at the Securities) time of search and seizure January 6- A4-AE-12- 7, 2022 7B-77-EF 700020002063 Priya Saraf June 1, 02-55-00- Physical computer system not 2021 - 30-31-39 found in the offices of GRD June 16, Securities Limited or Sanjay 2021 Taparia June 17, A4-AE-12- Physical computer system 2021 - 7B-77-EF found in the office of Sanjay July 27, Taparia 2022 August 30, 30-9C-23- Physical computer system not 2022 - 82-F7-AD found in the offices of GRD November Securities Limited or Sanjay 30, 2022 Taparia December 00-0C-29- Virtual Machine5 (VM) 06, 2022 - 3F-7D-B1 installed in the server of GRD June 21, Securities Limited and access 2023 found in the computer system placed in the office of Sanjay Taparia

5 Virtual Machine (VM) is a software computer which like a physical computer runs an operating system and applications. However, unlike a physical system, a VM is created within a software environment called a hypervisor. The hypervisor manages the physical resources of the host computer and allocates them to the VMs. This allows multiple VMs to run on a single physical computer and each VM can run a different operating system. A Virtual Machine can be used to run a Virtual Private Server (VPS). A VPS is a remote server which is dedicated to a particular use, which in the current case can be for trading. This can be useful if there is a need to have a reliable and high performance trading platform or if there is a requirement to be able to trade from anywhere in the world. Some of the benefits of using VMs for trading are:  Reduced latency: VMs can be located close to the exchanges, which can reduce the latency of order execution.  Increased reliability: VMs are less likely to experience downtime than physical servers.  Scalability: VMs can be easily scaled up or down to meet the needs of trading operation.  Security: VMs can be isolated from each other and from the host computer, which can improve security. Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

CTCL Id Trader Name Period MAC Id Details matched with (of GRD physical inspection at the Securities) time of search and seizure November 30-9C-23- Physical computer system Ram Kumar 11, 2022- 9B-89-52 found in the office of Sanjay 700020002752 Dargar December Taparia 08, 2022 iii In addition to the above, in his statement dated June 23, 2023, Sanjay Taparia has accepted the fact that GRD Securities Limited had lent him three CTCL IDs through which he used to execute trades for Ketan Parekh in the proprietary trading account of GRD Securities Limited.

iv Hence, from above, it can be inferred that Sanjay Taparia used 3 CTCL Ids viz. ‘700020002078’, ‘700020002752’ and ‘700020002063’ of GRD Securities, registered in the names of Shreya Mehrotra, Ram Kumar Dargar and Priya Saraf, respectively.

v It is important to note that GRD Securities had lent its CTCL IDs to Sanjay Taparia, however, he is not an Authorised Person of GRD Securities. Further, these trading terminals were used from the office premises of Sanjay Taparia i.e. outside of the office premises of GRD Securities.

45. Trading in the personal accounts of the Damanis – Anirudh Damani and Ashok Kumar Damani used to receive trade related instructions from Sanjay Taparia or from Rahul Saraf (under instructions from Sanjay Taparia), over calls and these NPI-based trades were executed by Damanis themselves through internet based trading from their residential premises. This has been confirmed by both Sanjay Taparia and the Damanis in the statements made by them to SEBI under oath as reproduced below:

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Excerpts from statement of Sanjay Taparia recorded on June 22 and June 23, 2023 “Q19 Whether you have passed on the information received by you from Ketan Parekh to anyone else? A19 Yes, when instructions were given to me by Ketan Parekh to execute trades and if I was not able to trade the same in account of GRD because of shortage of margin/ money, I used to tell Anirudh Damani or Ashok Damani to execute the said trades.

Q20 Whether Anirudh Damani or Ashok Damani were aware that the trades were placed on the instructions of Ketan Parekh? A20 No, they didn't know that the trades I told them to execute were on behalf of Ketan Parekh. I did not tell them and nor they asked for the same.

Q22 What is the arrangement with Ashok and Anirudh Damani, with respect to the trades executed by them in their accounts on your instructions? A22 My arrangement with Ashok and Anirudh Damani is for placing intra-day and delivery-based trades, on my behalf or on behalf of my friends/clients, in their individual accounts. Damanis charge me brokerage of around 0.03% for intra-day trades and 0.3% for delivery-based trades.”

Excerpts from statement of Anirudh Damani recorded on June 22, 2023 “Q1. We have observed some very specifically timed suspicious intra-day trades in your account which generated significant profits. Do you get specific information/instruction from someone for executing such trades? E.g. 27-0ct-2022 trades in scrip of VBL, 22-Jan-2022 in Jamna Auto etc. Even recently, such suspicious trades in scrip of Deepak Fertilizers Ltd were executed by you on June 07, 2023. I get instructions from Sanjay Taparia to execute such suspicious trades and above mentioned trades were also based upon the instructions from him.

Q2. Were you regularly executing such suspicious trades on instruction of Sanjay Taparia?

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

I was getting instructions to execute similar suspicious trades on regular basis from Sanjay Taparia. I used to sometimes execute less / more / equal quantity of shares as instructed by Sanjay Taparia.

Q3. How were the profits earned in such trades shared with Sanjay Taparia? The profits earned were shared from time to time with Sanjay Taparia in cash as per his instructions. But pursuant to today’s interaction, I shall not be sharing any profits with Sanjay Taparia in future and the entire profits from the aforementioned trade and similar such suspicious trades where profits haven't yet been shared by me, shall be retained by me. Also, I shall not follow any such instructions to execute suspicious trades in future.

Q4. Do you know from where Sanjay Taparia gets such prior information for executing suspicious trades which he passes on to you? No, I don't know.

Q5. Do you happen to know Ketan Parekh? (whom SEBI has debarred from the Stock Markets in regards to various violations related to Securities Markets. Photo of the Ketan Parekh, as available on Internet is placed below, confirm). I have heard about him in the news but I do not personally know Ketan Parekh.”

46. Further, the NPI-based trading can also be established with the help of following illustration: i On November 11, 2022, 2 funds of the Big Client sold 52.5 lakh shares in the scrip PB Fintech (Policy Bazaar). It was seen that GRD Securities Limited (FR1), Salasar Stock Broking Limited (FR2) and Anirudh Damani (FR3) have matched their trades with the Big Client for 20.61 lakh shares.

ii The screenshot of a message in the WhatsApp group Jack-ST, where Ketan Parekh, at around 11:15 am, is seen to be giving instructions about covering the short quantity on BSE at INR 384.50. At 11:16 am, Sanjay Taparia confirms that 5.58 lakh shares have been bought. The said screenshot is reproduced below: Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Figure no. 4 Screenshot of a message in the WhatsApp group “Jack-ST”

iii From analysis of trade log (illustrated below) following pattern of buying by FR1 and 3 is observed: Table no. 10 Pattern of buying by FR1 and FR3 on November 11, 2022 Average Count Trade Trade Buy/ Sum of Trade Price Match Particulars of Start End Sell Trade Qty Range (in Vol. Orders Time Time INR) FR3 Buy 7 09:20:50 10:01:53 20,000 380.76 - FR1 Buy 5 11:15:54 11:16:20 4,08,531 384.50 4,08,529 FR3 Buy 2 11:15:51 11:16:42 1,30,000 384.50 1,29,998 BC Sell 11 11:14:32 11:16:27 25,00,000 384.50 5,38,527 iv From the table, it can be seen that between 11:15-11:16 am, FR1 bought 4.08 lakhs shares and FR3 bought 1.3 lakh shares, and around 100% of their buy order matched with the sell order of the Big Client. Further, FR3 had already bought a quantity of 20,000 shares in the morning. Thus, the total buy by FR1 and FR3, as confirmed by Sanjay Taparia, in the group Jack- ST, was of around 5.58 lakhs.

v This illustrates that the trading instructions were passed on by Sanjay Taparia to Damanis and the same has also been confessed by both of them in their Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others statements. Further, based on these instructions, trades were carried out by Damanis.

D.4 Flow of NPI-based trading instructions from Ketan Parekh to Salasar Stock Broking Limited

47. The NPI-based trades, which were executed in the proprietary trading account of Salasar Stock Broking Limited were undertaken on the instructions of Ketan Parekh. These instructions were given on the WhatsApp group named “Jack- Saro”, in which Shyam Rajkumar Saraogi, Director of Salasar Stock Broking Limited and Sumit Sonthalia, son of Kiran Sonthalia the Director of Salasar Stock Broking Limited, were members.

48. Sumit Sonthalia was also working for Salasar Stock Broking Limited as a trader. Further, an office phone named “Sam”, phone number “XXX7733697” was also part of the aforesaid WhatsApp group. A sample snapshot of the WhatsApp chat showing the instructions given by Ketan Parekh in the group “Jack-Saro” is placed below: Figure no. 5 Screenshot of a message in the WhatsApp group “Jack-Saro”

49. The details of the members of the WhatsApp group “Jack-Saro”, as found from the WhatsApp back-up of Sumit Sonthalia, retrieved from his Google drive, is given in the table below:

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Table no. 11 Details of the members of the WhatsApp group “Jack-Saro” Names as Details as per the provided by Customer Names from devices Sumit Sr. Acquisition Form Mobile No. found during Search Sonthalia No. (CAF) of Telecom and Seizure during Service Providers search and (TSPs) seizure Jack New M/JACK/Jack Kadiya 1. X XX8527607 Ketan Parekh Latest. New/K Chhaganbhai Surendra 2. X XX6308049 680A/Akash New Doesn’t know Subhashchandra Pandey Surendra 3. X XX6436048 680H/ Harit Doesn’t know Subhashchandra Pandey Surendra 4. X XX9978591 Maverick/Kartik Ji/Kar Doesn’t know Subhashchandra Pandey Mobile kept in office for 5. X XX7733697 Sam Sekh Sukuir trading purpose Surendra Sagar/680Ko/Kau.New/Sa 6. X XX6123307 Sagar Subhashchandra hil Pandey Sumit Sonthalia/Sumeet Sumit 7. X XX0266666 Sumit Sonthalia Sonthalia/Sumit Sonthalia Shyam 8. X XX0460230 Shyam/Shyam Saraogi Priya Saraogi Saraogi

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

50. The instructions with respect to the NPI-based trades were received from Ketan Parekh (Jack) in the aforesaid WhatsApp group and thereafter a trader of Salasar Stock Broking Limited, including Sumit Sonthalia (one of the traders) and Shyam Rajkumar Saraogi (Director of Salasar Stock Broking Limited and one of its trader), who had access to the office phone named “Sam”, used to execute the NPI-based trades in the proprietary trading account of Salasar Stock Broking Limited.

51. The details of the CTCL Id and MAC Id, through which the NPI-based trades were executed in the proprietary trading account of Salasar Stock Broking Limited, are provided in the table below:

Table no. 12 Placement of orders in the prop account of Salasar Stock Broking Limited CTCL Id Trader Name (of Period MAC Id Details Matched with Salasar Stock Broking Limited) 700001002002 Pradeep Kumar Jan 01, 18-C0- Physical computer Saraogi 2021 - 4D-B0- system found in the June 21, E9-78 office of Salasar Stock 2023 Broking Limited

52. The aforesaid evidence prima facie establishes that the NPI-based trades were placed from the trading terminals present in the office of Salasar Stock Broking Limited.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

D.5 Flow of NPI-based trading instructions from Ketan Parekh to APR Properties Private Limited and Basukinath Properties Private Limited

53. Ashok Kumar Poddar was a close associate of Ketan Parekh and has known him since 1990s. He was a Kolkata based broker and used to provide broking services to Ketan Parekh for which he was also debarred from the securities market along with Ketan Parekh in the infamous stock market scam of 2001.

54. In the statement made by Ashok Kumar Poddar, it is stated that Ketan Parekh used to provide trade related instructions to Ashok Kumar Poddar over WhatsApp call and messages. Thereafter, Ashok Kumar Poddar used to communicate the same to his son, Rachit Poddar. As per the instructions received, Rachit Poddar used to execute the trades in the trading accounts of APR Properties Private Limited and Basukinath Properties Private Limited respectively, through the systems placed at their residence.

55. The analysis of CDR indicates that Ashok Kumar Poddar had frequent interactions with Ketan Parekh and his brother Kartik Parekh. During the period between November 2021 – June 2023, Ashok Kumar Poddar had 48 calls with Ketan Parekh on 6 of his numbers and 14 calls with Kartik Parekh (brother of Ketan Parekh). The table below shows the details: Table no. 13 Details from CDR of Ashok Kumar Poddar Calls of Ashok Kumar Poddar with Mobile number No. of calls XXX2522726 10 XXX2928015 15 XXX5555484 12 Ketan Parekh XXX8527607 4 XXX0308243 6 XXX7623119 1 Kartik Parekh XXX0657217 14 Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Calls of Ashok Kumar Poddar with Mobile number No. of calls Total No. of calls 62

56. Thus, NPI-based trades were executed in the trading accounts of APR Properties Private Limited and Basukinath Properties Private Limited from the computer devices found at the residential premises of Ashok Kumar Poddar and Rachit Poddar.

57. Based on the aforesaid facts, it is found that Ketan Parekh was executing NPI-based trades through accounts of the six FRs and a diagrammatic representation showing the flow of communication from Ketan Parekh to FRs for execution through their trading accounts is depicted below:

Figure no. 6 Flow of NPI-based trading instructions from Ketan Parekh to FRs

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

E. COMPARISON OF TRADING VOLUME AND PROFITS OF FRS

58. The outcome of the investigation in the present matter indicates that the trading volumes and profits made in the accounts of the FRs, namely, Salasar Stock Broking Limited, GRD Securities Limited, APR Properties Private Limited, Basukinath Properties Private Limited, Anirudh Damani and Ashok Kumar Damani rose significantly during the Investigation Period as compared to the pre-investigation period, except in the case of GRD Securities Limited due to the fact that GRD Securities Limited had lent only three out of its two hundred twenty-six proprietary trading terminals to Sanjay Taparia who was executing trades through the said terminals.

59. The details of trades executed by FRs, demonstrating substantial increase in the trading volumes and profits during the Investigation Period (30 months) as compared to the pre-investigation period (30 months), are provided in the following table: Table no. 14 Details of trades executed by FRs before and during the Investigation Period

Pre - Investigation Period (from 01-Jul-18 to 31- Investigation Period (from 01-Jan-21 to 20-Jun-23) Dec-20) Derivativ Derivativ Equity Equity Derivatives Equity Equity Derivatives es es Gross Gross Intra Intra Intra Intrada Gross Gross Intra Intrada Intra Intrada Noticee Trade Trade Day day Day y Trade Trade Day y Day y Value Value scrip profit contra profit Value Value scrip profit contract profit (in (in days (in ct (in (in (in days (in days (in lakh) lakh) lak days lakh lakh) lakh) lakh lakh h) ) ) ) GRD Securities 25,58,270 1,23,69,000 1,82,394 802 91,839 3,287 32,56,882 1,95,25,940 82,334 730 1,10,684 3,254 Ltd Salasar Stock 2,26,890 25,44,920 702 208 5,333 342 15,18,987 25,072 2,736 1,353 5,948 -188 Broking Limited Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Pre - Investigation Period (from 01-Jul-18 to 31- Investigation Period (from 01-Jan-21 to 20-Jun-23) Dec-20) Derivativ Derivativ Equity Equity Derivatives Equity Equity Derivatives es es Gross Gross Intra Intra Intra Intrada Gross Gross Intra Intrada Intra Intrada Noticee Trade Trade Day day Day y Trade Trade Day y Day y Value Value scrip profit contra profit Value Value scrip profit contract profit (in (in days (in ct (in (in (in days (in days (in lakh) lakh) lak days lakh lakh) lakh) lakh lakh h) ) ) ) Ashok Kumar 3,679 3,584 13 0 2 0 1,33,829 1,12,948 130 57 106 169 Damani Anirudh Damani 2,88,151 3,07,763 587 90 721 -183 9,75,738 1,61,344 502 598 306 69 APR Properties 6 103 1 0 1 -1 5,17,273 10,04,759 97 233 158 1,383 Private Limited Basukinath Properties Private 932 22,774 11 -1 137 3 11,74,759 9,67,642 214 544 544 -216 Ltd

60. From the aforesaid table, it is noted that more than 98% of the trades undertaken by FRs, in terms of trade value, were done in cash markets. Further, around 97% of the total profit earned through FR trades was made through cash market trades alone.

61. Further, the trading profiles of each FR has been juxtaposed with the trading profile of the Big Client during the Investigation Period to understand the correlation between their trades. The trading profile of each FR has been provided in the tabular format below:

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others i Trading profile of Salasar Stock Broking Limited (FR2)

Table no. 15 Trading profile of Salasar Stock Broking Limited (FR 2) Equity Segment Equity Derivative Segment Avera ge Squa Gros re off Average Gross s Square earne Gross Gross No of Traded Trade No of off Calend d Calend Traded Traded instan Value d instance earned ar days (INR ar days Value (INR Value ces (INR In Value s (INR In In In lakhs) (INR In lakhs) (INR lakhs) lakhs lakhs) In ) lakhs ) No of Scrip days/Contract 616 15,18,987 124 1,400 616 19,508 22,04,394 113 -3,385 days traded 12,219 Common Scrip days/Contract 259 364 11,94,196 3,281 1,048 264 443 1,17,511 265 105 days with the Big Clients No of Other Non-Common Scrip days/Contract days with 616 3,24,792 27 352 616 19,065 20,86,883 109 -3,490 11,855 the Big Clients No of Scrip days/Contract days wherein day trading 586 2,735 13,36,507 489 1,350 609 5,948 8,78,755 148 -188 (80% squared off) has been carried out No of Scrip days/Contract days wherein day traded (80% squared off) and 245 340 11,92,684 3,508 1,047 115 138 51,371 372 63 commonly traded with the Big Clients Instances where client earned a positive square off difference of INR 1 or more when day traded (80% squared off) and commonly 175 218 9,65,520 4,429 1,241 4 4 5,265 1,316 4 traded with the Big Clients and there is matched quantity between big client and any of the FRs

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

62. From the table above, it is seen that: i in the cash market, Salasar Stock Broking Limited earned a square off profit of INR 13.50 crores from the trades wherein day trading (80% squared off) was carried out. Among such trades, Salasar Stock Broking Limited earned a square off profit of INR 12.41 crores from such trades where Salasar Stock Broking Limited earned a square off difference of INR 1 or more and where matching in that scrip, on that day, was seen between the Big Client and any of the FRs. This shows that significant profits of Salasar Stock Broking Limited have come from trades based on NPI. ii Further, the number of instances of trades based on NPI is around 8% i.e. 218 instances out of 2,735 instances of day trading instances. However, the Gross traded value (GTV) of such instances of NPI based trades (INR 9,655 crores) is around 72% of the GTV of day trading instances (INR 13,365 crores). iii Additionally, the average GTV of the instances of NPI based trades was observed to be around INR 44 crores, which is almost 9 times of the average GTV of day trading instances (INR 4.9 crores).

63. The aforesaid trading profile illustrates that the NPI based trades had substantially high trading size/concentration and have yielded substantial unlawful profits for the Salasar Stock Broking Limited. Similarly, the tabular representation of trading profile for other FRs is provided below:

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others ii Trading profile of GRD Securities Limited (FR1)

Table no. 16 Trading profile of GRD Securities Limited (FR1) Equity Segment Equity Derivative Segment Avera Squa ge re off Average Gross Gross Square earn Gross Gross Calen No of Traded Trade off ed Calend No of Traded Traded dar instanc Value d earned (INR ar days instances Value (INR Value days es (INR In Value (INR In In In lakhs) (INR In lakhs) (INR lakhs) lakhs lakhs) In ) lakhs) No of Scrip days/Contract 618 32,56,882 28 930 618 3,43,816 1,91,07,410 56 8,279 days traded 1,16,602 Common Scrip days/Contract days with the 440 950 9,23,692 972 142 498 5,980 6,26,045 105 133 Big Clients No of Other Non-Common Scrip days/Contract days 618 23,33,189 20 788 618 3,37,836 1,84,81,364 55 8,146 1,15,652 with the Big Clients No of Scrip days/Contract days wherein day trading 618 82,482 27,24,178 33 711 618 1,09,028 76,44,501 70 2,368 (80% squared off) has been carried out No of Scrip days/Contract days wherein day traded (80% squared off) and 388 714 9,03,555 1,265 149 358 1,318 2,33,103 177 169 commonly traded with the Big Clients Instances where client earned a positive square off difference of INR 1 or more when day traded (80% squared off) and 85 97 4,79,944 4,948 560 26 26 16,955 652 41 commonly traded with the Big Clients and there is matched quantity between big client and any of the FRs

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others iii Trading profile of Anirudh Damani (FR 3)

Table no. 17 Trading profile of Anirudh Damani (FR 3) Equity Segment Equity Derivative Segment Avera ge Averag Gross Gross Squar Squar Gross e Gross No of Traded Trade e off No of e off Calenda Calenda Traded Traded instance Value d earned insta earned r days r days Value (INR Value s (INR In Value (INR In nces (INR In In lakhs) (INR In lakhs) (INR lakhs) lakhs) lakhs) In lakhs) No of Scrip days/Contract days 616 5,974 9,75,738 163 668 561 3,894 1,61,344 41 -33 traded Common Scrip days/Contract 85 103 4,94,154 4,798 382 37 44 10,191 232 0 days with the Big Clients No of Other Non-Common Scrip days/Contract days with the Big 616 5,871 4,81,584 82 286 561 3,850 1,51,153 39 -33 Clients No of Scrip days/Contract days wherein day trading (80% 317 492 5,49,185 1,116 598 196 306 15,135 49 69 squared off) has been carried out No of Scrip days/Contract days wherein day traded (80% 58 68 4,64,735 6,834 400 3 3 56 19 0 squared off) and commonly traded with the Big Clients Instances where client earned a positive square off difference of INR 1 or more when day traded (80% squared off) and 43 46 3,73,960 8,130 486 - - - - -commonly traded with the Big Clients and there is matched quantity between big client and any of the FRs

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others iv Trading profile of Ashok Kumar Damani (FR4)

Table no. 18 Trading profile of Ashok Kumar Damani (FR4) Equity Segment Equity Derivative Segment Avera ge Averag Gross Gross Squar Gross Squar e Gross No of Traded Trade e off No of Traded e off Calenda Calenda Traded instance Value d earned instanc Value earned r days r days Value s (INR In Value (INR In es (INR In (INR In (INR In lakhs) (INR lakhs) lakhs) lakhs) lakhs) In lakhs) No of Scrip days/Contract days 565 2,566 1,33,829 52 112 378 1,308 1,12,948 86 174 traded Common Scrip days/Contract days 13 13 32,689 2,515 0 14 17 10,498 618 4 with the Big Clients No of Other Non-Common Scrip days/Contract days with the Big 565 2,553 1,01,140 40 112 378 1,291 1,02,450 79 171 Clients No of Scrip days/Contract days wherein day trading (80% squared 109 126 37,333 296 57 79 106 31,960 302 169 off) has been carried out No of Scrip days/Contract days wherein day traded (80% squared 5 5 23,630 4,726 5 1 1 4,675 4,675 4 off) and commonly traded with the Big Clients Instances where client earned a positive square off difference of INR 1 or more when day traded (80% squared off) and commonly 3 3 20,332 6,777 17 - - - - -traded with the Big Clients and there is matched quantity between big client and any of the FRs

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others v Trading profile of Basukinath Properties Pvt Limited (FR5)

Table no. 19 Trading profile of Basukinath Properties Private Limited (FR5) Equity Segment Equity Derivative Segment Avera ge Squar Average Gross Square Gross e off Cale Gross Gross No of Trade off Calend Traded earne ndar No of Traded Traded instanc d earned ar days Value (INR d (INR day instances Value (INR Value es Value (INR In In lakhs) In s In lakhs) (INR In (INR lakhs) lakhs) lakhs) In lakhs) No of Scrip days/Contract 433 865 11,74,759 1,358 551 461 1,915 9,67,642 505 16 days traded Common Scrip days/Contract days with 86 121 11,02,310 9,110 508 74 90 62,048 689 34 the Big Clients No of Other Non- Common Scrip 404 744 72,449 97 44 453 1,825 9,05,595 496 -18 days/Contract days with the Big Clients No of Scrip days/Contract days wherein day trading 146 214 11,39,006 5,322 544 176 260 2,34,748 903 -216 (80% squared off) has been carried out No of Scrip days/Contract days wherein day traded (80% squared off) and 85 120 11,02,310 9,186 508 21 23 26,694 1,161 -9 commonly traded with the Big Clients Instances where client earned a positive square off difference of INR 1 or more when day traded (80% squared off) and 64 81 9,21,049 1,030 9 10 10,384 1,038 38 commonly traded with the 11,371 Big Clients and there is matched quantity between big client and any of the FRs Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others vi Trading profile of APR Properties Pvt Limited (FR6)

Table no. 20 Trading profile of APR Properties Private Limited (FR6) Equity Segment Equity Derivative Segment Avera Squar ge e off Average No Gross Square Gross earne Gross Gross of Traded off Calend Trade d Calend No of Traded Traded inst Value earned ar days d (INR ar days instances Value (INR Value anc (INR In (INR In Value In In lakhs) (INR In es lakhs) lakhs) (INR In lakhs lakhs) lakhs) ) No of Scrip days/Contract 239 428 5,17,273 1,209 242 398 1,539 10,04,759 653 729 days traded Common Scrip days/Contract days with the 41 55 4,50,576 8,192 168 89 110 69,087 628 70 Big Clients No of Other Non-Common Scrip days/Contract days 225 373 66,697 179 74 385 1,429 9,35,672 655 659 with the Big Clients No of Scrip days/Contract days wherein day trading 69 97 4,97,978 5,134 233 122 158 1,64,600 1,042 1,383 (80% squared off) has been carried out No of Scrip days/Contract days wherein day traded (80% squared off) and 40 54 4,50,575 8,344 168 19 20 17,138 857 62 commonly traded with the Big Clients Instances where client earned a positive square off difference of INR 1 or more when day traded (80% squared off) and commonly 28 35 2,77,932 7,941 407 7 7 8,591 1,227 46 traded with the Big Clients and there is matched quantity between big client and any of the FRs

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

64. From the tables above, it can be observed that FRs have earned significant profits through day trading majorly on common scrip day instances matching with the Big Client.

F. ROLE OF ROHIT SALGAOCAR IN OBTAINING AND SHARING NPI

65. The investigation revealed that although trades of the Big Client in India were spread across a large number of TMs, the trades executed through Motilal and Nuvama resulted in the maximum instances of NPI based trades. As per the data obtained from the Big Client, it was seen that the Big Client had traded through 29 Trading Members during the Investigation Period and around 5.2% and 9.1% of trades of the Big Client in the Indian equity markets was made through Motilal and Nuvama, respectively. During the search and seizure operation at the premises of traders of the aforesaid TMs, it was found that they used to execute trades for Big Client based on the instructions of Rohit Salgaocar even though he was not the authorised representative of the Big Client.

66. Further, Rohit Salgaocar used to operate through a corporate entity called Strait Crossing Pte Limited (SCPL) which was incorporated on March 15, 2016 and registered with Accounting and Corporate Regulatory Authority (ACRA) of Singapore. The Unique Entity Number (UEN) of SCPL is “201606768H” and its registered office address, as stated by Rohit Salgaocar, is “1 Harbourfront Place #03-11 Harbourfront Tower One Singapore (098633)”. The primary activity of SCPL is “Other Activities Auxiliary to Financial Service Activities N.E.C. (e.g. Mortgage Advisory Firms).

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

F.1 Arrangement between SCPL/Rohit Salgaocar and the Big Client

67. In its submission dated October 26, 2023, the Big Client stated that it did not have any agreement with SCPL or Rohit Salgaocar. However, traders of the Big Client, who knew Rohit Salgaocar, engaged with him while trading with respect to securities listed in India. The trade related conversation between Rohit Salgaocar and traders of the Big Client used to happen over Bloomberg chats and calls. In their statements, the traders have stated that Big Client was aware of the dealings with Rohit Salgaocar.

68. Upon analysis of the Bloomberg chats between traders of the Big Client and Rohit Salgaocar, it was found that traders of the Big Client and Rohit Salgaocar had frequent discussions with respect to trades in various scrips. There were occasions where the Big Client trader would provide Rohit Salgaocar with the quantum of trade and/or price at which they wanted to do certain trades in a scrip. The illustrations pertaining to the same are provided in Part G of this order.

69. Subsequently, the trader of the Big Client would provide the confirmation of going ahead with the trade and on a majority of instances, Rohit Salgaocar would ask trader of the Big Client to send the deal ticket to Motilal or Nuvama. The illustrations pertaining to the same are provided in Part G of this order.

70. Two traders of the Big Client namely, BCTrader1 and BCTrader26, were primarily responsible for trading securities listed in Indian markets on behalf of the Big Client and they handled 90% of the total value of the trades of Big Client referred to Motilal or Nuvama during the Investigation Period. In their statement made to SEBI, BCTrader1 and BCTrader2, stated that they would interact with 6 Note: Name of the traders of the Big Client have not been used and would be supplied to Noticees during inspection of documents and to Hon’ble SAT and Courts during court proceedings. Apart from these traders two other traders of Big Client, namely BCTrader3 and BCTrader4 have also been mentioned in this order. Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others various entities including Rohit Salgaocar for facilitating trades in Indian markets and that as per their understanding while the Big Client did not compensate Rohit Salgaocar, the Indian brokers compensated Rohit Salgaocar for his services. The relevant extracts from the statements of BCTrader2 recorded on May 28-30, 2024 at the office of the Big Client (Singapore) are reproduced below: “Q 18. How do you identify the broker for your trade? Reply — There are multiple factors I take into account for a broker selection. These may include maintaining continuity with a broker, who had earlier executed trade for us in that equity security of the company, brokers who were involved in the company's IPO, brokers who would have shown us their flows in certain companies which we are interested in. One of the reasons for limiting the number of brokers that receive our indications is to mitigate information leakage.

Q 19. Do you interact with anyone other than Trading Members (Brokers) registered with SEBI for the execution of your trades/facilitating execution of your trades? Reply — Yes, in addition to Indian brokers, I also used to interact with Mr. Rohit Salgaocar as someone who can source liquidity and help find the other side of the trade in the Indian market.

Q 27. Do you have any formal arrangement/contract with Rohit Salgaocar? Reply — No, I do not have any arrangement or contract with Rohit Salgaocar.

Q 28. Does Big Client have any formal arrangement/contract with Rohit Salgaocar, for availing his services? Reply — As per my knowledge, there is no formal arrangement/contract between Big Client and Rohit Salgaocar.

Q 29. Does Big Client pay any remuneration/fees/commission to Rohit Salgaocar for facilitating the trades? Reply — No, Big Client does not pay any remuneration/fees/commission to Rohit Salgaocar.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Q 30. Why was Rohit Salgaocar providing you with his services for helping you in executing Big Client trades? Reply —As per my knowledge, Rohit Salgaocar has agreements with various brokers that have been approved by Big Client for trade execution. I am not sure about the terms of the agreements but these brokers might have had a commission sharing arrangement with him or his firm Strait Crossing Pte Ltd.

Q 31. Is Big Client aware about your dealing with Rohit Salgaocar? Reply — Yes, Big Client is aware about my dealing with Rohit Salgaocar. The former regional manager of trading and former global head of trading knew about this. However, I do not know when they were first informed about this.

Q 32. Do you have arrangement with any other entity/person, like what you have with Rohit Salgaocar? Is there any other arrangement like Rohit in or outside India? Reply — For India, no. For markets outside India, I do not recall.”

71. From the Bloomberg chats between traders of the Big Client and Rohit Salgaocar, it is seen that the positions to be taken by the Big Client in various scrips during the Investigation Period were discussed. Various illustrations of the same are provided in Part G of this order. Further, the Bloomberg chats reveal that Rohit Salgaocar and traders of the Big Client also used to discuss trade related information with each other over calls.

Table no. 21 Extract of Bloomberg chat between Rohit Salgaocar and Trader of Big Client Time From Message Bloomberg chat on January 05, 2022 11:38:54 BCTrader1- Big Client I need some shares 11:38:56 Rohit Salgaocar - Strait Crossing Till 1:30pm delivery 259k 11:39:07 Rohit Salgaocar - Strait Crossing calling

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Time From Message Bloomberg chat on January 06, 2022 sure or if something comes BCTrader2 – Big Client 09:00:22 up then call BCTrader4 Will do, you have the algo set Rohit Salgaocar - Strait Crossing 09:01:03 in BHARTI right? Bloomberg chat on January 18, 2022 10:13:04 BCTrader2 – Big Client yo call me 10:13:13 Rohit Salgaocar - Strait Crossing calling Bloomberg chat on October 07, 2022 Hi BCTrader1 please let me Rohit Salgaocar - Strait Crossing 08:36:00 know when free 12:17:44 BCTrader1- Big Client Free house yo 12:18:08 Rohit Salgaocar - Strait Crossing Calling 14:02:22 BCTrader1- Big Client 1mn 876 if ever ICICI Bank 14:02:23 BCTrader1- Big Client can do 14:56:58 BCTrader1- Big Client closing up

72. Thus, Rohit Salgaocar used to obtain NPI through Bloomberg chats as well as through phone calls from the trader of the Big Client and had clear visibility of the quantum of buying/selling that the Big Client was about to undertake.

73. Rohit Salgaocar, in his statement dated March 7, 2024 and July 22, 2024, stated that he used to help the Big Client find counterparties for their trades in the Indian securities market, functioning as an Inter-Trader Broker. Further, most of his revenues, almost 90%, were from the Big Client trades in Indian Securities Market. He had no agreement with the Big Client for his services and had commission sharing agreements with the Indian TMs viz. Motilal, Nuvama etc. As per the agreements, the brokers would give him 75% of the net brokerage income after excluding costs from the trades of the Big Client. He Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others further stated that since 2021, he had routed 90% of the Big Client trades through Nuvama and Motilal. The relevant extracts from the statement of Rohit Salgaocar is reproduced below: “Q 21. From 2021 onwards, what is the percentage of Big Client’s trades that were routed by you through Motilal and Nuvama? Reply- Around 90%

Q 23. Explain how the trades for Big Client were executed by you? Reply-Dealer of the Big Client provides me with the name of the stock they are interested in. I will check the availability with different market participants including foreign funds, Indian funds, other holders of the shares etc and lastly with Ketan Parekh. After confirming the availability from the counterparty, I get back to the dealer of the Big Client with the quantity and price on offer. Upon confirmation from the dealer of the Big Client, the deal goes through. The Big Client dealer sends the deal ticket to the broker in India. After execution of the trades, Indian broker used to confirm me on Bloomberg chat. Sometimes, I used to get confirmation from Big Client dealers as well.

Q 27. In the reply to Q. No. 23, you have mentioned that you used to source counterparties through Mr. Ketan Parekh. What percentage of Big Client trades were being fulfilled by Ketan Parekh? Reply- Around 90%”

74. In view of the aforesaid discussion, the following facts are noted: i Traders of the Big Client and Rohit Salgaocar used to have frequent discussions with respect to trades in various scrips through Bloomberg chat as well as through phone calls; ii Various illustrations of Bloomberg chats, as provided in Part G of this order, will show that Rohit Salgaocar had clear visibility of the name of the scrip, quantum of buying/selling and the timing of execution of the trade that the Big Client was about to undertake in such scrips; iii Even in cases where the Bloomberg chats do not specify quantum/price of the impending order, Rohit Salgaocar had a fair idea about the price and quantity given his vast experience of dealing with the Big Client, owing to Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others his long standing relationship with them. He also used to speak to the traders of Big Client over calls which enabled him to have a fair insight about the impact of the Big Client orders on the existing demand and supply in the market; iv Rohit Salgaocar used to tell traders of the Big Client the name of the particular Indian Trading Member (mostly Motilal or Nuvama), to whom the deal ticket was to be sent for execution of trades. About 90% of trades of Big Client traded executed by Motilal and Nuvama were referred by Rohit Salgaocar. v Rohit Salgaocar was discussing impending trades of the Big Client with Ketan Parekh.

F.2 Agreements between SCPL/Rohit Salgaocar and Trading Members

75. Motilal and Nuvama had entered into a Memorandum of Understanding (MoU)/referral agreement (hereinafter “agreement”) with a Singapore based entity named SCPL.

76. Rohit Salgaocar, who was the only Director and the authorized signatory of SCPL, had signed the aforesaid agreements on behalf of SCPL. The said agreement outlined the scope of the services that SCPL would offer and the manner of its compensation which included, inter-alia, referral of clients by SCPL to the Motilal and Nuvama in return for a share in brokerage. The details of the said agreements are briefly discussed in the ensuing paragraphs.

77. Details of Agreement between SCPL and Motilal: The agreement between Motilal and SCPL, titled as “Memorandum of Understanding” (MoU) was made on January 21, 2021, which came into effect from January 25, 2021. Para 1 of the aforesaid MoU, provides for the scope of the arrangement between Motilal and SCPL, which states that the role of SCPL is only limited to the extent of Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others referring individuals/entities to Motilal for transacting in all traded securities and also initiate transactions on such securities from existing clients of Motilal.

78. Further, as per Schedule I of the said MoU, in consideration of carrying out the referral activity, Motilal was required to pay SCPL a referral fees of 75% of the net commission received, from the clients referred under the agreement. While the Big Client was an existing client of Motilal, the order flow of the Big Client to Motilal increased significantly after Motilal entered into the said agreement with SCPL. The same is illustrated in the table below:

Table no. 22 Change in Gross Traded Value (GTV) in the order flow of the Big Client to Motilal %age jump in GTV GTV GTV Total during the without through GTV investigation period Period Rohit Rohit (in INR vis-à-vis comparable Salgaocar Salgaocar# cr) period just before (in INR cr) (in INR cr) investigation period Jan 21- Jun 23 4,478 11,857 16,334 383.31 (Investigation period) Jul 18 - Dec 20 (Comparable 4,261 - 4,261 period prior to Investigation Period) # - Rohit Salgaocar entered into agreement with Motilal in January 2021. Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

79. Although Motilal had no written communication from the Big Client, authorising SCPL/ Rohit Salgaocar to act on their behalf or to handle their trades, the traders of Motilal were taking instructions from Rohit Salgaocar to execute trades of the Big Client. During the Investigation, Motilal contended that even though there was no written formal communication, the Big Client was aware that Rohit Salgaocar was facilitating/managing their trades and to substantiate the said contention, Motilal submitted a Bloomberg conversation, dated February 1, 2021, between trader of the Big Client (BCTrader1) and trader of Motilal, wherein BCTrader1 instructed Motilal to “order via Rohit”.

80. In view of the aforesaid discussions, following facts are noted: i Motilal entered into an agreement with SCPL for referral of clients; ii The Big Client was an existing client of Motilal. However, the order flow from the Big Client to Motilal increased by 383% after entering into the referral agreement with SCPL/Rohit Salgaocar and no client other than the Big Client was referred by SCPL to Motilal under the aforesaid agreement. iii SCPL was entitled for 75% referral commission on the trades of the Big Client; iv As the deal ticket from the Big Client was sent through the FIX system of Bloomberg, the execution status of the trades would only reflect in the system of the traders of the brokers and traders of the Big Client. However, Rohit Salgaocar was able to get the updates in respect of the trade execution through Bloomberg chats from traders of Motilal and Nuvama; v The trades of the Big Client were being executed by traders of Motilal as per the instructions of SCPL/ Rohit Salgaocar without there being any written mandate from the Big Client; vi Hence, the role of traders of Motilal and Nuvama was to punch the trades for the Big Client and the entire control with respect to the aforesaid trades was with Rohit Salgaocar.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

81. During the Investigation period, Motilal paid a total of INR 8,06,29,054 (around INR 8.06 crore) as referral fee/commission to Rohit Salgaocar.

82. Details of agreement between SCPL and Nuvama: The agreement between Nuvama and SCPL, titled as ‘Referral Agreement” was made on August 03, 2016. As per para 1.1 and 12.2 of the aforesaid referral agreement, the role of SCPL was limited to make the referrals only and the decision to execute trade was solely made by the Big Client and as per the agreement, SCPL was not to be involved in the making of such decision or in the execution of a trade by such client.

83. Further, as per Schedule 1 of the aforesaid referral agreement, in consideration of carrying out the referral activity, Nuvama was to pay SCPL a referral fees of 75% of the net brokerage earned. During the investigation period, except for Big Client, there was only one more client referred to Nuvama by SCPL under the said agreement. However, the trades from Big Client constitute more than 99% of such referred trades. The table below illustrates the aforesaid statement:

Table no. 23 Clients referred to Nuvama by SCPL during the Investigation Period

INR in Crores GTV of trades GTV of Clients of Nuvama involving trades Total GTV Rohit without Rohit Salgaocar Salgaocar Big Client 28,743.44 27,627.06 1,116.38 Other client 445.57 163.10 282.47 Total 29,189.01 27,790.16 1,398.85 Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

84. While the Big Client was an existing client of Nuvama, the order flow of the Big Client to Nuvama increased significantly during the Investigation Period vis-à-vis comparable period prior to the Investigation period. The same is illustrated in the table below:

Table no. 24 Change in Gross Traded Value (GTV) in the order flow of the Big Client to Nuvama %age jump in GTV during the GTV GTV investigation without through period vis-à-vis Total GTV Period Rohit Rohit comparable (in INR cr) Salgaocar Salgaocar period just (in INR cr) (in INR cr) before investigation period January 2021- June 2023 (Investigation 1,116 27,627 28,743 543.92 period) July 2018 - December 2020 (Comparable period 3,066 2,218 5,285 -prior to Investigation Period)

85. Although Nuvama had no written communication from the Big Client, authorising SCPL/ Rohit Salgaocar to act on their behalf or to handle their Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others trades, the traders of Nuvama were taking instructions from Rohit Salgaocar to execute trades of the Big Client. During the Investigation, Nuvama contended that even though there was no written formal communication, the Big Client was aware that Rohit Salgaocar was facilitating/managing their trades and to substantiate the said contention, Nuvama submitted an email communication with the Big Client, dated August 01, 2023, wherein trader of the Big Client (BCTrader1) informed Nuvama that “yes we trust Salgaocar help us achieve best execution as mandated by our funds, thank you for your attention to this matter and we would like to continue on with the relationship as is”. However, the aforesaid email was communicated after the search and seizure operation was carried out by SEBI.

86. In view of the aforesaid discussions, following facts are noted: i Nuvama entered into an agreement with SCPL/Rohit Salgaocar for referral of clients; ii The order flow from the Big Client to Nuvama increased by 543% during the Investigation Period vis-à-vis the comparable period prior to the Investigation Period and the quantum of gross traded value through Rohit Salgaocar/SCPL increased by almost 12 times; iii SCPL was entitled for 75% referral commission on the trades of the Big Client; iv Trades of the Big Client were being executed by traders of Nuvama as per the instructions of SCPL/ Rohit Salgaocar without there being any written mandate from the Big Client.

87. During the investigation period, Nuvama paid a total of INR 19,00,44,520 (around INR 19 crore) as referral fee/commission to Rohit Salgaocar.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

88. Thus, the total commission earned by Rohit Salgaocar during the investigation period, from Motilal and Nuvama was around INR 27.06 crore which was only in respect of the trades of the Big Client referred by SCPL/Rohit Salgaocar.

89. On analysis of the Bloomberg chats between Rohit Salgaocar and traders of Motilal and Nuvama, as illustrated in Part G of this order, it is seen that:

i Traders of Motilal and Nuvama would update Rohit Salgaocar upon receipt of the deal ticket (refer Bloomberg chats provided in Table no. 32).

ii Thereafter, Rohit Salgaocar would instruct traders of Motilal and Nuvama to immediately place an order in the scrip and sometimes to also provide them with the price and/or quantity at which such deal ticket was to be executed. (refer Bloomberg chats provided in Table no. 32).

iii In some instances, it was observed that Rohit Salgaocar would start giving instructions for trade even prior to the deal ticket/ order being received from the Big Client by Motilal and Nuvama. To illustrate, on September 16, 2021, Rohit Salgaocar instructed trader of Motilal, at 12:09:49 PM, to buy 5 lakh Bharti Airtel at INR 725 (this order was in continuation to the buy orders from morning that day), however, the trader of Motilal gave the confirmation of receipt of the deal ticket at 12:10:08 PM only. The relevant extract of Bloomberg chat between Rohit Salgaocar and Trader of Motilal is provided below: Table no. 25 Extract of Bloomberg chat between Rohit Salgaocar and Trader of Motilal on September 16, 2021 Time From Message 12:09:49 Rohit Salgaocar - Strait Crossing 500k 725 12:09:53 Rohit Salgaocar - Strait Crossing Get ready Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Time From Message 12:10:08 go the ticket I am ready on Trader of Motilal nse at 725 12:10:12 Rohit Salgaocar - Strait Crossing Go in 12:10:34 Trader of Motilal 477k pending 12:11:35 Trader of Motilal 137k pending 12:11:53 Rohit Salgaocar - Strait Crossing Reduce and wait 12:11:55 Trader of Motilal ok 12:16:02 Trader of Motilal 90k pending iv After receiving trade related instructions from Rohit Salgaocar, the traders of Motilal and Nuvama would continuously update Rohit Salgaocar about the execution status of the trades (as seen in the table above as well as in Part G of this order).

90. Thus, it can be seen that traders of Motilal and Nuvama were executing trades on the instructions of Rohit Salgaocar, even though, the Big Client had never authorised Motilal or Nuvama to take instructions from Rohit Salgaocar to execute its trades.

91. A diagrammatic representation depicting the arrangement between TMs and Rohit Salgaocar, arrangement between the Big Client and Rohit Salgaocar and the flow of information regarding the Big Client is as under:

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Figure no. 7 Flow of NPI regarding the trades of the Big Client

F.3 Misleading and false information provided by Rohit Salgaocar to traders of the Big Client

92. Rohit Salgaocar, in his statement dated March 7, 2024 and July 22, 2024, stated that he used to help Big Client find counterparties for its trades in the Indian securities market. However, from the analysis of Bloomberg chats between traders of the Big Client and Rohit Salgaocar, it has been seen that Rohit Salgaocar used to provide false information about the identity of the counterparties which he was in fact sourcing from Ketan Parekh. An illustration in this respect is shown below.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

93. On December 08, 2021, BCTrader2 (trader of the Big Client) and Rohit Salgaocar were seen to be discussing a buy trade in L&T and the Bloomberg chat with respect to the same is placed below:

Table no. 26 Bloomberg chat between Big Client trader and Rohit Salgaocar on Dec 08, 2021

Time From Message 08:40:12 BCTrader2 – Big Client i also have LT to buy, trying not to pay above 1800 Rohit Salgaocar - Strait 08:46:06 Got it Crossing Rohit Salgaocar - Strait 500K LT corporate seller from treasury.... You would 10:25:23 Crossing care? 10:26:26 BCTrader2 – Big Client ok Rohit Salgaocar - Strait 10:26:40 Crossing done Rohit Salgaocar - Strait Insurance for 200k and local HNI for 50k. Any care 12:17:26 Crossing total 250k Rohit Salgaocar - Strait 12:53:41 Crossing 350k 1833 12:54:11 BCTrader2 – Big Client ok

94. As seen from the chat above, Rohit Salgaocar, at around 10:25 am offered 500K L&T saying that a corporate treasury was the seller. Thereafter, at 12:17 pm he offered 250K L&T saying that 200K was from Insurance and 50K from a local HNI. Thereafter, he increased the offer size to 350K.

95. However, from the analysis of the trade log, it is observed that in this trade, FR2/Salasar Stock Broking Limited and FR5/APR Properties Private Limited matched almost 85.42% of the buy quantity of the Big Client (8,50,000 shares). Further, both the FRs had built the long position in L&T, just prior to the entry

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others of the Big Client. Thus, it is clear that FR2 and FR5 did NPI-based trades. The table below provides the details of the same:

Table no. 27 Summary of trades undertaken by FR2 and FR5 on December 08, 2021

Average Sum of Partic Buy/ Trade Start Trade Trade Price Match Information Trade ulars Sell Time End Time Range Vol. Qty (in INR) Buy trades FR5 Buy 09:15:38 10:14:50 3,50,000 1,825.29 -by FRs, prior to first FR2 Buy 10:15:38 10:20:21 11,905 1,829.06 -matching instance BC Buy 10:28:45 10:28:45 5,00,000 1,833.92 - Matching – FR2 Sell 10:28:45 10:28:45 40,000 1,834.00 40,000 Instance 1 FR5 Sell 10:28:45 10:28:45 4,20,000 1,834.00 4,17,495 Between first FR5 Buy 10:30:45 12:20:52 2,41,578 1,831.49 -and second FR5 Sell 12:32:49 12:35:56 1,841 1,837.00 -matching FR2 Buy 10:54:33 11:50:44 85,838 1,830.94 -instance FR2 Sell 12:10:06 12:14:53 7,743 1,835.66 - BC Buy 12:55:54 12:56:10 3,07,883 1,833.00 Matching – FR2 Sell 12:55:54 12:55:54 75,000 1,833.00 75,000 Instance 2 FR5 Sell 12:55:54 12:55:54 2,00,000 1,833.00 1,93,576 After second BC Buy 13:12:19 14:06:57 42,117 1,833.00 -matching FR5 Buy 14:21:46 14:47:32 30,263 1,829.99 -instance FR2 Buy 14:47:33 15:04:08 25,000 1,828.06 -

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Table no. 28 Matching between the big client and the FRs on December 08, 2021

Buyer Name Trade Time Seller Name Trade Quantity FR2 40,000 10:28:45 FR5 4,17,495 AXXXP7 FUND FR2 75,000 12:55:54 FR5 1,93,576 Grand Total 7,26,071

Table no. 29 Long positions built by each of the FR during the day Time period/FR FR2 FR5 Prior to first matching at 10:28:45 hrs 11,905 3,50,000 Between first matching at 10:28:45 hrs and second 85,838 2,41,578 matching at 12:55:54 hrs After second matching at 12:55:54 hrs 25,000 30,263 Total 1,22,743 6,21,841

96. From the tables above, following facts are seen: i The trades of Big Client have matched with the FRs which were arranged by Ketan Parekh;

ii Rohit Salgaocar and Ketan Parekh, together, knowing that the Big Client would be buying shares of L&T that day, first bought the shares through various FRs, and subsequently squared off the positions by matching it with the trades of the Big Client;

7 The identity of the Fund of Big Client is masked and will be revealed to the Noticees during inspection. Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others iii Rohit Salgaocar was providing false details about the counterparty to the Big Client trader when he told him that the seller in the trade was a corporate treasury, an insurance company and a local HNI;

iv Thus, in the garb of identifying pools of liquidity for the Big Client trade, Rohit Salgaocar, along with Ketan Parekh, was essentially running a scheme involving trading on the basis of the NPI about the impending orders of the Big Client in various scrips, through the accounts of various FRs, and profiting unduly from such trades.

97. Further, as per the statement of Rohit Salgaocar, he used to route almost 90% of the Big Client trades through Nuvama and Motilal, from which he earned an aggregate commission of around INR 27.06 crores. Further, 90% of these trades were being fulfilled by Ketan Parekh alone. The commissions earned by Rohit Salgaocar could not have been possible without the aforesaid scheme orchestrated by Rohit Salgaocar in connivance with Ketan Parekh and therefore the gains made through commissions by Rohit Salgaocar are also in the nature of ill-gotten gains.

G. ILLUSTRATIONS OF NPI-BASED TRADING ACTIVITIES IN THE ACCOUNTS OF FRs 98. Trading activities in the accounts of various FRs have been examined based on the trend of order placement by FRs which matched with the orders of the Big Client as well as the correlation between such trades and flow of NPI between various Noticees. In case where multiple instances of matching are observed between FRs and Big Client on a particular day, order placement analysis is illustrated below for a particular time patch only.

99. To illustrate that the trades carried out by FRs were in fact NPI-based trades, following evidences have been provided in illustrations in ensuing paragraphs:

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others i scrip, quantity, price and timing of trades undertaken by FRs and Big Client on a particular day; ii Bloomberg chats between trader(s) of the Big Client and Rohit Salgaocar showing timed communication of NPI to Rohit Salgaocar which included scrip and quantity/price of the impending order of the Big Client in various scrips; iii Bloomberg chats between traders of Motilal and Nuvama with Rohit Salgaocar showing that Rohit Salgaocar was instructing traders for execution of the orders of Big Client and was getting prompt updates about the execution status of orders from them; iv chats between Ketan Parekh and the FRs/ facilitators through WhatsApp groups “Jack-Saro” and “Jack-ST” showing sufficient evidence that such timely and precise communication of NPI by Ketan Parekh to FRs could not have been possible without involvement of Rohit Salgaocar. (Note: The co-relation and communication between Rohit Salgaocar and Ketan Parekh has already been explained in paragraphs 32 to 36.)

100. Communication of NPI from Rohit Salgaocar to Ketan Parekh is inferred from the following: i IPDRs of the various mobile numbers of Ketan Parekh which matched with the IP address of Rohit Salgaocar; ii Statements made by Rohit Salgaocar and Ketan Parekh to the IA; iii Simultaneous communication between Rohit Salgaocar and the traders of Big Client on one hand and the trading instructions made by Ketan Parekh, directly or indirectly to FRs on the other hand in a time co-ordinated manner.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

G.1 Illustration of NPI-based trades by FR1 and FR2 in the scrip of Titan Company Limited (TITAN/500114) on April 05, 2023 101. On analysis of the trade logs, it is observed that FR1 and FR2 have undertaken NPI-based Trades against the orders of Sxxxxxxxxxxxd Inc., one of the Funds of the Big Client, making an overall profit of INR 10,88,086.20 on that day.

102. It is observed that during the day FR1 and FR2 matched their sell orders with the buy orders of the Big Client in three different time patches. During these time patches, the Big Client bought 2.5 lakh shares out of which FR1 and FR2 matched 2,25,616 shares.

103. The trades in one of the time patches, showing matching of trades between the Big Client and FR1 is illustrated and explained below:

Table no. 30 Trades undertaken by the FR1 and Big Client Parti Buy Count Order Order Trade Trade Sum of Average Trade Matc cular / of Start End Start End Trade Price Range (in h s Sell Orders Time Time Time Time Qty INR) Vol. 09:25:5 09:25:5 2561.25-2577.95 FR1 Buy 5 09:20:08 09:20:08 76,000 - 9 9 (2568.81) 09:27:5 09:28:0 09:30:4 2569.15-2570.00 BC Buy 3 09:27:54 1,00,000 - 4 4 3 (2570) 09:30:2 09:37:3 2570-2572 87,0 FR1 Sell 7 09:27:49 09:27:49 98,174 7 1 (2570.07) 41

104. From the table above, it is seen that: i FR1 had placed 5 Buy orders during the period between 09:20:08 to 09:25:59. A quantity of 76,000 shares was executed at an average price of INR 2,568.81. It is noted that the price of the scrip increased, from INR 2,537.40 (previous day close price) to INR 2,574.60 i.e. till the time FR1 executed buy trades. Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others ii Subsequently, the Big Client placed 3 buy orders for a cumulative quantity of 1,00,000 shares between 09:27:54 and 09:28:04 at a price of INR 2570 and the same got executed. iii At that time, FR1 also placed 7 sell orders for shares between 09:27:49- 09:30:27. A quantity of 98,174 shares got executed and of this 87,041 shares matched with the order of the Big Client i.e., 88.66% of the total shares sold by FR1. iv FR1, during the aforementioned patch, oversold a net of 22,174 shares and matched trades with the Big Client in 3 patches. Further, FR1 squared off its entire position during the day.

105. While the trades executed by the Big Client and the FR1 have been exhibited above, the manner in which the instructions in respect of the aforesaid trades were passed between various entities is shown below.

Table no. 31 Instruction with respect to the positions taken by FR1 prior to entry of the Big Client Column 1: Column 2: Bloomberg chat between the Big Trading Instructions from 955A (Ketan Parekh) on Client trader and Rohit Salgaocar on WhatsApp group Jack-ST on April 05, 2023 April 05, 2023 Time From Message 08:41:26 BCTrader3 - I would like Big Client to buy HDFCB and TTAN today 08:41:28 Rohit Hi Salgaocar - BCTrader3 Strait Crossing good morning

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Column 1: Column 2: Bloomberg chat between the Big Trading Instructions from 955A (Ketan Parekh) on Client trader and Rohit Salgaocar on WhatsApp group Jack-ST on April 05, 2023 April 05, 2023 08:41:46 BCTrader3 - about Big Client $90m in HDFCB, $20m in TTAN 08:42:01 Rohit Got it, am Salgaocar - checking Strait Crossing on these, will be back

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Column 1: Column 2: Bloomberg chat between the Big Trading Instructions from 955A (Ketan Parekh) on Client trader and Rohit Salgaocar on WhatsApp group Jack-ST on April 05, 2023 April 05, 2023

106. From Column 1 and 2 in table above, it is seen that: i at around 8:41 am, Big Client trader told Rohit Salgaocar that they were looking to buy shares of Titan. The trader had also provided the quantum which they wanted to buy. ii at around 9:16 am, Ketan Parekh simultaneously instructed to buy Titan in the group “Jack-ST”. However, upon knowing that the buying by FRs was happening in F&O, clarified that the buying was to be done in cash market. iii at around 9:19 am and 9:24 am, Ketan Parekh gave 2 instructions for buying 50,000 and 25,000 shares of Titan, each, in the group “Jack-ST”

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others and thereafter Rahul (employee of Sanjay Taparia) provided confirmation in this regard at 9:21 am and 9:26 am.

107. In view of the above, the cumulative buying of 76,000 shares done in the account of FR1 can be correlated with the impending order of the Big Client since Rohit Salgaocar knew about the quantum of Titan shares which the Big Client wanted to buy and accordingly passed this information to Ketan Parekh who then instructed to buy 75,000 shares. It is seen that FR1 bought additional 1000 shares on its own. The further flow of this NPI from Ketan Parekh to FRs can be seen in the table below: Table no. 32 Instructions with respect of the positions taken by the FR1 and BC, when matching took place Column 1: Column 2: Column 3: Bloomberg chat between Big Bloomberg chat between Trading Instructions from Client trader and Rohit Rohit Salgaocar and the 955A/Jack New (Ketan Parekh) on Salgaocar on April 05, 2023 trader of Nuvama on April 05, WhatsApp 2023 Time From Message Messag 09:25:40 Rohit 100k Time From e Salgaocar - TTAN 09:27:4 Trader of Recd Strait would you 0 Nuvama TTAN Crossing care? Rohit 09:26:42 BCTrader3 - Yea! 09:27:5 Salgaoc GO IN Big Client 0 ar - Strait 09:27:03 BCTrader3 - 2570 Crossing Big Client 09:27:5 Trader of ok 09:27:04 BCTrader3 - ? 2 Nuvama Big Client 09:27:5 Trader of ok 09:27:09 Rohit checking 4 Nuvama Salgaocar - 09:27:5 Trader of in Strait 4 Nuvama Crossing

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Column 1: Column 2: Column 3: Bloomberg chat between Big Bloomberg chat between Trading Instructions from Client trader and Rohit Rohit Salgaocar and the 955A/Jack New (Ketan Parekh) on Salgaocar on April 05, 2023 trader of Nuvama on April 05, WhatsApp 2023 09:27:21 Rohit That's 09:27:5 Trader of 47k Salgaocar - done 9 Nuvama Strait nuvama 09:28:0 Trader of 73k Crossing pls 0 Nuvama 09:28:0 Trader of 27k 7 Nuvama pending 09:28:1 Trader of 87k 4 Nuvama Rohit 09:29:5 Salgaoc NOW? 7 ar - Strait Crossing 09:30:0 Trader of TTAN 0 Nuvama 13k pendi 09:30:3 Trader of TTAN 3 Nuvama 99k Trader of TTAN: 09:30:4 Nuvama completer 9 d 09:30:5 Trader of 100k @ 5 Nuvama 2570

108. From the aforesaid table, it is seen that: i (Column 1) At around 9:25 am, Rohit Salgaocar, continuing his earlier chat with the trader of the Big Client, confirmed whether the Big Client would purchase 1 lakh shares of Titan. Subsequently, the price of the shares (@ INR 2570) was also agreed upon and Rohit Salgaocar asked trader of the Big Client to send the deal ticket to Nuvama at 9:27 am.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others ii (Column 2) At around 9:27 am, the trader of Nuvama informed Rohit Salgaocar that deal ticket was received from the Big Client trader and Rohit Salgaocar instructed Nuvama’s trader to place the order. Afterwards, Nuvama’s trader provided continuous updates to Rohit Salgaocar about the execution of the order and in the end confirmed order completion at 9:30:49.

iii (Column 3) At around 9:27 am, Ketan Parekh, in the group “Jack-ST” instructed to sell 1 lakh Titan shares at INR 2570, in response to which, Rahul Saraf (employee of Sanjay Taparia) confirmed placing order of sell of 1 lakh shares of Titan at INR 2570 per share sold at 09:28 AM. This can be correlated with the cumulative selling of 98,174 shares done in the account of FR1, as shown above. The instructions received were for 1,00,000 shares, however, FR1 placed orders of 1,01,000 shares.

109. In respect of the quantity and price at which the Big Client was to buy Titan Limited, following is noted: i Rohit Salgaocar had a vast experience of dealing with the Big Client, owing to his long standing relationship with them. This enabled him to have a fair insight about the impact of the Big Client orders on the existing demand and supply in the market. Further, in the instant case, Big Client had upfront indicated, as evident from their chat, that the Big Client wanted to buy Titan worth 20 million USD. Thus, Rohit Salgaocar had a fair idea about the size and the price at which the trades of the Big Client could be executed.

ii This becomes all the more evident, given the fact that on April 05, 2023, the volume in the Titan jumped by almost 50% (14.8 lakhs) in comparison to its last 30-day average volume (9.76 lakhs), with almost 65% of average daily trading volume of last 30 days (6.35 lakhs) being contributed by the Big Client and FRs. Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

110. In view of the aforesaid illustration, it is seen that: i The chats in the tables above and the timing of flow of NPI between various entities prima facie establishes that the information of the forthcoming buy order of the Big Client in the scrip Titan reached to Ketan Parekh in a perfectly time-coordinated manner.

ii As Rohit Salgaocar received instructions from trader of the Big Client about buying Titan that day, the same was communicated to Ketan Parekh, who in turn instructed Sanjay Taparia (who had access to the trading account of FR1) to buy shares of Titan. Thereafter, just when the Big Client ordered to buy the shares of Titan, Ketan Parekh immediately instructed Sanjay Taparia to place sell order, which matched with the buy order of the Big Client.

iii This process of matching the Buy orders of the Big Client with the sell orders of FRs happened 2 more times in the day, where trades were placed through the account of FR1 and FR2.

iv Thus, armed with the knowledge of the NPI of the impending orders of the Big Client, Ketan Parekh got trades of such large quantity executed in the accounts of FR1 and FR2, which otherwise they would not have undertaken. This resulted in FR1 and FR2 matching with almost 90.25% of the buy quantity of the BC in the aforesaid time patches, leading to a total square off profit of INR 10,88,086.20 for FR1 and FR2 as calculated in the table below:

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Table no. 33 Calculation of unlawful gains made under this illustration Average Average FR Buy Qty Buy Value Buy Price Sell Qty Sell Value Sell Price Profit FR1 2,49,908 64,21,59,740 2,569.58 2,49,908 64,31,40,637 2,573.51 9,80,896.95 FR2 35,250 9,06,45,247 2,571.50 35,250 9,07,52,436 2,574.54 1,07,189.25 Total Profit made by the FRs 10,88,086.20

111. It is also seen that the value of the shares of Titan, bought by the Big Client on April 05, 2023, was less than the targeted quantity and the Titan trade was carried over next trading day (April 06, 2023), where FR1 again traded based on NPI. The trades undertaken by FR 1 and the Big Client on April 06, 2023, wherein FR1 earned a square off profit of INR 5,56,909, is provided in the table below: Table no. 34 Trades undertaken by FR 1 and the Big Client in on April 06, 2023 Average Count Order Order Trade Trade Sum of Buy/ Trade Price Match Particulars of Start End Start End Trade Sell Range (in Vol. Orders Time Time Time Time Qty INR) 2554.85- FR 1 Buy 4 09:20:26 09:38:07 09:20:26 09:38:54 78,430 2560.00 - (2559.39) 2571.00- FR 1 Sell 1 09:21:44 09:21:44 09:22:02 09:22:02 1 2571.00 - (2571.00) 2560.00- BC Buy 4 09:39:46 09:39:46 09:39:49 09:42:36 1,50,000 2560.00 - (2560.00) 2560.00- FR 1 Sell 6 09:39:49 09:42:36 09:39:49 09:42:38 1,50,000 2561.00 1,37,869 (2560.00)

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Average Count Order Order Trade Trade Sum of Buy/ Trade Price Match Particulars of Start End Start End Trade Sell Range (in Vol. Orders Time Time Time Time Qty INR) 2545.00- FR 1 Buy 13 09:45:08 15:29:05 09:45:08 15:29:19 71,571 2557.00 - (2552.90)

112. Thus, trades in a particular scrip have also been carried over to next day in some instances and thus FRs have made unlawful gains over and above what can be seen on a given day.

G.2 Illustration of NPI-based trades by FR2 in the scrip of HDFC Limited (HDFC/500010) on September 19, 2022

113. On analysis of trade logs, it is observed that FR2 has undertaken NPI-based trades against orders of AXXXP Fund, one of the funds of the Big Client, making an overall profit of INR 12,68,193.00 on that day.

114. It is observed that during the day, FR2 matched its sell orders with the buy orders of the Big Client in 1 time patch. During this time patch the Big Client bought a total of 2.5 lakh shares of HDFC Limited out of which FR2 matched 99,173 shares.

115. The trades undertaken by FR2 and the Big Client in time period prior to matching and during matching of orders are illustrated and explained below:

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Table no. 35 Trades undertaken by the FR2 and Big Client during aforesaid time period Partic Buy Coun Order Order Trade Trade Sum of Average Trade Match ulars / t of Start End Start End Time Trade Price Range (in Vol. Sell Order Time Time Time Qty INR) s 2428.80-2439.00 FR2 Buy 13 10:03:42 10:32:32 10:03:42 10:32:34 1,00,000 - (2433.32) Big Buy 7 11:11:02 11:11:17 11:11:02 11:11:26 2,50,000 2446 - Client FR2 Sell 4 11:11:08 11:11:08 11:11:08 11:11:08 1,00,000 2446 99,173

116. From the table above, it is seen that: i FR2 placed 13 Buy orders during the period between 10:03:42 to 10:32:32. Entire quantity of 1,00,000 shares was executed at an average price of INR 2433.32. ii Subsequently, the Big Client placed 7 buy orders for a cumulative quantity of 2,50,000 shares during the period between 11:11:02 - 11:11:17. The same got executed at an average price of INR 2446. iii At that time FR2 also placed 4 sell orders at 11:11:08, and the entire quantity of 1,00,000 shares got executed at an average price of INR 2446 of which 99,173 shares matched with the Big Client order i.e. 99.17% of the total shares sold by FR2.

117. While the trades executed by the Big Client and the FR2 have been exhibited above, the manner in which the instructions in respect of the aforesaid trades were passed between various entities are shown below.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Table no. 36 Instructions in respect of the positions taken by the FR2, prior to the entry of the Big Client Column 1: Column 2: Bloomberg chat between Big Client Trading Instructions from Jack New (Ketan Parekh) on trader and Rohit Salgaocar on WhatsApp group Jack-Saro on September 19, 2022 September 19, 2022 Time From Message

BCTrader2 – i can buy 09:59:09 Big Client slug of HDFC too

Rohit HDFC, not 09:59:32 Salgaocar - the banks Strait Crossing right?

BCTrader2 – that's right. 09:59:42 Big Client HDFC

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

118. From columns 1 and 2 in the table above, it is seen that: i at around 9:59 am, trader of the Big Client told Rohit Salgaocar that they would buy HDFC Limited. ii at around 10:03 am, Ketan Parekh simultaneously started instructing to buy HDFC in the group “Jack-ST”. Further, at around 10:32 am he instructed to complete 1 lakh buy. The messages are reflected and acknowledged in the group by “Sam” (name of the mobile kept in the office of FR2 as discussed at paragraph 48) of buying 100K shares of HDFC @ 2433.80 @ 10:33AM. This can be correlated with the cumulative buying of 1,00,000 shares of HDFC Limited, done in the account of FR2, as seen in table above at an average price of 2433.32 per share at 10:32:34.

119. The further flow of the aforesaid NPI from Ketan Parekh to FRs can also been seen in the table below:

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Table no. 37 Instructions with respect of the positions taken by the FR2 and Big Client, when matching took place Column 1: Column 2: Column 3: Bloomberg chat between Big Client Bloomberg chat between Rohit Trading Instructions from Jack New trader and Rohit Salgaocar on Salgaocar and the trader of (Ketan Parekh) on WhatsApp group September 19, 2022 Nuvama on September 19, 2022 Jack-Saro Time From Message Time From Message 11:08:00 Rohit Small Trader of Recd 11:10:43 Salgaocar - HDFC and Nuvama HDFC Strait I don't Rohit 250k Crossing think Salgaocar - 11:10:45 HDFC grows Strait 2446 250k too Crossing irch or Rohit small? Salgaocar - 11:11:00 Go inb 11:08:41 BCTrader2 – looking Strait Big Client Crossing 11:09:10 BCTrader2 – 2445 Trader of 11:11:02 ok Big Client Nuvama 11:09:54 Rohit 2446? Trader of 11:11:06 26k done Salgaocar - Nuvama Strait Trader of 11:11:08 52k done Crossing Nuvama 11:10:06 Rohit 250k Trader of 176k 11:11:11 Salgaocar - Nuvama done Strait Trader of 200k 11:11:13 Crossing Nuvama done 11:10:15 BCTrader2 – Ok Trader of 224k 11:11:15 Big Client Nuvama done 11:10:19 Rohit thx Trader of 26k 11:11:25 Salgaocar - Nuvama pending Strait Trader of 11:11:28 done Crossing Nuvama

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Column 1: Column 2: Column 3: Bloomberg chat between Big Client Bloomberg chat between Rohit Trading Instructions from Jack New trader and Rohit Salgaocar on Salgaocar and the trader of (Ketan Parekh) on WhatsApp group September 19, 2022 Nuvama on September 19, 2022 Jack-Saro 11:10:23 Rohit Edel pls Trader of Bought Salgaocar - 11:11:47 Nuvama 250k @ Strait 2446.00 Crossing 11:10:38 BCTrader2 – sent Big Client

120. From the aforesaid table, it is seen that: i (Column 1) At around 11:08 am, Rohit Salgaocar, continuing his earlier chat with the trader of the Big Client, offered 2.5 lakhs shares at INR 2446 and the trader then agreed to the trade, after which Rohit Salgaocar asked the Big Client trader to send the deal ticket to the Edelweiss (now Nuvama). ii (Column 2) At around 11:10 am, the trader of Nuvama informed Rohit Salgaocar that deal ticket was received from the Big Client and Rohit Salgaocar instructed Nuvama’s trader to place the HDFC order. Afterwards, Nuvama’s trader provided to Rohit, continuous updates about the order and in the end confirmed order completion. iii (Column 3) At around 11:11 am, Ketan Parekh instructed to sell HDFC at INR 2446, in the group “Jack-Saro” to which Sam (mobile phone kept in the office of FR2) confirmed at 11:11 AM that 1 lakh shares of HDFC had been sold @ 2446. This can be correlated with the cumulative selling of 1,00,000 shares of HDFC Limited, in the account of FR2, as seen in the table above. Further, as can be seen in table above, the instructions across 3 different chat windows were time coordinated.

iv In respect of the quantity and price at which the Big Client was to buy HDFC Limited, as explained above, Rohit Salgaocar, owing to his vast experience of dealing with the Big Client and his insights in respect of the impact of the Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Big Client orders on the existing demand and supply in the market, had a fair idea about the size and the price at which the trades of the Big Client could be executed.

v The aforesaid analysis gets supported by the fact that on September 19, 2022 the volume in the HDFC Limited jumped by almost 75% (45.85 lakhs) in comparison to its 30-day average volume (26.17 lakhs). The Big Client and FR2 contributed around 5.5 lakhs to this volume, which is roughly 21% of the average daily trading volume of last 30 days.

121. In view of the aforesaid illustration, it is seen that: i The chats in the tables above and the timing of flow of NPI between various entities prima facie establishes that the information of the forthcoming buy order of AXXXP Fund in the scrip of HDFC Limited reached to Ketan Parekh in a perfectly time-coordinated manner.

ii As Rohit Salgaocar received instructions from trader of the Big Client about buying HDFC Limited, he communicated the same to Ketan Parekh who in turn instructed FR2 to buy shares of HDFC Limited.

iii Thereafter, just when the Big Client ordered to buy the shares of HDFC Limited, Ketan Parekh immediately instructed FR2 to place sell order, which matched with the buy order of the Big Client.

iv Thus, armed with the knowledge of the NPI of the impending buy orders of the Big Client, Ketan Parekh got trades of such large quantity executed in the account of FR2, which otherwise it would not have undertaken. This resulted in FR2 matching with almost 39.67% of the buy quantity of the Big Client in the aforesaid time-patch, and made a total square off profit of INR 12,68,193.00 as calculated in the table below: Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Table no. 38 Calculation of unlawful gains made under this illustration Average Average Sell FR Buy Qty Buy Value Buy Price Sell Qty Sell Value Price Profit FR2 1,00,000 24,33,31,808 2,433.32 1,00,000 24,46,00,001 2,446.00 12,68,193.00

G.3 Illustration of NPI-based trade by FR1, FR2 and FR3 in the scrip of Policy Bazar Limited (PB Fintech/ 543390) on November 11, 2022

122. On analysis of the trade logs, it is observed that FR1, FR2 and FR3 have undertaken NPI-based Trades against the orders of two funds of the Big Client (Big Client) namely AXXXP Fund and Axxxxxxn Fund, making an overall profit of INR 18,55,650 on that day.

123. It is observed that during the day, two funds of the Big Client (AXXXP Fund and Axxxxxxn Fund) sold a total of 52.5 lakh shares of Policy Bazar Limited, in multiple time patches. During 3 time patches, either of FR1, FR2 and FR3 matched their buy orders with the sell orders of the Big Client, resulting in matched quantity of 20,61,291 shares.

124. Of the 3 time patches wherein NPI-based trading was observed, trading in 2 time patches has been shown wherein the first patch involves matching of trades of FR2 and the Big Client and the second time patch involves matching of trades of FR1, FR2 and FR3 with that of the Big Client.

125. The trades in the first time patch, showing matching of trades between the Big Client and FR2 is illustrated and explained below:

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Table no. 39 Trades undertaken by FR2 and Big Client Part Bu Count Order Order Order Trade Trade Sum Average Mat icul y/ of Start End Limit Start End of Trade Price ch ars Sel Order Time Time Price Time Time Trade Range (in Vol. l s Range Qty INR) FR2 Sell 16 09:15: 09:58: 379.5 - 09:15: 10:01: 5,00,0 379.50-383.75 - 00 48 383.75 00 48 00 (382.62) Big Sell 7 10:02: 10:02: 382 10:02: 10:02: 17,50, 382.00-383.45 - Clie 16 16 16 16 000 (382.00) nt FR2 Bu 7 10:01: 10:02: 382 10:02: 10:02: 5,00,0 382.00-382.00 4,95 y 50 14 16 16 00 (382.00) ,873

126. From the table above, it is seen that: i Between 09:15:00 to 09:58:48, FR2 had placed 16 sell orders, in which 5,00,000 shares were executed at an average price of INR 382.62.

ii Around 10:02:16 am, Big Client placed 7 sell orders of which 17,50,000 shares which got executed at an average price of INR 382.

iii Between 10:01:50 - 10:02:14, FR2 placed 7 buy orders for 5,00,000 shares which got executed at an average price of INR 382 and of this 4,95,873 shares matched with the Big Client order i.e., 99.17% of the total shares bought by FR2.

127. While the trades executed by the Big Client and FR2 have been exhibited above, the manner in which the instructions in respect of the aforesaid trades were passed between various entities are shown below.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Table no. 40 Instructions in respect of the positions taken by the FR2, prior to the entry of the Big Client Column 1: Column 2: Bloomberg chat between Big Client Trading Instructions from Jack New (Ketan Parekh) trader and Rohit Salgaocar on on WhatsApp group Jack-Saro November 11, 2022 Time From Message Hi BCTrader2 Good Morning. Back in the PLM north of 1000 for blocks, Rohit APTUS 325 ob 08:02:2 Salgaocar and 5 - Strait POLICYBZ(ther Crossing e are whispers around that someone is trying to build a book)] yo rohit morning. BCTrader 08:07:1 Hopefully helps 2 -Big 4 some of this Client stuff i'm trying to sell Rohit This POLICYBZ 08:08:5 Salgaocar should only be 3 - Strait north of 390 Crossing right? BCTrader let's say 380 08:11:3 2 -Big but won't get 9 Client there

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Column 1: Column 2: Bloomberg chat between Big Client Trading Instructions from Jack New (Ketan Parekh) trader and Rohit Salgaocar on on WhatsApp group Jack-Saro November 11, 2022

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Column 1: Column 2: Bloomberg chat between Big Client Trading Instructions from Jack New (Ketan Parekh) trader and Rohit Salgaocar on on WhatsApp group Jack-Saro November 11, 2022

128. From Column 1 and 2 in table above, it is seen that: i before market hours, Rohit Salgaocar and trader of the Big Client were discussing about Policy Bazar and trader of the Big Client confirmed to Rohit Salgaocar that they would sell Policy Bazar that day. Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others ii from 9:00 am to 9:58 am, Ketan Parekh gave multiple instructions to sell scrip of Policy Bazar at various price in the WhatsApp group “Jack-Saro”.

129. In view of the above, cumulative selling of 5,00,000 shares done in the account of FR2 can be correlated with the impending order of the Big Client since Rohit Salgaocar knew about the quantum of shares which the Big Client wanted to sell and accordingly passed this information to Ketan Parekh who then instructed FRs to take position in the market. The further flow of NPI is as under: Table no. 41 Instructions with respect to the positions taken by the FR2 and Big Client Column 1: Column 2: Column 3: Bloomberg chat between Big Bloomberg chat between Rohit Trading Instructions from Jack New Client trader and Rohit Salgaocar Salgaocar and the trader of (Ketan Parekh) on WhatsApp group on November 11, 2022 Nuvama on November 11, 2022 Jack-Saro Time From Message Time From Message Rohit Trader 09:52:3 Salgaocar - 10:02: of 750k? Completed 7 Strait 21 Nuvama Crossing Wealth Rohit POLICYBZ: Trader 09:52:5 Salgaocar - POLICY Sold 1.75 10:03: of 4 Strait BZ mln @ 19 Nuvama Crossing 382.00 on Wealth NSE 10:01:0 BCTrader2 - 382 or 0 Big Client better Rohit 10:01:0 Salgaocar - 382. For 2 Strait 1.75 Crossing 10:01:0 BCTrader2 -done 9 Big Client

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Column 1: Column 2: Column 3: Bloomberg chat between Big Bloomberg chat between Rohit Trading Instructions from Jack New Client trader and Rohit Salgaocar Salgaocar and the trader of (Ketan Parekh) on WhatsApp group on November 11, 2022 Nuvama on November 11, 2022 Jack-Saro Rohit 10:01:1 Salgaocar - Nuvama 4 Strait pls Crossing

10:01:4 BCTrader2 -sent 9 Big Client

130. From the aforesaid table, it is seen that: i (Column 1) At around 9:52 am, Rohit Salgaocar, continuing with his earlier chat with the trader of the Big Client, discussed the price and quantity of shares of PolicyBazaar which were to be sold. The Big Client agreed to sell 17.5 lakhs shares in PolicyBazaar at the rate of INR 382 per share. Thereafter, Rohit Salgaocar asked the trader of the Big Client to send deal ticket to the Nuvama. ii (Column 3) At around 10:01 am, Ketan Parekh, simultaneously instructed to buy Policy Bazar at INR 382 in the group “Jack-Saro”, to which Sam (mobile phone kept in the office of FR2) confirmed buying of 5 lakh shares of Policy Bazar. The same can be correlated with the buy trade of 5 lakh shares in the account of FR2.

iii (Column 2) Between 10:02:21 and 10:03:19 am, Nuvama’s trader informed Rohit Salgaocar about completion of sell order received from the Big Client trader i.e., total 17.5 lakh shares of Policy Bazar sold at INR 382.00 on NSE. Further, as can be seen in table above, the instructions across 3 different chat windows were time coordinated.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

131. In respect of the quantity and price at which the Big Client was to sell Policy Bazar, the following is noted:

i In the morning itself, the trader of the Big Client had given the price range to Rohit Salgaocar. Further, owing to Rohit Salgaocar’s vast experience of dealing with the Big Client, he had a fair idea about the size of the trades which the Big Client executed.

ii This becomes all the more evident, given that on November 11, 2022 the volume in the Policy Bazar jumped by almost 5891% (5.09 Cr) in comparison to its 30-day average volume (8.5 lakhs). The Big Clients, FR1, FR2 and FR3 contributed around 79.30 lakhs to this volume, which is roughly 930% of the average daily trading volume of last 30 days.

iii Further, it is seen that the 1st instance of matching happened at around 10:02:16 am, and the total volume contributed by the Big Client and FR2 till that time was around 22.50 lakhs, which is 32.42% of their total volume on the day.

132. In view of the aforesaid illustrations, it is seen that: i The chats in the tables above and the timing of flow of information between various entities, prima facie establishes that the information of the forthcoming sell order of AXXXP Fund in the scrip of Policy Bazar reached to Ketan Parekh in a perfectly time-coordinated manner.

ii As Rohit Salgaocar received the instructions from trader of the Big Client about selling Policy Bazar that day, the same was communicated to Ketan Parekh, who in turn instructed FR2 to sell shares of Policy Bazar Limited. Thereafter, just when the Big Client ordered to sell the shares of Policy

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Bazar Limited, Ketan Parekh immediately instructed FR2 to place buy order, which matched with the sell order of the Big Client.

133. The trades in the second time patch, showing matching of trades of FR1, FR2 and FR3 with that of the Big Client are illustrated and explained below: Table no. 42 Trades undertaken by the FR1, FR2, FR3 and Big Client Part Bu Cou Order Order Order Trade Trade Sum of Average Mat icul y/ nt of Start End Limit Start End Trade Trade Price ch ars Sel Ord Time Time Price Time Time Qty Range (in INR) Vol. l ers Range FR1 Sell 17 10:04:56 10:54: 383.9- 10:04: 11:05: 5,58,53 384.00-386.05 - 22 385.6 56 19 1 (384.88) FR1 Buy 5 10:17:45 11:10: 382.5- 10:17: 11:10: 1,32,50 382.50-385.00 - 12 385.1 45 12 0 (384.23) FR2 Buy 5 10:22:04 10:23: 383.5- 10:22: 10:29: 25,000 383.50-384.50 - 26 384.5 05 46 (384.00) FR2 Sell 13 10:03:55 11:10: 384-386 10:04: 11:15: 6,05,86 384.00-386.00 - 22 36 52 9 (384.75) FR3 Sell 2 11:09:51 11:10: 384.5 11:09: 11:15: 1,50,00 384.50 - 08 51 09 0 Big Sell 11 11:14:32 11:16: 384.5 11:15: 11:18: 25,00,0 384.50 Clie 27 09 26 00 nt FR1 Buy 5 11:15:54 11:16: 384.5 11:15: 11:16: 4,08,53 384.50 4,08 20 54 20 1 ,529 FR2 Buy 7 11:15:39 11:16: 384.50 11:15: 11:16: 5,80,86 384.50 5,79 13 39 13 9 ,001

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Part Bu Cou Order Order Order Trade Trade Sum of Average Mat icul y/ nt of Start End Limit Start End Trade Trade Price ch ars Sel Ord Time Time Price Time Time Qty Range (in INR) Vol. l ers Range FR3 Buy 2 11:15:51 11:16: 384.50 11:15: 11:16: 1,30,00 384.50 1,29 42 51 42 0 ,998

134. From the table above, it is seen that: i FR2 placed 13 sell orders between 10:03:55 to 11:10:22 in which 6,05,869 shares got executed at an average price of INR 384.75.FR2 also placed 5 buy orders between 10:22:04 to 10:23:26 in which 25,000 shares got executed at an average price of INR 384.00.

ii Similarly, FR1 placed 17 sell orders between 10:04:56 to 10:54:22 in which 5,58,531 shares were executed at an average price of INR 384.88. FR1 also placed 5 buy orders between 10:17:45 to 11:10:12 in which 1,32,500 shares were executed at an average price of INR 384.23.

iii FR3 also placed 2 sell orders between 11:09:51 to 11:10:08 in which 1,50,000 shares were executed at an average price of INR 384.50.

iv Subsequently, Big Client placed 11 sell orders for a cumulative quantity of 25,00,000 shares during the period between 11:14:32 – 11:16:27. The same got executed at an average price of INR 384.50.

v At that time FR1, FR2 and FR3 placed 5, 7 and 2 buy orders, respectively, for a cumulative quantity of 11,19,400 shares, between 11:15:39 – 11:16:42, and 11,19,400 shares got executed at an average price of INR 384.50, of which 11,17,528 shares matched with the Big Client order i.e., 99.83% of the total shares bought by FRs.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

135. While the trades executed by the Big Client and the FRs have been exhibited above, the manner in which the instructions in respect of the aforesaid trades were passed between various entities are shown below.

Table no. 43 Instructions with respect to the positions taken by the FR2 and Big Client, when matching took place Column 1: Column 2: Column 3: Bloomberg chat between Big Bloomberg chat between Rohit Trading Instructions from 955A/Jack Client trader and Rohit Salgaocar Salgaocar and the trader of New (Ketan Parekh) on WhatsApp on November 11, 2022 Nuvama on November 11, 2022 Messag Time From Message Time From e Trader of Received going to Nuvama POLICYB 10:01:5 BCTrader2 - eat 11:10:49 Wealth Z 2 Big Client lunch Trader of now Nuvama 11:11:08 Wealth 384.50 Rohit Rohit 10:01:5 Salgaocar - 11:11:12 Salgaocar Call me 9 Strait Trader of Crossing thanks Nuvama Rohit 11:11:34 Wealth yes 10:02:0 Salgaocar - Trader of 3 Strait Keep Nuvama complete Crossing looking 11:18:33 Wealth d 11:21:26 Trader of Rohit Nuvama POLICYB 10:02:0 Salgaocar - Wealth Z: Sold @ 7 Strait 384.50 on Crossing ? BSE 10:01:0 BCTrader2 - 9 Big Client not now

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Column 1: Column 2: Column 3: Bloomberg chat between Big Bloomberg chat between Rohit Trading Instructions from 955A/Jack Client trader and Rohit Salgaocar Salgaocar and the trader of New (Ketan Parekh) on WhatsApp on November 11, 2022 Nuvama on November 11, 2022 10:02:1 BCTrader2 -eating 3 Big Client Rohit Buyer 10:47:4 Salgaocar - for 9 Strait 2.5mn Crossing at 384 back. counter 11:06:5 BCTrader2 - 384.50 4 Big Client for 2.5mn Rohit 11:07:1 Salgaocar - 9 Strait One Crossing min Rohit 11:09:1 Salgaocar - 1 Strait Crossing 384.50? Rohit 11:09:1 Salgaocar - 4 Strait Crossing 2.5mn Rohit 11:10:0 Salgaocar - 2 Strait rang the Crossing bell

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Column 1: Column 2: Column 3: Bloomberg chat between Big Bloomberg chat between Rohit Trading Instructions from 955A/Jack Client trader and Rohit Salgaocar Salgaocar and the trader of New (Ketan Parekh) on WhatsApp on November 11, 2022 Nuvama on November 11, 2022 11:10:1 BCTrader2 - yes 5 Big Client done Rohit 11:10:1 Salgaocar - 8 Strait Crossing thanks Rohit 11:12:1 Salgaocar - 3 Strait Crossing nuvama Rohit 11:12:1 Salgaocar - 9 Strait I will do Crossing on bse so you want me to 11:13:1 send all 8 to BCTrader2 - Nuvam Big Client a?

Rohit 11:13:2 Salgaocar - 2 Strait Crossing Yes pls 11:13:3 BCTrader2 - 3 Big Client sent

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Column 1: Column 2: Column 3: Bloomberg chat between Big Bloomberg chat between Rohit Trading Instructions from 955A/Jack Client trader and Rohit Salgaocar Salgaocar and the trader of New (Ketan Parekh) on WhatsApp on November 11, 2022 Nuvama on November 11, 2022 Rohit 11:14:4 Salgaocar - 4 Strait Crossing thx

136. From the aforesaid table, it is seen that: i (Column 1) At around 10:01 am, Rohit Salgaocar continued with his earlier chat with the trader of the Big Client, in respect of the sell trade in Policy Bazar, wherein the price, quantity and the Exchange (in this case BSE) on which the trade was to be executed was agreed upon. Subsequently, Rohit Salgaocar asked the Big Client trader to send the deal ticket to the Nuvama.

ii (Column 2) At around 11:10 am, the trader of Nuvama informed Rohit Salgaocar that deal ticket is received from the Big Client. Subsequently, Rohit Salgaocar instructed Nuvama’s trader to call him. Afterwards, Nuvama’s trader provided confirmation to Rohit of order completion.

iii (Column 3) Between 10:03 am and 11:10 am Ketan Parekh gave multiple instructions to sell Policy Bazar at various prices in the group “Jack-Saro”. This can be correlated with the buy and sell trades done in the account of FR2. At 11:10 am, it can also be observed from the chat that Ketan Parekh told FR2 to be ready to buy Policy Bazar and to cover the shares sold on BSE. At 11:16 am, FR2 confirmed that the buy order for 5,80,869 shares had been executed on BSE out of which, 5,79,001 trades matched with the Big Client.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others iv FR1 and FR 3 had also created net short position, by selling shares in cash segment, in Policy Bazar and most of this short position created by FR1 and FR3 had also been squared off by them and matched with the Big Client in the aforesaid time patch. By doing this, both FR1 and FR 3 had matched 4,08,529 and 1,29,998 trades with the Big Client, respectively.

137. In respect of the quantity and price at which Big Client was to buy Policy Bazar, it is seen that: i In respect of the quantity and price at which Big Client was to sell Policy Bazar, as explained above, Rohit Salgaocar, owing to his vast experience of dealing with the Big Client and his insights in respect of the impact of the Big Client orders on the existing demand and supply in the market, had a fair idea about the size and the price at which the trades of the Big Client could be executed.

ii This gets supported by the fact that on November 11, 2022 the volume in the Policy Bazar jumped by almost 5891% (5.09 Cr) in comparison to its 30-day average volume (8.5 lakhs). The Big Clients, FR1, FR2 and FR3 contributed around 79.12 lakhs to this volume, which is roughly 930% of the average daily trading volume of last 30 days.

iii Further, it is seen that the Exchange at which the trade is going to be executed was communicated to the FRs so that the net short position created gets squared off with the intended Big Client. It is to be noted that the short position created by the FRs, would not have otherwise been created.

138. In view of the aforesaid illustration, it is seen that: i The chats in the aforesaid table and the timing of flow of information between various entities, prima facie establishes that the information of the Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others forthcoming sell order of the Big Client in the scrip of Policy Bazar reached to Ketan Parekh in a perfectly time-coordinated manner.

ii As Rohit Salgaocar received the instructions from traders of the Big Client about the impending trades of the Big Client on that day, the same was communicated to Ketan Parekh, who in turn instructed Sanjay Taparia (who had access to account of FR1 and FR3)8 and FR2, to sell shares of Policy Bazar. Thereafter, just when the Big Client ordered to sell the shares of Policy Bazar, Ketan Parekh immediately instructed Sanjay Taparia and FR2, to place buy order, which matched with the buy order of the Big Client.

iii This process of matching the Buy orders of the Big Client with the sell orders of FRs happened 3 times in the day, where trades were placed through the account of FR1, FR2 and FR3.

iv Thus, armed with the knowledge of the impending buy orders of the Big Client, Ketan Parekh got trades of such large quantity executed in the accounts of FR1, FR2 and FR3, which otherwise they would not have undertaken. This resulted in a match of 39.26% of the sell quantity of the Big Client in the aforesaid time patches and a total square off profit of INR 18,55,650 for FR1, FR2 and FR3 as calculated in the table below:

Table no. 44 Calculation of unlawful gains made under this illustration Average Average FR Buy Qty Buy Value Buy Price Sell Qty Sell Value Sell Price Profit FR1 8,18,693 31,63,02,063 386.35 8,16,693 31,57,69,389 386.64 2,40,026.05

FR2 16,90,964 65,15,38,290 385.31 16,90,964 65,30,00,219 386.17 14,61,929.00

8 Connection of Sanjay Taparia and FR3 is discussed at paragraph 45 and 46. Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Average Average FR Buy Qty Buy Value Buy Price Sell Qty Sell Value Sell Price Profit FR3 1,70,000 6,52,81,269 384.01 1,55,000 5,96,74,852 385.00 1,53,694.97 Total Profit made by the FRs 18,55,650

G.4 Illustration of NPI-based trades by FR 2 and FR5 in the scrip of Cholamandalam Investment and Finance Company Limited (CHOLAFIN / 511243) on January 09, 2023

139. On analysis of the trade logs, it is observed that FR2 and FR5 have undertaken NPI-based trades against the orders of AXXXP Fund, one of the funds of the Big Client, making an overall profit of INR 70,63,705.40.

140. It is observed that during the day, the Big Client sold around 9 lakh shares of Cholamandalam Investment and Finance Company Limited (hereinafter “CIFC” or “Chola”). FR2 and FR5 matched their buy orders with the sell orders of the Big Client, matching the sell order of the Big Client with a quantity of 4,60,085.

141. The trades undertaken by FR2, FR5 and Big Client prior to matching and during matching of the orders are illustrated and explained below: Table no. 45 Trades undertaken by the FR2, FR5 and Big Client Parti Buy Count Order Order Trade Trade Sum of Average Trade Matc cular / of Start End Start End Trade Price Range (in h s Sell Orders Time Time Time Time Qty INR) Vol. 09:03:1 09:17:1 09:07:1 09:19:2 660.00-667.00 4 80,310 - FR5 Sell 3 1 9 0 (661.21) Big 09:19:3 09:19:3 09:19:3 09:21:5 660.00 - 660.60 7 9,00,000 - Clien Sell 7 7 7 1 (660.00) t Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Parti Buy Count Order Order Trade Trade Sum of Average Trade Matc cular / of Start End Start End Trade Price Range (in h s Sell Orders Time Time Time Time Qty INR) Vol. 09:20:2 09:20:3 09:20:2 09:20:3 660.00 - 660.00 1,47, 3 1,50,000 FR2 Buy 7 2 7 2 (660.00) 946 09:19:4 09:20:5 09:19:4 09:20:5 659.85 - 660.00 3,12, FR5 Buy 4 3,12,810 0 0 0 0 (660.00) 139 09:38:3 09:38:3 09:58:5 675.95-682.60 FR5 Sell 19 9:58:43 2,32,500 - 7 7 4 (678.77) 13:54:3 14:29:3 13:54:3 14:30:1 676.00 - 679.00 FR2 Sell 39 1,50,000 - 4 1 4 4 (677.34)

142. From the table above, it is seen that: i Big Client placed 7 sell orders at 09:19:37. The same got executed at an average price of INR 660.00. It is noted that FR5 placed 4 sell orders by 09:19:20 am, i.e. before Big Client entered the market, in which 80,310 shares were executed. The price decreased from around INR 667.90 to INR 660.06 during this period owing to large sell orders placed by FR5.

ii FR2 placed 3 buy orders between 09:20:27-09:20:32, in which 1,50,000 shares got executed at an average price of 660, of which 1,47,946 shares matched with the Big Client order i.e., 98.63% of the total shares bought by FR2. Further, FR5 placed 4 buy orders between 09:19:40-09:20:50 in which 3,12,810 shares, got executed at an average price of 660, of which 3,12,139 shares matched with the Big Client order i.e., 99.78% of the total shares bought by FR5. Thus, FR2 and FR5 cumulatively bought 4,60,085 shares from the Big Client which means they matched 51.12% of the Big Client order.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others iii Afterwards, during the period between 13:54:34 to 14:29:31, FR2 placed 39 Sell orders in which 1,50,000 shares got executed at an average price of INR 677.34. FR5 placed 19 sell orders between 09:38:37 to 09:58:43 in which 2,32,500 shares got executed at an average price of INR 678.77. Thus, it is seen that based on the NPI-based trading instructions, FRs were making unlawful gains from trades which were executed after matching with the Big Client also.

143. The discussion between Rohit Salgaocar and the trader of Big Client about CIFC started on the previous working day i.e. January 06, 2023, where also NPI-based trades were executed by FR5. The relevant extracts of the Bloomberg chats between Rohit Salgaocar and the trader of Big Client on January 06, 2023 are shown below:

Table no. 46 Bloomberg chats between Rohit Salgaocar and the trader of Big Client on January 06, 2023 Time From Message 09:07:48 BCTrader2 - Big Client can also sell CIFC 09:30:03 Rohit Salgaocar - Strait Crossing 200k CIFC? 09:30:59 BCTrader2 -Big Client mkt 680 or better yes 09:31:28 Rohit Salgaocar - Strait Crossing 681 09:31:31 Rohit Salgaocar - Strait Crossing Done 09:36:45 Rohit Salgaocar - Strait Crossing Continue to look 680 ob? 10:53:56 BCTrader2 -Big Client would stll do mkt here 10:54:19 Rohit Salgaocar - Strait Crossing Will look

144. As can be seen from table above, on January 06, 2023, BCTrader2 told Rohit that he wanted to sell CIFC. Thereafter, during the day Rohit Salgaocar did a trade of 200K shares in CIFC for Big Client. Thereafter, the trader of Big Client confirmed that he was still interested in selling CIFC indicating that he had more quantity which could be sold, to which Rohit Salgaocar replied that he would look. Hence, it is seen

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others that Rohit Salgaocar, owing to his vast experience of dealing with the Big Client, had a fair idea about the size of the trades that the Big Client was looking to execute.

145. While, the trades executed by the Big Client, FR2 and FR5 have been exhibited in Table no. 45, the manner in which the instructions in respect of the aforesaid trades were passed between various entities are shown below.

Table no. 47 Instruction with respect to the positions to be taken in the scrip on January 09, 2023 Column 1: Column 2: Bloomberg chat between Big Client Trading Instructions from Jack New (Ketan Parekh) on trader and Rohit Salgaocar on WhatsApp group Jack-Saro January 9, 2022 Time From Message Hi BCTrader2 08:20:45 Rohit Good Salgaocar - Morning. Just Strait checking if Crossing back to look for blocks in CIFC and levels please? MAXHEALTH at 430 ob PLM 980 ob and RLXF at 970 ob thanks BCTrader2 morning 08:23:23 (Big Client) Rohit. all good. cifc 650 and better

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

146. From Column 1 and 2 in table above, it is seen that: i At around 8:23 am on January 09, 2023, trader of the Big Client indicated to Rohit Salgaocar that he was interested in Chola (CIFC) with a price range of “650 and better”; ii At around 09.08 am, Ketan Parekh simultaneously communicated in the WhatsApp group “Jack-Saro” that Chola (CIFC) cash would be selling on that day.

147. The further flow of the aforesaid NPI from Ketan Parekh to FRs is depicted in the table below: Table no. 48 Instructions with respect to the positions taken by the FR2 and Big Client Column 1: Column 2: Column 3: Bloomberg chat between Big Bloomberg chat between Rohit Trading Instructions from Jack New Client trader and Rohit Salgaocar Salgaocar and the trader of (Ketan Parekh) on WhatsApp group on January 09, 2023 Nuvama on January 09, 2023 Jack-Saro Time From Message 09:16:41 Rohit 1mn you Time From Message Salgaocar - care 09:1 Trader of Recd Order Strait CIFC? 9:24 Nuvama to sell CIFC Crossing 09:1 Trader of 900k @ 660 09:16:47 Rohit Rang the 9:27 Nuvama Salgaocar - bell Strait 09:1 Trader of Ready Crossing 9:30 Nuvama BCTrader2 Looking 09:1 Rohit 09:17:03 (Big Client) Go in 9:34 Salgaocar BCTrader2 Yes 09:17:21 (Big Client) 09:1 Trader of 09:17:35 Rohit 660 Can I 9:36 Nuvama Ok Salgaocar - show? 09:1 Trader of 83k Strait 9:43 Nuvama Crossing

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Column 1: Column 2: Column 3: Bloomberg chat between Big Bloomberg chat between Rohit Trading Instructions from Jack New Client trader and Rohit Salgaocar Salgaocar and the trader of (Ketan Parekh) on WhatsApp group on January 09, 2023 Nuvama on January 09, 2023 Jack-Saro 09:17:39 BCTrader2 Yes 09:1 Trader of 135k (Big Client) 9:48 Nuvama 09:17:41 BCTrader2 and that 09:2 Trader of 390k (Big Client) would be it 0:35 Nuvama 09:17:55 BCTrader2 as in no (Big Client) more after 09:2 Trader of 633k 09:17:55 Rohit That's 0:49 Nuvama Salgaocar - done, 09:2 Trader of 775k Strait 1:23 Nuvama Crossing 09:18:06 Rohit U want to 09:2 Trader of 867k Salgaocar - keep back 1:43 Nuvama Strait some? 09:2 Trader of completed Crossing 1:55 Nuvama 09:18:14 BCTrader2 i hav 112k 09:2 Trader of CIFC:Sold (Big Client) left. will 3:34 Nuvama 900k @ 660 keep 09:18:20 BCTrader2 nuvama? (Big Client) 09:18:22 Rohit Shud I do Salgaocar - 900 ? Strait Crossing 09:18:43 BCTrader2 you think (Big Client) that's better? 09:18:45 Rohit Yes Salgaocar - nuvama Strait Crossing 09:18:53 BCTrader2 worried it (Big Client) will not Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Column 1: Column 2: Column 3: Bloomberg chat between Big Bloomberg chat between Rohit Trading Instructions from Jack New Client trader and Rohit Salgaocar Salgaocar and the trader of (Ketan Parekh) on WhatsApp group on January 09, 2023 Nuvama on January 09, 2023 Jack-Saro trade so much today 09:19:00 BCTrader2 ok 900 (Big Client) 09:19:11 Rohit 900k is Salgaocar - odne 660 Strait Crossing

148. From columns 1, 2 and 3 in the table above, it is seen that: i at around 9:19 am, Rohit Salgaocar got a confirmation from the trader of the Big Client about the sell order of 900,000 shares in CIFC and the deal ticket is sent to Nuvama.

ii at around 9:19 am, Nuvama’s trader informed Rohit Salgaocar about receipt of CIFC sell order from the Big Client and thereafter, Rohit Salgaocar instructed Nuvama’s trader to place the order. Afterwards, Nuvama’s trader provided Rohit with continuous updates about the status of execution of the order and in the end confirms order completion at around 9:22 am.

iii at around 9:19-9:20 am, Ketan Parekh, in the group “Jack-Saro”, instructed to sell Chola at 664 and cover Chola at 660. To this Sam (mobile kept in the office of FR2) confirmed buying 1.5 lakh Chola at INR 660 and pending sell order of 1 lakh at INR 664. However, immediately afterwards Ketan Parekh instructed in the group to remove selling i.e. to delete the pending sell order in the scrip Chola, which had just been placed.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others iv at around 1:51 pm, Ketan Parekh in the group “Jack-Saro”, instructed to reverse the existing positions in Cash and Futures of Chola and Sam (mobile kept in the office of FR2) reversed both the positions and confirmed about the same in the group. The trade reversed in the cash market can be correlated with the cumulative sell of 1.5 lakh shares of Chola, in the account of FR2.

v In respect of the quantity and price at which the Big Client was looking to sell CIFL, the trader of the Big Client had given the price range to Rohit Salgaocar in the morning itself. Further, as stated above, the discussion about CIFL has been continued from previous working day i.e. January 06, 2023, wherein the trader of the Big Client had indicated that he has more quantity which can be sold. Given that Rohit Salgaocar had vast experience of dealing with the Big Client, it can be said that he had a fair idea about the size of the trades that the Big Client was looking to execute.

vi Further, on January 09, 2023, the volume in the CIFL jumped by almost 3 times (39.66 lakhs) in comparison to its 30-day average volume (13.36 lakhs). The Big Client, FR2 and FR5 contributed around 13.63 lakhs to this volume, which is roughly 102% of the average daily trading volume of last 30 days. Further, it is seen that the instance of matching happened at around 9:19-9:20 am, and the total volume contributed by the Big Client, FR2 and FR5 till that time was around 13.63 lakhs, which is 100% of their volume on the day.

149. In view of the aforesaid illustration, it is seen that: i The chats in the tables above and the timing of flow of NPI amongst various entities prima facie establishes that the information of the forthcoming sell

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others order of AXXXP Fund in the scrip of CIFL reached to Ketan Parekh in a perfectly time-coordinated manner.

ii As Rohit Salgaocar received the instructions from trader of the Big Client about selling CIFL that day, the same was communicated to Ketan Parekh, who in turn instructed about the same to FR2. Thereafter, just when the Big Client ordered to sell the shares of CIFL, Ketan Parekh immediately instructed FR2 to place buy order, which matched with the sell order of the Big Client.

iii This process of matching the sell order of the Big Client with the buy orders of FRs happened at around 9:19-9:20 am, where trades were placed through the account of FR2 and FR5.

iv Thus, armed with the knowledge of the impending sell orders of the Big Client, Ketan Parekh got trades of such large quantity executed in the accounts of FR2 and FR59, which otherwise they would not have undertaken. This resulted in a match of 51.12% of the sell quantity of the Big Client and a total square off profit of INR 70,63,705.40 for FR2 and FR5 as calculated in the table below: Table no. 49 Calculation of unlawful gains made under this illustration Average Average FR Buy Qty Buy Value Buy Price Sell Qty Sell Value Sell Price Profit FR2 1,50,000 9,90,00,000 660.00 1,50,000 10,16,01,369 677.34 26,01,369.20 FR5 3,12,810 20,64,54,594 660.00 3,12,810 21,09,16,930 674.27 44,62,336.20 Total Profit made by the FRs 70,63,705.40

9 Flow of NPI from Ketan Parekh to FR5 is discussed in Part D.5 of this order. Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

G.5 Illustration of NPI-based trades by FR 2 and FR6 in the scrip of Tube Investments of India Limited (TIINDIA/540762) on May 18, 2022

150. Upon analysis of the trade logs, it is observed that FR2 and FR6 have undertaken NPI-based trades against the orders of AXXXP Fund, one of the funds of the Big Client, making an overall profit of INR 7,53,405.65.

151. It was observed that during the day FR2 and FR6 matched their buy orders with the sell orders of AXXXP Fund in two time patches. During the aforesaid patches, the Big Client sold around 2.25 lakh shares of Tube Investments of India Limited out of which FRs matched 2,23,150 shares.

152. The trades undertaken by the FR2, FR6 and the Big Client in time period prior to matching and during matching of orders are illustrated and explained below:

Table no. 50 Trades undertaken by the FR2, FR6 and Big Client during aforesaid Patch Partic Buy/ Co Order Order Trade Trade Sum of Average Match ulars Sell unt Start End Time Start End Time Trade Trade Vol. of Time Time Qty Price Ord Range (in ers INR) 1666.00- FR2 Sell 29 09:15:00 09:31:20 09:15:00 09:32:24 1,50,000 1681.30 - (1669.45) 1670.00- FR6 Sell 1 09:33:12 09:33:12 09:33:12 09:33:12 3367 1674.50 - (1670.33) Big Sell 4 09:35:31 09:36:13 09:35:56 09:36:36 2,00,000 1666.00 Client

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Partic Buy/ Co Order Order Trade Trade Sum of Average Match ulars Sell unt Start End Time Start End Time Trade Trade Vol. of Time Time Qty Price Ord Range (in ers INR) 1661.95- FR2 Buy 4 09:36:05 09:36:11 09:36:05 09:36:11 1,65,000 1666.00 1,64,600 (1666.00) 1662.15- FR6 Buy 1 09:35:56 09:35:56 09:35:56 09:35:56 35,000 1666.00 34,628 (1665.99) 1667.00- FR2 Sell 1 09:37:41 09:38:01 09:37:41 09:40:17 15,000 1668.05 (1667.00) 1669.00- FR6 Sell 20 09:41:57 14:46:28 09:48:30 14:51:10 51,360 1674.00 (1670.90) 1669.00- Big Sell 1 14:51:29 14:51:29 14:51:29 14:51:48 25,000 1669.50 Client (1669.00) 1668.00- FR6 Buy 2 14:45:06 14:51:48 14:45:16 14:51:48 26,153 1669.00 23,922 (1668.91) 1669.80- FR6 Sell 3 14:52:54 15:25:24 14:53:30 15:25:24 6,426 1671.00 (1670.68)

153. From the table above, it is seen that: i between 9:15 am and 9:31 am, FR2 had placed 29 sell orders wherein a quantity of 1,50,000 shares was executed at an average price of INR 1,669.45. It is noted that the price of the scrip has decreased from INR 1,692.90 (previous day close price) to INR 1,666.00 till the time trade with the Big Client had matched. At 9:33 am, FR6 also placed sell order which got executed for 3367 shares at an average price of INR 1670.33.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others ii between 9:35 am and 9:36 am, the Big Client placed 4 sell orders wherein 2,00,000 shares got executed at an average price of INR 1,666.00.

iii at around 9:36 am, FR2 and FR6 also placed buy orders wherein for 1,65,000 shares and 35,000 shares, respectively got executed and a total of 1,99,228 shares got matched with the Big Client order i.e., 99.61% of the total shares sold by the Big Client.

iv at around 9:37 am, FR2 placed 1 sell order wherein 15,000 shares got executed at an average price of INR 1667.00. Subsequently FR6 sold 51,360 shares at an average price of INR 1670.90 which got executed between 9:48 am and 2:51 pm.

v at around 2:51 pm, FR6 again matched trade with the Big Client in another time-patch. Further, it was seen that FR6 squared off its entire position during the day.

154. While the trades executed by the Big Client, FR2 and FR6 have been exhibited above, the manner in which the instructions in respect of the aforesaid trades were passed from Big Client to FR2 are shown below:

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Table no. 51 Instruction with respect to positions taken by the FR2, prior to entry of the Big Client Column 1: Column 2: Bloomberg chat between Big Client Trading Instructions from Jack New (Ketan Parekh) on trader and Rohit Salgaocar on May 18, WhatsApp group Jack-Saro 2022 Time From Message 09:07:04 BCTrader4- Big Im trying to Client sell some TIINDIA. Know any recent buyers? 09:08:43 Rohit I will check Salgaocar - with the last Strait Crossing few buyers, and be back asap 09:08:51 BCTrader4 - ty Big Client

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Column 1: Column 2: Bloomberg chat between Big Client Trading Instructions from Jack New (Ketan Parekh) on trader and Rohit Salgaocar on May 18, WhatsApp group Jack-Saro 2022

155. From Column 1 and 2 in table above, it is seen that: i at around 09:07 am the Big Client trader told Rohit Salgaocar that they would sell TIINDIA. ii from 9:11 am onwards Ketan Parekh gave multiple sell instructions for TIINDIA. During the course of these instructions, Sam (mobile phone kept in the office of FR2), provided updates about the orders placed. At 9:32 am, Sam confirmed that 1.5 lakh TIINDIA is sold and no more margin left for placing further trades.

156. The further flow of the aforesaid NPI-based trading instructions from Ketan Parekh to FR2 is depicted in the table below:

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Table no. 52 Instructions with respect to the positions taken by the FR2, FR6 and Big Client, during matching phase Column 1: Column 2: Column 3: Bloomberg chat between Big Client Bloomberg chat between Rohit Trading Instructions from Jack New (Ketan trader and Rohit Salgaocar on May 18, Salgaocar and the trader of Parekh) on WhatsApp group “Jack-Saro” 2022 Nuvama on May 18, 2022 Time From Message Messag 09:31:36 Rohit Salgaocar 125K tiindia Time From e - Strait Crossing ? 09:34:50 Rohit Get 09:33:53 BCTrader4 - Big What px? Salgaoca ready Client r - Strait 200k1666 09:34:04 Rohit Salgaocar Sorry 200k Crossing - Strait Crossing 1866? 09:34:53 Trader of Sure 09:34:12 BCTrader4- Big Yes Nuvama Client 09:35:01 Trader of Ready 09:34:16 Rohit Salgaocar 1666 sorry Nuvama - Strait Crossing 09:35:28 Rohit Go in 09:34:18 BCTrader4- Big Which Salgaoca Client broker? r - Strait 09:34:25 Rohit Salgaocar Edel pls Crossing - Strait Crossing 09:35:30 Trader of ok 09:34:26 BCTrader4- Big 1666 Nuvama Client 09:35:31 Trader of in 09:34:47 BCTrader4- Big Done sent Nuvama Client 09:35:47 Trader of Nil so far 09:34:57 Rohit Salgaocar thanks Nuvama - Strait Crossing 09:36:01 Trader of 34k done 09:35:10 BCTrader4- Big ty Nuvama Client 09:36:11 Trader of 134k Nuvama done 09:36:13 Trader of 184k Nuvama done 09:36:21 Trader of 767 shs Nuvama pending

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Column 1: Column 2: Column 3: Bloomberg chat between Big Client Bloomberg chat between Rohit Trading Instructions from Jack New (Ketan trader and Rohit Salgaocar on May 18, Salgaocar and the trader of Parekh) on WhatsApp group “Jack-Saro” 2022 Nuvama on May 18, 2022 09:37:15 Trader of TIINDIA. Nuvama Sold 200k @ 1666.00 on NSe

157. From columns 1, 2 and 3 in the table above, it is seen that: i At around 9:31am, Rohit Salgaocar continuing with his earlier chat with the trader of the Big Client, offered 2 lakh shares of TIINDIA at INR 1666. Big Client trader agreed to the trade and sought broker name to which Rohit Salgaocar responded “Edelweiss” (now Nuvama).

ii between 9:35 am and 9:37 am, Rohit Salgaocar instructed the trader of Nuvama to get ready for 200 thousand shares for INR 1666 and then instructed Nuvama’s trader to place the TIINDIA order. Afterwards, Nuvama’s trader provided to Rohit, continuous updates about the order and in the end confirmed order completion.

iii at 9:35 am, Ketan Parekh, in the group “Jack-Saro”, instructed to buy 1.65 lakh TIIINDIA at INR 1,666, to which Sam (mobile phone kept in the office of FR2) confirmed that the 1.65 lakh TIINDIA was bought. The trade can be correlated with the cumulative buy of 1.65 lakh shares of TIINDIA, in the account of FR2.

iv The above trade resulted in an excess long quantity of 15,000 shares in the account of FR2. In this respect Ketan Parekh, at 9:37 am instructed to sell, after which Sam (mobile phone kept in the office of FR2) confirmed

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others the buy and sell of 1.65 lakh shares in TIINDIA. The excess 15,000 shares were sold by FR2 at 9:37 am.

v In respect of the quantity and price at which Big Client was to buy TIINIDIA, as explained above, Rohit Salgaocar, owing to his vast experience of dealing with the Big Client and his insights in respect of the impact of the Big Client orders on the existing demand and supply in the market, had a fair idea about the size and the price at which the trades of the Big Client could be executed.

vi This gets supported by the fact that on May 18, 2022, the volume in the TIINIDIA jumped by almost 8.3 times (16.23 lakhs) in comparison to its 30 days’ average volume (1.95 lakhs). The Big Client, FR2 and FR6 contributed around 7.01 lakh shares to this volume, which is roughly 360% of the average daily trading volume of last 30 days.

158. In view of the aforesaid illustration, it is seen that: i The chats in the tables above and the timing of flow of information between various entities, prima facie establishes that the information of the forthcoming sell order of AXXXP Fund in the scrip TIINDIA reached to Ketan Parekh in a perfectly time-coordinated manner.

ii As Rohit Salgaocar received the instructions from the Big Client about selling TIINIDA that day, the same was communicated to Ketan Parekh, who in turn instructed FR2 to sell shares of TIINIDA. Thereafter, just when the Big Client orders to sell the shares of TIINDIA, Ketan Parekh immediately instructed FR2 to place buy order, which matched with the sell order of the Big Client.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others iii Thus, armed with the knowledge of the impending sell orders of the Big Client, Ketan Parekh got trades of such large quantity executed in the account of FR2 and FR610, which otherwise it would not have undertaken. This resulted in a match of 99.18% of the sell quantity of the Big Client in the aforesaid time patches and a total square off profit of INR 7,53,405.65 for FR2 and FR6 as calculated in the table below: Table no. 53 Calculation of unlawful gains made under this illustration Average Average FR Buy Qty Buy Value Buy Price Sell Qty Sell Value Sell Price Profit FR2 1,65,000 27,48,89,667 1,666.00 1,65,000 27,54,22,676 1,669.23 5,33,008.85 FR6 61,153 10,19,56,719 1,667.24 61,153 10,21,77,116 1,670.84 2,20,396.80 Total Profit made by the FRs 7,53,405.65

Conclusion from the aforesaid illustrations 159. From the aforesaid illustrations, it is observed that FRs, either directly or through facilitators, used to build positions in the same scrips ahead of the impending order of the Big Client based on the NPI-based trading instructions received from Ketan Parekh. As and when the substantial impending orders of the Big Client were placed in the market, the FRs took counter positions upon instructions received from Ketan Parekh to match with the position of the Big Client. This would lead to FRs either squaring off of their initial position taken in the scrip or creating excess long or short position in the scrip, which they eventually square off during the day and thus generated huge illegal gains in a short span of time.

160. It is observed that the circumstances in which FRs were receiving instructions from Ketan Parekh and thereafter trading in the securities markets revealed that they were aware that these trading instructions were not genuine and were only possible with 10 Flow of NPI from Ketan Parekh to FR6 is discussed is discussed in Part D.5 of this order. Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others leakage of the substantial impending transactions in such scrips for the following reasons: i Being associated with securities market for a long time, FRs should have known that the precise quantity/price and timing of the trading instruction on a repetitive basis was not possible without access to some non-public information regarding impending trades in the scrips that were being front run; ii The nature of the trading instructions communicated to FRs i.e. to take positions on instant basis and then to square off such trades within the same day to earn huge profits in a short span of time should have raised a doubt in the minds of FRs regarding the sincerity of the trading instructions; iii FRs were sharing profits earned through NPI-based trades with Ketan Parekh in clandestine manner through banking and non-banking channels as explained in Part I of this order; iv The FRs were receiving trading instructions from Ketan Parekh who is widely known for fraudulent activities in the securities markets and is still undergoing criminal proceedings as detailed in Part M of this order and as such there ought to have been suspicion regarding the authenticity of the trading instructions.

161. In view of the above, I am of the view that FRs were fully aware about the nature of fraudulent trading activity being committed through their trading accounts since they were aware that the trading instructions received from Ketan Parekh were based on some non-public information relating to the scrips in which they were executing trades. Further, since large orders placed by FRs were repeatedly matching with the counterparty at the desired price, they ought to have known, given their long association with the securities markets, that the trading instruction received from Ketan Parekh were matching substantial orders of another trader in those scrips. Hence, while executing trading instructions received from Ketan Parekh, FRs were aware that they were in possession of information which was not publically available Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others and there was a high probability that such information was regarding a substantial impending transaction in securities.

162. Further, as illustrated above, these leakages were happening because Rohit Salgaocar was divulging NPI about the impending order of the Big Client in various scrips to Ketan Parekh, for executing the fraudulent scheme. Thus, it resulted in unfair gains to following entities: I. All FRs, in the form of profit made from the NPI-based trades carried out in their trading accounts; and II. Rohit Salgaocar, in the form of undue commission earned from Motilal and Nuvama.

H. CALCULATION OF TOTAL UNLAWFUL GAINS MADE BY NOTICEES FROM TRADING BASED ON NPI AND COMMISSION INCOME OF ROHIT SALGAOCAR 163. From the analysis of the trading activities and price of buy and sell transactions of the FRs, clearly identifiable profit generating trades were found to have been executed on various days during the Investigation Period through which the FRs prima facie generated unlawful gains of INR 38.70 crores as depicted herein below: Table no. 54 Profit earned by FRs during the Investigation Period

Equity Segment Equity Derivative Segment Average Square Average Gross Square off Entit Cale No of Gross Traded Gross off Calend No of Gross Traded earned y ndar instan Value (INR In Traded earned ar instan Traded Value (INR (INR In days ces lakhs) Value (INR (INR In days ces Value (INR In lakhs) lakhs) In lakhs) lakhs) In lakhs) FR1 85 97 4,79,943.93 4,947.88 559.54 26 26 16,954.90 652.11 41.37 FR2 175 218 9,65,519.81 4,428.99 1,241.02 4 4 5,265.12 1,316.28 4.18 FR3 43 46 3,73,959.92 8,129.57 485.63 - - - - - FR4 3 3 20,332.25 6,777.42 17.22 - - - - - Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Equity Segment Equity Derivative Segment Average Square Average Gross Square off Entit Cale No of Gross Traded Gross off Calend No of Gross Traded earned y ndar instan Value (INR In Traded earned ar instan Traded Value (INR (INR In days ces lakhs) Value (INR (INR In days ces Value (INR In lakhs) lakhs) In lakhs) lakhs) In lakhs) FR5 64 81 9,21,048.85 11,370.97 1,029.92 9 10 10,383.89 1,038.39 38.2 FR6 28 35 2,77,931.71 7,940.91 406.9 7 7 8590.58 1,227.23 46.39 Total 3740.23 130.14 Note: This table provides the instances where FRs earned a positive square off difference of INR 1 or more, when day traded (80% squared off), commonly traded with the Big Client and there is matched quantity with either of the FR.

164. Further, from the information provided by TMs, it was found that through trades based on NPI, Rohit Salgaocar has also earned referral fee/commission of INR 8,06,29,054 (around INR 8.06 crore) and INR 19,00,44,520 (around INR 19 crore) from Motilal and Nuvama, respectively. Thus, the total unlawful gain made by Rohit Salgaocar is INR 27.07 crore which was only in respect of the trades of the Big Client referred by SCPL/Rohit Salgaocar.

165. Thus, prima facie, Noticees made cumulative unlawful gains amounting to approximately INR 65.77 crores (INR 38.70 crores by FRs + INR 27.07 crore by Rohit Salgaocar). The individual and joint and several liabilities of Noticees are tabulated in Table no. 64.

I. ILLUSTRATION OF PROFIT SHARING FROM FR TRADES 166. After elaborating the trade details, now I will examine the profit sharing between various Noticees. From analysis of the WhatsApp data available on the devices found during the Search and Seizure operation, statements made by FRs/ facilitators and analysis of the bank statements of various entities, it is gathered that there were Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others numerous fund transfers, both through cash as well as bank transfers, between Ketan Parekh and FRs/ facilitators.

167. Various illustrations of the money transfers between aforesaid entities have been shown below, with the help of the screenshots of WhatsApp chats and extracts of the bank account statements: I. Fund transfers between Ketan Parekh and Sumit Sonthalia: i Cash Transfer of INR 25 lakhs from Ketan Parekh (Jack New) to Sumit Sonthalia, through Angadiya: With respect to this transaction, discussions of Sumit Sonthalia with Ketan Parekh and with mobile number XXX6123307 (saved as Sagar in the phone of Sumit Sonthalia and Kau.New in the mobile of Sanjay Taparia) have been shown below. Table no. 55 Cash transfer of INR 25 lakhs from Ketan Parekh (Jack New) to Sumit Sonthalia Screenshot of chats from the WhatsApp of Chat Date Explanation Sumit Sonthalia with Jack 11/11/2022  Sumit asks Ketan New Parekh for 25 (Ketan lakhs in Mumbai Parekh)

Sagar 12/11/2022  Sumit messages Sagar for 25 lakhs in Mumbai, saying that he had discussed same with Bhai (Ketan Parekh).

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Screenshot of chats from the WhatsApp of Chat Date Explanation Sumit Sonthalia with Sagar 14/11/2022  Sumit asked Sagar about update on fund program.  Sagar says that funds will be transferred tomorrow. Jack 14/11/2022  Sumit also asks New Ketan Parekh for (Ketan the fund program Parekh) and tells that “Kau” (Sagar) has told him that 25 lakhs will be transferred tomorrow.  Ketan Parekh, at 7:06 PM, messages saying that tell Kau that funds are coming tonight and will be transferred tomorrow. Sagar 14/11/2022  Sumit sends same message to Sagar.  Also sends details of Angadiya (unofficial channels) and note, against which payment is to be made.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Screenshot of chats from the WhatsApp of Chat Date Explanation Sumit Sonthalia with Sagar 14/11/2022  Afterwards, Sagar confirms, saying tomorrow morning it shall be done.

ii As seen in the chats above, Sumit Sonthalia was coordinating with Ketan Parekh and Sagar in respect of a cash transfer of INR 25 lakhs. Further, Sumit Sonthalia in one of the chats with Ketan Parekh said that Kau (mobile XXX6123307, saved in the name of Sagar in his phone) had confirmed that transfer would happen tomorrow. In response, Ketan Parekh told Sumit to message Kau that funds were coming tonight and would be transferred tomorrow. Thereafter, Sumit forwarded the same message to Sagar, saying “Bhai told to message”.

iii Thus, mobile number XXX6123307, which is saved as Sagar in the phone of Sumit Sonthalia or Kau New in the phone of Sanjay Taparia, belongs to the same person and the said person works for Ketan Parekh. Further, from the chats it is seen that Sumit Sonthalia received INR 25 lakhs from Ketan Parekh, through Angadiya.

iv Cash Transfer of INR 50 lakhs from Sumit Sonthalia to Ketan Parekh (Jack New), through Angadiya: This transaction involved discussions only with mobile number XXX6123307, saved in the name of Sagar (an associate of Ketan Parekh).

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Table no. 56 Cash transfer of INR 50 lakhs from Sumit Sonthalia to Ketan Parekh (Jack New) Screenshot of chats from the WhatsApp Date Explanation of Sumit Sonthalia 02/12/20  Sagar asks Sumit for 23 funds, saying that Boss (Ketan Parekh) is asking.  Sumit says a token of 50 lakhs will be done in Mumbai

02/12/20  Sagar provides the details 23 of Angadiya and the note, against which payment is to be made.

03/12/20  Sumit, sends the photo of 23 same note to Sagar saying “Paid” i.e. INR 50 lakhs paid to the Angadiya.  Sagar confirms receipt of the same.

v From chats above, it can be seen that Ketan Parekh received INR 50 lakhs from Sumit Sonthalia, through Angadiya.

II. Fund transfers between Ketan Parekh and Sanjay Taparia: i Bank Transfer of INR 65 lakhs from Ketan Parekh (Jack Latest. New) to Sanjay Taparia Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Table no. 57 Bank transfer of INR 65 lakhs from Ketan Parekh (Jack Latest.New) to Sanjay Taparia Screenshot of chats from the WhatsApp of Date Explanation Sanjay Taparia 25/05/202  Sanjay Taparia sends account 3 details to Ketan Parekh (Jack Latest. New), in which funds are to be transferred.

25/05/202  Ketan Parekh confirms that INR 3 65 lakhs is transferred

Extract of Bank Statements 25/05/202  INR 65 lakh was transferred Date Ba Account Nam Debit Credi 3 from the account of Realstone nk Number e (in t Trading Company Private Na INR) (in Limited to the account of me INR) Samriddh Wire Products 25/05/ Uni 51010100 Reals 65,00 Private Limited, as confirmed 2023 on 6630212 tone ,000 by Ketan Parekh. Ba Tradi nk ng of Com pany Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Screenshot of chats from the WhatsApp of Date Explanation Sanjay Taparia Ind Privat ia e Limit ed 25/05/ Axi 91703006 Samri 65,00 2023 s 0547707 ddh ,000 Ba Wire nk Prod ucts Privat e Limit ed ii From the aforesaid table, it can be seen that Ketan Parekh transferred INR 65 lakhs to Sanjay Taparia, from the account of a firm Realstone Trading Company Private Limited (hereinafter referred to as “Realstone”).

iii Cash Transfer of INR 20 lakhs from Ketan Parekh to Sanjay Taparia, through Angadiya: With respect to this transaction, discussions between Sanjay Taparia with Shyam Rajkumar Saraogi, mobile no. XXX0460230 (Shyam Rajkumar Saraogi of Salasar Stock Broking) and Kau New, mobile number XXX6123307 (saved as Sagar in the phone of Sumit Sonthalia) have been shown below.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Table no. 58 Cash transfer of INR 20 lakhs from Ketan Parekh to Sanjay Taparia Screenshot of chats from the WhatsApp of Date Explanation Sanjay Taparia 14/06/2023  Shyam sends details of a person and the photo of note to Sanjay Taparia.

15/06/2023  Sanjay Taparia send the same details to Kau New

16/06/2023  Next day Sanjay Taparia checks with Kau New if 20 lakhs have been transferred.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Screenshot of chats from the WhatsApp of Date Explanation Sanjay Taparia 19/06/2023  On June 19, 2023, Kau New confirms that transfer is done.  Also sends photo of the note and a receipt of Angadiya, depicting details of transfer and the name of person which Shyam told to Sanjay Taparia.

19/06/2023  Sanjay Taparia forwards the same to Shyam.

iv From the table above, it can be seen that on June 14, 2023, Shyam Rajkumar Saraogi sent details of a person and the photo of a 10 rupee note to Sanjay Taparia and thereafter on June 15, 2023, Sanjay Taparia sent the same details to Kau.New (Associate of Ketan Parekh). On June 19, 2023, Kau.New confirmed to Sanjay Taparia that the transfer of money is done and also sent a photo of the note and a receipt of Angadiya, depicting details of transfer (INR 20 lakhs) and the name of person which Shyam Rajkumar Saraogi had informed to Sanjay Taparia on June 14, 2023. Thereafter Sanjay Taparia forwards these details to Shyam Rajkumar Saraogi.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

III. Fund transfers between Ketan Parekh and various entities of Rachit Poddar (director of FR5 and FR6): i From the aforesaid evidence, it is seen that Ketan Parekh had transferred funds to Sanjay Taparia using the account of firm Realstone. On analysis of the bank statement of this account, it is noted that during the investigation period a total of 263 debit and credit transactions have happened between the account of Realstone and bank accounts of various firms of Rachit Poddar. A summary of these transactions is as under: Table no. 59 Fund transfers between Ketan Parekh and various entities of Rachit Poddar Money received Money paid from Name of the account in the account of the account of Account number holder Realstone Realstone (in INR) (in INR) XXX00002635509 28,67,05,000.00 35,53,00,000.00 APR Properties Pvt Limited XXX09836040066 25,86,63,232.00 22,78,16,000.00 Basukinath Properties Pvt XXX72694719 5,65,50,000.00 5,06,00,000.00 Limited R R Food Import LLP XXX00070966191 6,69,10,632.00 17,42,50,000.00 Hello Money Advisors LLP XXX09022357 2,38,70,483.00 - Griebs Commosales XXX09334796 2,38,75,387.00 - Total 71,65,74,734.00 80,79,66,000.00 ii Out of the account holders mentioned in the aforesaid table, NPI-based trades were undertaken using the accounts of APR Properties Private Limited and Basukinath Properties Private Limited, of which Rachit Poddar is a Director. Further, RR Food Import LLP, Hello Money Advisors LLP and Griebs Commosales

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others have only two partners viz. Rachit Poddar and Manju Poddar, aunt of Rachit Poddar.

IV. Relationship between Realstone and Ketan Parekh i On analysis of the bank account statement of the Realstone, it is observed that the highest value of cumulative transfers (both debit as well as credit) and highest number of transactions are observed with an account of a firm called Classic Share and Stock Broking Services Limited. A summary of the transactions between Realstone and Classic Share is shown in the table below. Table no. 60 Summary of the transactions between Realstone and Classic Share Money Money paid Transaction received in the from the count Name of the account Account number account of account of (both debit holder Realstone Realstone and credit) (in INR) (in INR) Classic Share And Stock XXX101005904421 1,02,02,89,859 84,13,78,688 500 Broking Services Limited ii Classic Share and Stock Broking is an entity linked with Ketan Parekh, as one of the Director of Classic Share is Kartik Parekh who is brother of Ketan Parekh. Further, Ketan Parekh and Kartik Parekh are common Directors in 4 companies namely – Triumph Securities Limited, Classic Infin Limited, Panther Investrade Limited and Saimangal Investrade Limited.

iii Thus it can be seen that the account of Realstone was in substance used and controlled by Ketan Parekh.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

V. Summary of bank transfers made between Realstone (front for Ketan Parekh) and bank accounts of various FRs/ facilitators i The table below shows the details of transactions done between the bank account of Realstone Trading and bank accounts of FRs/ facilitators (as gathered from various WhatsApp chats between FRs and Ketan Parekh/his associate and/or the bank account statement of Realstone), during the investigation period. Table no. 61 Summary of bank transfers made between Realstone and bank accounts of various FRs/ facilitators Money Money paid received in Transaction Name of the from the the account count account Account number account of Details of (both debit holder Realstone Realstone and credit) (in INR) (in INR) APR XXX00002635509 28,67,05,000 35,53,00,000 117 Properties XXX09836040066 25,86,63,232 22,78,16,000 94 Pvt Limited Basukinath Rachit Poddar is Director of APR Properties XXX72694719 5,65,50,000 5,06,00,000 14 Properties Private Limited and Pvt Limited Basukinath Properties Private Limited Griebs XXX09334796 2,38,75,387 1 Commosales Rachit Poddar is Partner of Griebs, Hello Money Hello Money, R R Food, along with his Advisors XXX09022357 2,38,70,483 1 aunt, Ms. Manju Poddar. LLP RR Food XXX00070966191 6,69,10,632 17,42,50,000 36 Import LLP Sanghi Steel Rahul Saraf, employee of Sanjay Udyog Pvt XXX033915 8,38,00,000 11,24,00,000 42 Taparia, shared the bank account details Limited with the mobile number XXX6123307 (an Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Money Money paid received in Transaction Name of the from the the account count account Account number account of Details of (both debit holder Realstone Realstone and credit) (in INR) (in INR) associate of Ketan Parekh and which is Askamdar XXX8475000 8,45,00,000 7,97,00,000 27 saved as Kau. New in the phone of Multicap LLP Sanjay Taparia and Sagar in the phone of Sumit Sonthalia)

Jaliyan XXX0200000363 1,26,16,117 1,25,00,000 6 Commodity

Highgrowth Sanjay Taparia shared the bank account Vincom PVT XXX001010230211 30,00,000 2 details with Ketan Parekh. LIMITED

Samriddh Wire XXX030060547707 65,00,000 1 Products Pvt Limited

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Money Money paid received in Transaction Name of the from the the account count account Account number account of Details of (both debit holder Realstone Realstone and credit) (in INR) (in INR) Sanjay Taparia shared the details of bank account details to Kau New, an associate of Ketan Parekh. MVM Commodities XXX40029324 65,00,000 27,84,610 4 Pvt Limited

168. The proof of information sharing between various entities pertaining to the account numbers for transfer of money is show in the table below: Table no. 62 Proof of information sharing between various entities Name of Proof of information sharing the Account account number holder

Sanghi Steel Udyog XXX033915 Pvt Limited

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Askamda r XXX8475000 Multicap LLP

Jaliyan XXX02000003 Commod 63 ity

Highgrowt h Vincom XXX00101023 PVT 0211 LIMITED

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

MVM Commodit XXX40029324 ies Pvt Limited

169. In view of the transactions/details showcased above, it is prima facie established that there were regular cash/bank transactions between Ketan Parekh and various FRs/ facilitators. These transactions are nothing else but profit sharing amongst Noticees.

J. FACT FINDING TO SUPPORT ALLEGATION OF MODUS OPERANDI

170. The elaborate examination of the trading activities carried out in the account of FRs prima facie indicates that orders were placed just ahead of the orders of the Big Client based on the NPI about such impending orders in various scrips. As seen from the extracts of Bloomberg chats produced in different parts of this order, it was Rohit Salgaocar who, while advising traders of the Big Client, was in possession of time-sensitive NPI pertaining to the impending orders of the Big Client in various scrips. He was also instructing traders of Motilal and Nuvama about the execution of the trades of the Big Client and was getting updates from them. Further, it has been admitted in the statements under oath by both Rohit Salgaocar and Ketan Parekh that they used to interact with each other over WhatsApp during the Investigation Period and the same has also been corroborated by the data obtained from IPDR of the mobile numbers of Ketan Parekh. Considering this and in light of the evidence that Ketan Parekh was able to communicate this time-sensitive NPI which was available with Rohit Salgaocar within minutes to the FRs. either directly or through facilitators, leads to an inference that Ketan Parekh was obtaining the time-sensitive NPI from Rohit Salgaocar over WhatsApp. Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

171. In the present case, it has been prima facie noted from the factual details of trading activities carried out in the accounts of the FRs that generally the first leg of order placement was ahead of the order placement of the Big Client; and the second leg (reversal of first trade) of such order was in sync with the order placement of the Big Client. Further, in instances where any excess short or long position was created in the account of FRs while matching with the Big client, the same was also squared off during the day. In the process the aforesaid Noticees were successful in generating quick profits. Such clearly identifiable profit generating trades were found to have been executed on various days during the Investigation Period through which the FRs generated unlawful gains of around INR 38.69 crores as provided in Table no. 54.

172. Further, it is prima facie established from the details of WhatsApp chats and bank statements of various Noticees that Ketan Parekh used to send/receive money both in cash and through bank transfer to/from the facilitators and the FRs. Thus, empowered with the information about the impending orders in various scrips, Noticees unlawfully enriched themselves at the expense of other investors who were not privy to such NPI.

K. EXAMINATION OF LEGAL ISSUES TO DETERMINE IF THERE IS A VIOLATION

173. In the instant matter, it is seen that the mechanism of execution of fraudulent trades by the FRs is a modified form of “front running” since the FRs have applied ingenious strategies to substantially increase their profits as compared to traditional front running. The strategies employed are explained in detail in the ensuing paragraphs.

174. The term “front running” is defined under SEBI’s Circular no. CIR/EFD/1/2012 dated May 25, 2012. While referring to the said definition, and other definitions of front

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others running, the Hon’ble Supreme Court in the matter of in the matter of SEBI Vs. Shri Kanaiyalal Baldevbhai Patel and ors. [(2017) 15 SCC 1] observed as: …17. SEBI has defined front-running in one of its circular (CIR/EFD/1/2012 dated May 25, 2012) in the following manner-

Front-running; for the purpose of this circular, front running means usage of non-public information to directly or indirectly, buy or sell securities or enter into options or futures contracts, in advance of a substantial order, on an impending transaction, in the same or related securities or futures or options contracts, in anticipation that when the information becomes public; the price of such securities or contracts may change.

….

19. In actuality, front-running is more complicated than these definitions suggest. It comprises of at least three forms of conduct. They are: (1) trading by third parties who are tipped on an impending block trade ("tippee" trading); (2) transactions in which the owner or purchaser of the block trade himself engages in the offsetting futures or options transaction as a means of "hedging" against price fluctuations caused by the block transaction ("self-front-running"); and (3) transactions where a intermediary with knowledge of an impending customer block order trades ahead of that order for the intermediary's own profit ("trading ahead")….”

175. Based on the afore-quoted judgment, the following may be listed as ingredients to classify a trading activity as front running: I. There is existence of an information regarding a substantial order on behalf of a Big Client in a particular security, and such information is not available publicly;

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

II. Based on such information about impending orders in various scrips, order (s) is/are placed in the account of Front Runner (“FR Order”) in the securities in advance of the order (s) of the Big Client. The FR order is placed in alignment with the order of the Big Client i.e. if the Big Client is going to buy securities, the FR order will also be of buying shares and vice versa. III. The placement of the buy orders of the Big Client generally causes the prices of the scrip to move upward or the sell orders of the Big Client generally causes the price to move downwards. IV. During the time of placement of orders of the Big Client, the Front Runner squares off his position and earns the difference in price which is majorly attributable to the orders of the Big Client.

176. To summarise, when Big Client is going to buy shares, the Front Runner follows a pattern of Buy-Buy–Sell, where first Buy trades are carried out in the account of Front Runner; second set of Buy trades are carried out in the account of the Big Client generally causing the prices to move upward and the third set of Sell trades are squaring off the position by Front Runner. Similarly, in Sell-Sell-Buy pattern, the Front Runner first short sells the shares before sell orders of the Big Client are placed in the system and eventually buys the shares and earns profit.

177. The Front Running activity can either be carried out in cash segment or may also be carried out in the derivatives (Futures and Options) segment. Following the patterns explained above, the Front Runner may take a long position (in case of Buy-Buy-Sell pattern) or may take a short position (in case of Sell-Sell-Buy pattern).

178. As per the generally understood definition of front running, an FR basis the information with respect to substantial impending transaction of the Big Client and builds a position in the market prior to the entry of the order of Big Client. Subsequently, when the Big Client order enters into the market, the FR matches the Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others order of the Big Client by placing its order in near proximity to the order of the Big Client. To illustrate, having knowledge of an impending substantial buy order of a Big Client, FR buys 1,00,000 shares of ABC at an average price of INR 97. Subsequently, the Big Client places order to buy 5,00,000 shares of ABC at a price of INR 100 and the front runner matches this buy order by placing a sell order of 1,00,000 ABC at a price of INR 100. Thus, in this process front runner squares off its position and earns undue profits, which in the current example comes out to be INR 3,00,000. This modus operandi of front running is known as Buy-Buy-Sell (BBS).

179. Similarly, when a FR first sells and then later on matches the sell order of Big Client by placing a buy order, it is categorized as Sell-Sell-Buy (SSB). This kind of BBS or SSB front running trading pattern is identified as traditional front running.

180. However, in the instant matter, the trading pattern of many trades executed by the FRs does not always follow traditional front running trading pattern. In certain instances, the FRs have modified the usual modus operandi of front running and, thus, have adopted a novel approach to benefit from the NPI with respect to substantial impending transaction of the Big Client. After the traditional BBS and SSB trading strategy, the prices in a scrip generally retrace to normal levels after the big trades get executed. A person equipped with the knowledge of the impending big order and knowing how the prices in the scrip behave post such big trades can undertake NPI-based trades by matching quantities with Big Client as well as by taking positions in larger quantities than the position of Big Client and then squaring off their excess position when the prices in the scrip retrace to normal levels. In both the instances, FR can make huge profits in a short span of time.

181. The aforesaid approach can be understood as Buy-Buy-Sell-Buy (BBSB) or Sell- Sell-Buy-Sell (SSBS) or Sell-Buy-Sell (SBS) or Buy-Sell-Buy (BSB). The same is explained below:

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others i. Buy-Buy-Sell-Buy (BBSB): Based on prior knowledge about impending buy order of the Big Client, the FR takes a buy position in the scrip prior to entry of the Big Client. When the Big Client places its buy order, the FR matches it with its sell order. However, the sell quantity of the FR is higher than the buy position, which it had earlier built in the scrip. Thereafter, during the day as price in the scrip retraces to its normal level, the FR squares off its short position in the scrip (i.e. built due to sell trades undertaken in excess of its earlier buy position) by undertaking buy trades during the day. Thereby, FR increases his payoff vis-à-vis the payoff he would have earned had he only squared off his position against the trades of Big Client only. This pattern of NPI-based trades is labelled as BBSB (shown in picture below). Figure no. 8 Depiction of Buy-Buy-Sell-Buy (BBSB) Strategy

Sell by the Buy by FR - FR - Buy by the Buy by the squares off matching FR Big Client excess with Big short Client ii. Sell-Sell-Buy-Sell (SSBS): The converse of BBSB trading strategy can be understood as SSBS trading strategy. Based on prior knowledge about impending sell order of the Big Client, the FR builds a sell position in the scrip. When the Big Client places its sell order, the FR matches it with its buy orders. However, the buy quantity of the FR is higher than the sell position, which it had earlier built in the scrip. Thereafter, during the day as price in the scrip retraces to its normal level, the FR squares off its long position in the scrip (i.e., built due to buy trades undertaken in excess of its earlier sell position) by undertaking sell trades. Thereby increasing his payoff vis-à-vis the payoff he would have earned had he only squared off his

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others position against the trades of Big Client. This pattern of NPI-based trades is, thus, labelled as SSBS (shown in picture below). Figure no. 9 Depiction of Sell-Sell-Buy-Sell (SSBS) Strategy

Buy by Sell by FR Sell by the FR - Sell by -squares the Big matching the FR off excess Client with Big long Client iii. Buy-Sell-Buy (BSB): Based on the prior knowledge about impending buy order of the Big Client, the FR matches it with its sell trades. However, this sell has been done by the FR without any initial buy in the scrip, thereby, creating a short position in the scrip. Due to the buy order of the Big Client, there is a sudden rise in the demand for the scrip, leading to rise in prices. However, once the buy order of the Big Client gets executed, the price in the scrip retraces to its normal level. Thus, FR squares off its short position in the scrip (i.e. created by matching its sell trades with the buy trades of the Big Client) throughout the day. This pattern of NPI-based trade is labelled as BSB trading strategy (shown in picture below). Figure no. 10 Depiction of Buy-Sell-Buy (BSB) Strategy

Buy by the Big Sell by the FR -matching Buy by FR -squares off Client with Big Client short position iv. Sell-Buy-Sell (SBS): Based on the prior knowledge about impending sell order of the Big Client, the FR matches it with its buy trades. However, this buy has been done by the FR without any initial sell in the scrip, thereby, creating a long position in the scrip. Due to the sell order of the Big Client, there was a sudden fall in the demand for the scrip, leading to depression in Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others prices. However, once the sell order of the Big Client gets executed, the price in the scrip retraces to its normal level. FR squares off its long position in the scrip (i.e. created by matching its buy order with the sell order of the Big Client) throughout the day. This pattern of NPI-based trades is, thus, labelled as SBS (shown in picture below). Figure no. 11 Depiction of Buy-Sell-Buy (BSB) Strategy

Sell by Buy by the FR - Sell by FR -the Big matching with squares off Client Big Client long position

182. In the instant matter, in addition to the traditional BBS and SSB front-running strategies, the FRs have used BBSB, SSBS, BSB and SBS trading strategies to take advantage of the prior knowledge of the orders of the Big Client as explained above. The aforesaid strategies are nothing but an extended form of front-running since the orders are placed in securities by FRs, while directly or indirectly in possession of information that is not publically available, regarding a substantial impending transaction in that securities, its underlying securities or its derivative.

183. When the examination of trades carried out in the earlier part of this order is considered with a lens of the definition of front running elaborated above, I hold, prima facie, that the trades executed in the accounts of the FRs were in the nature of extended front running of the trades of the Big Client. It is for this reason that in this order profit makers who carried out extended form of front running are called front runners. It may be emphasised that the trading patterns showing identifiable patterns are themselves sufficient to prima facie hold such trades as extended front running, however, the present case has direct evidence in the form of statement of Noticees and also other corroborative evidences in term of Bloomberg chats, Whatsapp Chats, phone calls, digital footprints of IP address etc.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

184. Having examined the trades executed in the account of the FRs, where it has been observed with strong evidences that trades in the above mentioned Noticees account were in the nature of extended front running the trades of the Big Client, it become imperative now to make a further examination as to whether the acts on the part of Noticees can prima facie be in violation of provisions of clauses (a), (b), (c) and (e) of section 12A of the Securities and Exchange Board of India Act, 1992 and clauses (a), (b), (c), (d) of regulation 3, sub-regulation (1) of regulation 4 and clause (q) of sub-regulation (2) of regulation 4 read with clause (c) of sub-regulation (1) of regulation 2 of the SEBI (Prohibition of Fraudulent and Unfair Trade Practices) Regulations, 2003, (PFUTP Regulations). In case the answer to the above in affirmative, it is to be examined whether the facts of the matter warrant an urgent action while exercising power bestowed under the provisions of section 11, section 11B of the SEBI Act and clause (d) of sub-regulation 1 of regulation 11 of the PFUTP Regulations. Before proceeding further, it is necessary to refer the relevant provisions of law which are reproduced here under for reference:

“SEBI Act, 1992

Functions of Board.

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.

11 (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: —

… Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others (d) impound and retain the proceeds or securities in respect of any transaction which is under investigation;

….

(4A) Without prejudice to the provisions contained in sub-sections (1), (2), (2A), (3) and (4), section 11B and section 15-I, the Board may, by an order, for reasons to be recorded in writing, levy penalty under sections 15A, 15B, 15C, 15D, 15E, 15EA, 15EB, 15F, 15G, 15H, 15HA and 15HB after holding an inquiry in the prescribed manner.

Power to issue directions and levy penalty.

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 Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others 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.

(2) Without prejudice to the provisions contained in sub-section (1), sub-section (4A) of section 11 and section 15-I, the Board may, by an order, for reasons to be recorded in writing, levy penalty under sections 15A, 15B, 15C, 15D, 15E, 15EA, 15EB, 15F, 15G, 15H, 15HA and 15HB after holding an inquiry in the prescribed manner.

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.

(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, Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others 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;

….

(e) deal in securities while in possession of material or non-public information or communicate such material or non-public information to any other person, in a manner which is in contravention of the provisions of this Act or the rules or the regulations made thereunder;

Delegation.

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.

Contravention by companies.

27. (1) Where a contravention of any of the provisions of this Act or any rule, regulation, direction or order made thereunder has been committed by a company, every person who at the time the contravention was committed was in charge of, and was responsible to, the company for the conduct of the business of the company, as well as the company, shall be deemed to be guilty of the contravention and shall be liable to be proceeded against and punished accordingly:

Provided that nothing contained in this sub-section shall render any such person liable to any punishment provided in this Act, if he proves that the contravention was committed without his knowledge or that he had exercised all due diligence to prevent the commission of such contravention.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

PFUTP Regulations

2. (1) In these regulations, unless the context otherwise requires, —

… (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, (7) deceptive behaviour 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.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others (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;

Nothing contained in this clause shall apply to any general comments made in good faith in regard to— (a) the economic policy of the government (b) the economic situation of the country (c) trends in the securities market or (d) any other matter of a like nature whether such comments are made in public or in private;

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 thereunder;

(c) employ any device, scheme or artifice to defraud 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 Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others 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 thereunder. Prohibition of manipulative, fraudulent and unfair trade practices

Regulation 4 (1) Without prejudice to the provisions of regulation 3, no person shall indulge in a fraudulent or an unfair trade practice in securities.

Regulation 4 (2) Dealing in securities shall be deemed to be a fraudulent or an unfair trade practice if it involves–

...(q) any order in securities placed by a person, while directly or indirectly in possession of information that is not publically available, regarding a substantial impending transaction in that securities, its underlying securities or its derivative.”

185. As noted above that in case, records indicate violation of aforesaid provisions, it will be required to be examined whether sufficient grounds are present necessitating issuance of interim directions under sub-sections (1) and (4) of section 11, and sub-section (1) of section 11B of the SEBI Act.

186. I note that the clauses (a), (b) and (c) of section 12A of the SEBI Act, 1992 and regulations 3 and 4 quoted above, 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; 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 Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others contravention of the provisions of the SEBI Act or rules or regulations; or v. dealing in securities while in possession of material or non-public information or communicate such material or non-public information to any other person in contravention of the provisions of the SEBI Act or rules or regulations made thereunder.

187. Sub-regulation (1) of regulation 4 of the PFUTP Regulations prohibit any person to indulge in fraudulent transaction and unfair trade practice in securities. The term “fraud” of “fraudulent” are defined broadly in clause (c) of sub-regulation (1) of regulation 2 of the PFUTP Regulations. An act of front running a trade is clearly covered as “fraudulent transaction” in the definition. Further, clause (q) of sub-regulation (2) of regulation 4 of the PFUTP Regulations stipulates that any order of securities placed by a person while directly/indirectly in possession of an information pertaining to a substantial impending transaction in such securities, shall be deemed to be fraudulent transaction. This particular clause clearly makes front running a fraudulent transaction. Thus, buying, selling or dealing in securities in a fraudulent manner leads to violation of provisions of section 12A of the SEBI Act read with regulations 3 and 4 of the PFUTP Regulations.

188. In the present case, it has been elaborated in detail based on factual evidence as to how Rohit Salgaocar and Ketan Parekh have prima facie devised a scheme in where Ketan Parekh was obtaining NPI about the impending order of the Big Client from Rohit Salgaocar and passing trading instructions on the basis of such NPI to FRs, either directly or through facilitators, who took positions in various scrips ahead of the order of the Big Client in those scrips. As and when the orders on behalf of the Big Client containing large quantities were placed, the FRs were directed to take counter positions, so as to match with the order of Big Client. This would lead to FRs either squaring off of their initial position taken in the scrip or creating excess long or short position in the scrip, which they would eventually square off during the day, Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others thereby, generating undue profits in quick span of time. The investigation has also brought out evidence about the sharing of unlawful profits between Noticees in cash as well as banking transactions. All the acts on the part of Noticees elaborated in the present order indicates towards the scheme that was crafted for personal gains and to defraud the investors, as the NPI pertaining to the impending transactions in various scrips was encashed to make unlawful gains in the accounts of the FRs.

189. In view of the analysis of the facts of the present case, I hold that there is a prima facie case of fraudulent and unfair trade practice carried out by Noticees which resulted in accrual of unlawful gains of INR 65,77,11,547 (INR 38.70 crores by FRs + INR 27.07 crore by Rohit Salgaocar) in the accounts of Rohit Salgaocar and the FRs. The analysis carried out in the present order backed by evidence leads to a prima facie conclusion that the violation of clauses (a), (b), (c), (e) of section 12 A and clauses (a), (b), (c), (d) of regulation 3, sub-regulation (1) of regulation 4, clause (q) of sub-regulation (2) of regulation 4 of the PFUTP Regulations have been committed by Noticees herein as under: i. Noticees have employed fraudulent/manipulative or deceptive device or contrivance, in contravention of the provisions of the SEBI Act, 1992 and the PFUTP Regulations. ii. Noticees have employed a device/scheme or artifice to defraud investors and for that they have engaged in act, practice, course of business which operated as fraud or deceit upon investors in contravention of provisions of the SEBI Act, 1992 and the PFUTP Regulations as quoted above. iii. Noticees have dealt in securities or facilitated such dealing, while in possession of material or non-public information in the form of advance information about the impending orders in various scrips. iv. The dealing in securities by the aforesaid Noticees in manner as elaborated in the present order is fraudulent and an unfair trade practice and was in the nature of extended front running. Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

190. I note that in a similar matter (Madhu Chanda and others vs. SEBI, Appeal no. 335 of 2023, Date of decision: October 30, 2023) involving front running in multiple accounts, the Hon’ble Securities Appellate Tribunal (SAT) has inter alia observed as: “…We find that the very nature front running refers to an extremely precise trading activity which is impossible to achieve unless the front runner had access to the non-public information about the impending orders of the Big Client (in this case the, Sterling group). For this reason, matching of common scrip days, common percentage of shares, precise matching of price by the front runner with the Big Client, earning significant amounts of profits on common scrip days with the Big Client when compared to non-common scrip days are all extremely strong indicators that the front runners were placing its orders ahead of and in tandem with the large orders of the Big Client in order to make gains for themselves. Thus, due to the trading based on prior information of trades of the Sterling group, the front runners and the entities who facilitated them gained unlawfully and caused loss to other investors / deprived the investors from profits. …We find that a sample analysis of the trades placed in the accounts of each of the front runners vis-a-vis the trades in the account of the respective Sterling group entity has been carried out meticulously in the WTM order as well as the respective AO orders which clearly establish the manner in which the front running trades were carried out.

191. On the basis of examination of evidences collected during the investigation, I prima facie hold that: i. Noticees were involved in extended front running the trades of the Big Client. ii. The said acts on the part of Noticees are fraudulent in terms of clause (c) of sub-regulation (1) of regulation 2 of the PFUTP Regulations and is violative of clauses (a), (b), (c) and (e) of section 12 A of the SEBI Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Act, 1992 read with clauses (a), (b), (c), (d) of regulation 3, sub-regulation (1) of regulation 4 and clause (q) of sub-regulation (2) of regulation 4 of the PFUTP Regulations.

L. LIABILITY OF DIRECTORS OF FR1, FR2, FR5 AND FR6 192. Four of the FRs, in whose proprietary trading account NPI-based trades were carried out namely, GRD Securities Limited, Salasar Stock Broking Limited, Basukinath Properties Private Limited and APR Properties Private Limited are not natural person but are companies incorporated in India. Section 27 of the SEBI Act enunciates the liability of a director, manager, secretary or other officer of the company for the contraventions committed by such company. In terms of sub-section (1) of section 27 of the SEBI Act, every person who at the time the contravention was committed was in charge of, and was responsible to, the company for the conduct of its business shall be deemed to be guilty of the contravention along with the company. However, such presumption is rebuttable if such person proves that the contravention was committed without his or her knowledge or that he or she had exercised all due diligence to prevent the commission of such contravention.

193. In order to ascertain the liability of the person responsible for the conduct of its business of the corporate FRs, a table containing the details of directors who were in charge of, and were responsible to, the company for the conduct of its business during the Investigation Period and the role played by them is provided below:

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Table no. 63 Liability of the directors for contraventions committed by FR companies Whether Date of Date of Designation charged Rationale for charging or not Name appointment retirement (Category) as charging the directors of director of director Noticee

GRD Securities Limited

Pramod Kumar Drolia was the managing director and promoter of GRD Securities Limited at the time the contravention was alleged to be Pramod committed by the company and was Managing Director Kumar 01/08/2007 Not retired Yes in such capacity in charge of, and (Promoter) Drolia responsible to, the company for the conduct of its business and hence is prima facie held to be guilty of the alleged contravention committed by GRD Securities Limited. Bimal Kumar Drolia was the Whole- Time Director and promoter of GRD Securities Limited at the time the Bimal Whole-Time contravention was alleged to be Kumar Director 01/08/2007 Not retired Yes committed by the company and was Drolia (Promoter) in such capacity in charge of, and responsible to, the company for the conduct of its business and hence is prima facie held to be guilty of the Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Whether Date of Date of Designation charged Rationale for charging or not Name appointment retirement (Category) as charging the directors of director of director Noticee contravention committed by GRD Securities Limited. Anita Drolia was the executive director and promoter of GRD Securities Limited at the time the contravention was alleged to be committed by the company and was Anita Director 06/01/2020 11/11/2021 Yes in such capacity in charge of, and Drolia (Promoter) responsible to, the company for the conduct of its business and hence is prima facie held to be guilty of the contravention committed by GRD Securities Limited. Priya Saraf was an independent director at the time the contravention was alleged to be committed and in such capacity is not deemed guilty of alleged contravention committed by the company since she is not Priya Director 15/07/2022 Not retired Yes presumed to be in charge of the day- Saraf (Independent) to-day activities of the company.

However, the physical computer system with CTCL ID ‘700020002063’ which was found in the office of Sanjay Taparia was Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Whether Date of Date of Designation charged Rationale for charging or not Name appointment retirement (Category) as charging the directors of director of director Noticee registered in the name of Priya Saraf (as detailed in Table no. 9) and hence it is inferred that she facilitated trading in the proprietary trading account of GRD Securities Limited through her CTCL ID. Since there is direct evidence on record to show her involvement in the alleged contravention, she is deemed to be in-charge of the company for the contravention committed by the company and hence deemed guilty. Nainaa Drolia was an independent director at the time the contravention was committed and in absence of direct evidence on record to show that Nainaa Director 04/12/2021 15/07/2022 No she was in charge of, and responsible Drolia (Independent) to the company for the alleged contravention, she is not held guilty of the alleged contravention committed by GRD Securities Limited. Satyam Saraf was an independent director at the time the contravention Satyam Director 30/09/2016 Not retired No was committed and in absence of Saraf (Independent) direct evidence on record to show that he was in charge of, and responsible Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Whether Date of Date of Designation charged Rationale for charging or not Name appointment retirement (Category) as charging the directors of director of director Noticee to the company for the alleged contravention, he is not held guilty of the alleged contravention committed by GRD Securities Limited.

Salasar Stock Broking Limited

Kiran Kumar Sonthalia was the Whole-Time Director of Salasar Stock Broking Limited at the time the contravention was alleged to be Kiran committed by the company and was Whole-Time Kumar 30/12/1994 Not retired Yes in such capacity in charge of, and Director(-) Sonthalia responsible to, the company for the conduct of its business and hence is prima facie held to be guilty of the contravention committed by the company. Shyam Saraogi was the Whole-Time Director of Salasar Stock Broking Limited at the time the contravention Shyam Whole-Time was alleged to be committed by the 11/01/2019 Not retired Yes Saraogi Director(-) company and was in such capacity in charge of, and responsible to, the company for the conduct of its business and hence is prima facie Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Whether Date of Date of Designation charged Rationale for charging or not Name appointment retirement (Category) as charging the directors of director of director Noticee held to be guilty of the contravention committed by the company. Further, there is evidence on record to show his direct involvement in the commission of alleged contravention as brought out in this order.

Further, as discussed in this order, following evidences show his active involvement in the alleged violations as facilitator:

i. Shyam Saraogi was a member of the WhatsApp group named “Jack-Saro”, in which Ketan Parekh provided NPI-based trade instructions pursuant to which such trades were executed from the proprietary account of Salasar Stock Broking Limited.

ii. Shyam Saraogi colluded with Sanjay Taparia and an associate of Ketan Parekh to transfer money through Angadiya.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Whether Date of Date of Designation charged Rationale for charging or not Name appointment retirement (Category) as charging the directors of director of director Noticee Pradeep Kumar Saraogi was an independent director at the time the contravention was alleged to be committed by the company and in such capacity is not prima facie held to be guilty of alleged contravention committed by the company since he is not presumed to be in charge of the day-to-day activities of the company.

However, the physical computer system with CTCL ID Pradeep Director ‘700001002002’ through which the Kumar 17/05/2005 Not retired Yes (Independent) NPI-based trades were executed in Saraogi the proprietary trading account of Salasar Stock Broking Limited was found in the office of Company was registered in the name of Pradeep Kuma Saraogi (as detailed in Table no. 12) and hence it is inferred that he facilitated trading in the proprietary trading account of Salasar Stock Broking Limited through his CTCL ID. Since there is direct evidence on record to show his involvement in the alleged contravention, he is deemed Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Whether Date of Date of Designation charged Rationale for charging or not Name appointment retirement (Category) as charging the directors of director of director Noticee to be in-charge of the company for the contravention committed by the company and hence prima facie held guilty. Ashok Tibrewal was the Whole-Time Director of Salasar Stock Broking Limited at the time the contravention was alleged to be committed. However, the evidence on record shows that he has been in dispute Ashok Whole-Time 30/12/1994 Not retired No with Salasar Stock Broking Private Tibrewal Director(-) Limited since 2016 (as per NCLT case no. CP/21(KB) 2016) and is not involved in the day to day operations of the company. Accordingly, he is not held guilty of the contraventions committed by the company.

APR Properties Private Limited

Rachit Poddar was the director and promoter of APR Properties Private Rachit Director Limited at the time the contravention 30/09/2019 Not retired Yes Poddar (Promoter) was alleged to be committed by the company and was in such capacity in charge of, and responsible to, the Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Whether Date of Date of Designation charged Rationale for charging or not Name appointment retirement (Category) as charging the directors of director of director Noticee company for the conduct of its business and hence is prima facie held to be guilty of the contravention committed by the company.

Further, as discussed in this order, following evidences show his active involvement in the alleged violations as facilitator:

i. Mobile number of Ketan Parekh was saved as “Wellwisher” on the mobile phone of Rachit Poddar;

ii. In the statement made by father of Rachit Poddar i.e. Ashok Kumar Poddar, he stated that Ketan Parekh used to provide trade related instructions to Ashok Kumar Poddar over WhatsApp call and messages. This is corroborated by the analysis of CDR which indicates that Ashok Kumar Poddar had frequent

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Whether Date of Date of Designation charged Rationale for charging or not Name appointment retirement (Category) as charging the directors of director of director Noticee interactions with Ketan Parekh and his brother Kartik Parekh;

iii. In the statement made by Ashok Kumar Poddar, he further stated that he used to communicate the NPI-based trading instructions received from Ketan Parekh to his son, Rachit Poddar who then used to execute the NPI-based trades in the trading accounts of APR Properties Private Limited and Basukinath Properties Private Limited through the systems placed at their residence;

iv. The computer devices from which NPI-based trades were executed in the trading accounts of APR Properties Private Limited and Basukinath Properties Private Limited were found at the residential premises of Ashok Kumar Poddar and Rachit Poddar;

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Whether Date of Date of Designation charged Rationale for charging or not Name appointment retirement (Category) as charging the directors of director of director Noticee v. The analysis of bank accounts of various firms of Rachit Poddar shows that during the investigation period a total of 263 debit and credit transactions have happened between the account of Realstone (a firm associated with Ketan Parekh) and bank accounts of various firms of Rachit Poddar.

Manoj Kumar Agarwal was the director and promoter of APR Properties Private Limited at the time the contravention was alleged to be Manoj committed by the company and was Director Kumar 20/09/2022 Not retired Yes in such capacity in charge of, and (Promoter) Agarwal responsible to, the company for the conduct of its business and hence is prima facie held to be guilty of the contravention committed by the company. Mahendra Kumar Agarwal was a Mahendra director of APR Properties Private Kumar Director(-) 14/07/1995 25/04/2022 Yes Limited at the time the contravention Agarwal was alleged to be committed and was Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Whether Date of Date of Designation charged Rationale for charging or not Name appointment retirement (Category) as charging the directors of director of director Noticee in such capacity in charge of, and responsible to, the company for the conduct of its business and hence is prima facie held to be guilty of the contravention committed by the company. Renu Agarwal was a director of APR Properties Private Limited at the time the contravention was alleged to be committed and was in such capacity Renu Director(-) 31/01/2002 25/04/2022 Yes in charge of, and responsible to, the Agarwal company for the conduct of its business and hence is prima facie held to be guilty of the contravention committed by the company.

Basukinath Properties Private Limited

Rachit Poddar was the director and promoter of APR Properties Private Limited at the time the contravention Rachit was alleged to be committed by the Director(Promoter) 30/09/2019 Not retired Yes Poddar company and was in such capacity in charge of, and responsible to, the company for the conduct of its business and hence is prima facie Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Whether Date of Date of Designation charged Rationale for charging or not Name appointment retirement (Category) as charging the directors of director of director Noticee held to be guilty of the contravention committed by the company.

Further, as discussed in this order, following evidences show his active involvement in the alleged violations as facilitator:

i. Mobile number of Ketan Parekh was saved as “Wellwisher” on the mobile phone of Rachit Poddar;

ii. In the statement made by father of Rachit Poddar i.e. Ashok Kumar Poddar, he stated that Ketan Parekh used to provide trade related instructions to Ashok Kumar Poddar over WhatsApp call and messages. This is corroborated by the analysis of CDR which indicates that Ashok Kumar Poddar had frequent interactions with Ketan Parekh and his brother Kartik Parekh; iii. In the statement made by Ashok Kumar Poddar, he further Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Whether Date of Date of Designation charged Rationale for charging or not Name appointment retirement (Category) as charging the directors of director of director Noticee stated that he used to communicate the NPI-based trading instructions received from Ketan Parekh to his son, Rachit Poddar who then used to execute the NPI-based trades in the trading accounts of APR Properties Private Limited and Basukinath Properties Private Limited through the systems placed at their residence;

iv. The computer devices from which NPI-based trades were executed in the trading accounts of APR Properties Private Limited and Basukinath Properties Private Limited were found at the residential premises of Ashok Kumar Poddar and Rachit Poddar;

v. The analysis of bank accounts of various firms of Rachit Poddar shows that during the investigation period a total of 263 Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Whether Date of Date of Designation charged Rationale for charging or not Name appointment retirement (Category) as charging the directors of director of director Noticee debit and credit transactions have happened between the account of Realstone (a firm associated with Ketan Parekh) and bank accounts of various firms of Rachit Poddar.

Manoj Kumar Agarwal was the director and promoter of APR Properties Private Limited at the time the contravention was alleged to be Manoj committed by the company and was Kumar Director(Promoter) 20/09/2022 Not retired Yes in such capacity in charge of, and Agarwal responsible to, the company for the conduct of its business and hence is prima facie held to be guilty of the contravention committed by the company. Mahendra Kumar Agarwal was a director of APR Properties Private Limited at the time the contravention Mahendra was alleged to be committed and was Kumar Director(-) 20/02/2001 25/04/2022 Yes in such capacity in charge of, and Agarwal responsible to, the company for the conduct of its business and hence is prima facie held to be guilty of the Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Whether Date of Date of Designation charged Rationale for charging or not Name appointment retirement (Category) as charging the directors of director of director Noticee contravention committed by the company.

194. In the matter of KK Ahuja v. V.K Arora (2009 10 SCC 48.), the Hon’ble Supreme Court analysed the terms ‘in charge of’ and ‘responsible to’ in the context of vicarious liability provisions and held that the ‘in-charge’ principle presents a factual test and the ‘responsible to’ principle presents a legal test. The court held that a person would be in-charge of the business of the company if the person is in overall control of the day-to-day business of the company.

195. Thus, while an executive or whole-time director of the defaulting company can be called to be ‘in charge of the business of the company’, an independent director or a non-executive director, having no control over the day-to-day business of the company might not be considered to be in charge of the business of the company unless evidence to the contrary can be shown.

196. In view of the above and basis the legal principle contained in section 27 of the SEBI Act, a rebuttable presumption can be drawn against the executive directors of the FRs for fastening vicarious liability upon them for the contraventions committed by the corporate FRs in the instant matter. Accordingly, for the reasons stated in the table above. I find the aforesaid directors, except Nainaa Drolia, Satyam Saraf and Ashok Tibrewal, are vicariously liable for the extended front-running activities committed by the FR companies.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

M. NEED FOR INTERIM EX-PARTE ORDER

197. I have already held that the acts imputed in the present order on Noticees are prima facie held in violation of various provisions of the SEBI Act, 1992 and the PFUTP Regulations. Now it would be important to examine as to whether this interim ex-parte order is required to be passed. I note that sub-section (4) of section 11 and section 11B allows SEBI to restrain persons from accessing the securities market and prohibit any person associated with securities market to buy, sell or deal in securities and to issue “such directions as may be necessary” in the interest of investors of the securities market. The evidence of the present case speaks volume about the intricate design that was at play. Traders of the Big Client were discussing with Rohit Salgaocar prior to executing trades and such information was prima facie encashed by Rohit Salgaocar by sharing the same with Ketan Parekh. While the traders of the Big Client were discussing trades with Rohit Salgaocar for ensuring counter parties for their trading, Rohit Salgaocar was using that information to make illegal profits by routing information to Ketan Parekh. When the information reached Ketan Parekh, he acted in a systematic manner and trades were executed in different accounts which cumulatively generated unlawful profits. Ketan Parekh is not an ordinary person. As discussed later, he was debarred from the securities markets for 14 years earlier also.

198. It is noted that a duty has been cast upon SEBI under section 11 to protect the interests of investors in securities and to promote the development of and to regulate the securities market. All the afore-quoted objects are equally crucial for growth of the securities market. It is also noticed that any kind of manipulative activities by a person or group of persons have impact on the securities market as a whole. Therefore, it becomes essential that the investors and the securities market are protected from the manipulative and unfair trade practices relating to securities market and SEBI has been empowered to take any measures, as it deems fit to achieve the mandate. The PFUTP Regulations have been framed with an objective Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others of preventing fraudulent and unfair trade practices relating to securities market, which will aid in achieving the mandate of investor protection, regulation and development of securities market.

199. A prima facie case of violation of various provisions of the SEBI Act, 1992 and the PFUTP Regulations has already been made out against Noticees which is largely backed by direct evidences on record. I observe that the association of some of the Noticees to the securities market, their overall conduct and the manner in which they have used technology to cover their tracks, necessitate to take emergent actions to protect the integrity of the securities market, so that the interest of the investors is not jeopardised. Further, at this stage, I also note the following factors: I. All Noticees are closely associated with the securities market as discussed above. II. The trading activities which are prima facie swarmed with illicit design, were repeatedly carried out for long period of time. III. The concerned Noticees were able to generate large amount of profits which is prima facie found to be unlawful, which may be siphoned off beyond regulatory reach, if immediate steps are not taken. IV. Further, I have considered other factors like the nexus that Noticees have with each other; the use of technology by them to share information, the sharing of profits of large amounts. Considering all these factors, it becomes imperative for SEBI to protect siphoning off of the unlawful gains made by Noticees, which may be liable for disgorgement in the final proceedings.

200. At this juncture, it is also crucial to note that Ketan Parekh is a habitual offender and has been found guilty of market manipulation in the past as well. Through his group broking firms and investment companies, Ketan Parekh indulged in manipulative trades which led to the stock markets crash in 2001. A Joint Parliamentary Committee on Stock market scam and matters relating thereto was also constituted Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others on April 27, 2001 to probe, inter alia, into the irregularities and manipulations related to the stock markets crash of 2001 and the Committee submitted its report on December 19, 2002 wherein it noted that Ketan Parekh was the key player in the scam and received large sums of money from banks as well as from Corporate bodies during the period when SENSEX was falling rapidly and therefore recommended SEBI to investigate the matter expeditiously. The investigations conducted by SEBI into the alleged violations, inter alia, revealed that, Ketan Parekh created artificial volumes and manipulations in various scrips during the period between 1999 to 2001and accordingly various enforcements actions were initiated against Ketan Parekh group entities including passing of various directions under Section 11B of the SEBI Act, Adjudication Proceedings and Prosecution Proceedings.

201. Vide SEBI order dated December 12, 2003, Ketan Parekh and his group entities were prohibited from dealing in the securities in any manner, directly or indirectly, and were also debarred from associating with the securities market for a period of 14 years. While the aforesaid order of debarment was in force, it was found that an entity named Gibs Computers, which was controlled by Ketan Parekh, was trading in the securities market despite clear embargo on Ketan Parekh to directly or indirectly deal or associate with securities market. Accordingly, a monetary penalty of one crore rupees was imposed on the entity by the Adjudicating Officer vide order dated June 26, 2013.

202. SEBI has also initiated prosecution proceedings against Ketan Parekh and connected entities. I note that in the said proceedings, Ketan Parekh has evaded the service of summons, bailable warrants and non-bailable warrants and finally appeared only after the issuance of proclamation by the court and after further follow-ups by SEBI.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

203. In view of the above, considering the repetitive nature of violations by Ketan Parekh and evidences gathered in the instant matter, I am of the view that an interim ex-parte order is required to be passed in this matter to protect the interest of the securities market and investors.

204. I seek to place reliance on the order of the Hon’ble Securities Appellate Tribunal, passed in the matter of Amalendu Mukherjee Vs. SEBI (Appeal (L) no. 169 of 2020), wherein the Hon’ble Tribunal has underscored the necessity of passing impounding orders by inter alia observing as: “We are of the opinion that the WTM is empowered under the SEBI Act and the Regulations to pass an ex-parte order in order to protect the interests of securities market and the investors. If such impounding order is not passed, it may result in defeating the ultimate direction of disgorgement if any, as there would be chances of such monies being dissipated by the appellant. …”

205. Based on the foundation of factors quoted above and in totality of the facts of the present case, I am compelled to invoke the provisions under sub-section (1) of section 11, sub-section (4) of section 11, section 11B of the SEBI Act, 1992 and regulation 11 of the PFUTP Regulations, to hold that it is a fit case for passing interim order and to impound the proceeds of prima facie unlawful gains made by Noticees.

N. BASIS OF DISGORGEMENT AND JOINT AND SEVERAL LIABILITY

206. Having held that in the facts of the present case, invocation of powers to issue interim order is necessitated, the next issue that deserves consideration is fixing of prima facie liability for impounding of unlawful gains which accrued due to deployment of fraudulent scheme by Noticees. In this connection, I note that the explanation to sub-section (1) of section 11B of the SEBI Act, 1992 inter alia empowers SEBI to issue

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others directions to any person, for disgorgement of wrongful gains made by him, by contravention of any provision of the SEBI Act or the regulations made thereunder.

207. In order to fix the liability of the respective entities, it is noted that Rohit Salgaocar was instrumental in obtaining the NPI about the substantial impending trades of the Big Client in various scrips and Ketan Parekh, through facilitators and FRs, used such information to execute front running trades.

208. Thus, apart from the FRs (in whose account the unlawful profit accrued), other Noticees also played an active role for generation of the unlawful gains, making them liable jointly and severally for impounding, with the respective Noticee in whose account the profit accrued.

209. Further, in view of the findings in Part L of this order, the directors of various companies are also liable to be proceeded against for the unlawful profits that accrued to the Noticees and are held jointly and severally liable with their respective companies, by virtue of section 27 of the SEBI Act, 1992.

210. In view of the aforesaid discussion and the calculation of unlawful gains made by Noticees as detailed in Table no. 54, I hold that Noticees to be prima facie jointly and severally liable for impounding of unlawful profits in the following manner: Table no. 64 Joint and several liabilities of Noticees for impounding of wrongful gains Amount of Entities jointly and Sr. wrongful severally liable for Noticee No. gains made impounding of (INR) wrongful gains 27,06,73,574 Rohit Salgaocar and 1. Rohit Salgaocar (Commission Ketan Parekh earnings)

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Amount of Entities jointly and Sr. wrongful severally liable for Noticee No. gains made impounding of (INR) wrongful gains Rohit Salgaocar, Ketan 6,00,91,126 Parekh, Sanjay Taparia, (Profits made GRD Securities Limited, 2. GRD Securities Limited through Pramod Kumar Drolia, fraudulent Bimal Kumar Drolia, trading) Priya Saraf and Anita Drolia 4,85,62,517 (Profits made 3. Anirudh Damani through fraudulent Rohit Salgaocar, Ketan trading) Parekh, Sanjay Taparia, 17,22,612 Anirudh Damani and (Profits made Ashok Kumar Damani 4. Ashok Kumar Damani through fraudulent trading) Subtotal 11,03,76,255

12,45,20,605 Rohit Salgaocar, Ketan (Profits made Parekh, Sumit Salasar Stock Broking 5. through Sonthalia, Salasar Limited fraudulent Stock Broking Limited, trading) Kiran Kumar Sonthalia, Shyam Saraogi and Subtotal 12,45,20,605 Pradeep Kumar Saraogi

Rohit Salgaocar, Ketan 10,68,11,692 Parekh, Ashok Kumar (Profits made Poddar, Basukinath Basukinath Properties 6. through Properties Private Private Limited fraudulent Limited, APR Properties trading) Private Limited, Rachit Poddar, Manoj Kumar

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Amount of Entities jointly and Sr. wrongful severally liable for Noticee No. gains made impounding of (INR) wrongful gains Agarwal and Mahendra Kumar Agarwal Rohit Salgaocar, Ketan Parekh, Ashok Kumar Poddar, Basukinath 4,53,29,421 Properties Private (Profits made APR Properties Private Limited, APR Properties 7. through Limited Private Limited, Rachit fraudulent Poddar, Manoj Kumar trading) Agarwal, Mahendra Kumar Agarwal and Renu Agarwal Subtotal 15,21,41,113 TOTAL 65,77,11,547

O. INTERIM ORDER 211. Thus, after analysing all the evidences on record I hold that this is a fit case to exercise powers of passing interim order so as to insulate the securities market and to protect the unlawful gains, which may go beyond regulatory reach. Accordingly, I, in exercise of the powers conferred upon me under sub-section (1) of section 11, sub-section (4) of section 11, sub-section (1) of section 11B read with section 19 of the SEBI Act, 1992 read with regulation 11 of the PFUTP Regulations, hereby by way of the present interim order cum show cause notice, issue the following directions, which shall remain in force until further orders: I. An amount of INR 65,77,11,547 (Sixty Five Crore Seventy Seven Lakh Eleven Thousand Five Hundred Forty Seven Rupees), being the total unlawful gain earned from the alleged violations, shall be impounded, jointly and severally in manner provided in Table no. 64 and the Noticees are directed to credit/deposit jointly/severally the aforesaid amount of unlawful gains to interest bearing savings account(s) created specifically Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others for the purpose in a Scheduled Commercial Bank.

The Noticees shall create interest bearing savings account(s) with Lien in favour of SEBI and the amount kept therein shall not be released without permission from SEBI. II. Noticees no. 1 and 2 i.e. Rohit Salgaocar and Ketan Parekh devised the entire scheme to unjustly enrich from the NPI pertaining to the Big Client by orchestrating front running activities. Noticee no. 10 has admitted to be a facilitator in the front running activities. Further, Noticees no. 2 and 10 i.e. Ketan Parekh and Ashok Kumar Poddar had been prohibited from dealing in the securities and debarred from associating with the securities market in the past as well. Considering the same, Noticees no. 1,2 and 10 shall be restrained from buying, selling or dealing in securities or associating with any intermediary registered with SEBI, either directly or indirectly, with immediate effect. III. Banks, where Noticees no. 1 to 22 are holding bank accounts, shall be directed that no debits shall be made, without permission of SEBI, in respect of the bank accounts held jointly or severally by Noticees, except for the purposes of transfer of funds to the interest bearing savings account(s) as stipulated above.

Further, this direction shall not apply to those bank accounts of Noticees no. 3 and 4 which deal with clients’ funds, since Noticees no. 3 and 4 are stock brokers registered with SEBI and deal with funds of clients. IV. Depositories shall also be directed that no debit shall be made, without permission of SEBI, in respect of the demat accounts held by Noticees. However, credits, if any, into the accounts may be allowed. V. 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. Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

VI. The Registrar and Transfer Agents shall ensure that, they neither permit any transfer nor redemption of securities, including Mutual Funds units, held by Noticees. VII. Noticees shall not dispose of or alienate any of their assets/properties, till such time the amount of unlawful gain is credited to an interest bearing savings account except with the prior permission of SEBI. VIII. 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 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. IX. The directions stipulated in paragraph (III), (IV), (V), (VI) and (VII) shall cease to apply upon credit of unlawful gains to the interest bearing savings account as stipulated in sub-paragraph (I) of this paragraph. X. If the 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 on the date of this order. Banks are allowed to debit the accounts for the purpose of complying with this direction.

212. The prima facie observations/findings contained in this Order are made on the basis of the material available on record. In light of the alleged violations of the provisions of the SEBI Act, 1992 and the PFUTP Regulations by Noticees, this Order shall be treated as a Show Cause Notice under sub-section (1) of section 11, sub-section (4) of section 11, sub-section (4A) of section 11, sub-section (1) of section 11B, and sub- Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others section (2) of section 11B of the SEBI Act, 1992 read with regulation 11 of the PFUTP Regulations read with SEBI (Procedure for Holding Inquiry and Imposing Penalties) Rules, 2005, calling upon all the Noticees to show cause as to why suitable directions shall not be passed against them, including directions as proposed hereunder: I. Direction to disgorge an amount equivalent to the total gains made on account of alleged extended front running along with interest; II. Direction to restrain them from accessing the securities market and prohibiting them from buying, selling or otherwise dealing in securities for an appropriate period; III. Direction to restrain them from associating with any registered intermediary; and IV. Directions for imposition of penalty under sub-section (4A) of section 11 and sub-section (2) of section 11B read with section 15HA of the SEBI Act, 1992 against all Noticees.

213. Noticees may file their replies to SEBI within 21 days from the date of receipt of this Order and avail an opportunity of personal hearing in the matter, if they so desire.

214. This Order is without prejudice to any other action that SEBI may initiate under the securities laws, as deemed appropriate.

215. This Order shall come into force with immediate effect and shall be in force till further Orders.

216. A copy of this Order shall be forwarded to: I. Noticees, Stock Exchanges, Depositories, Registrar and Share Transfer Agents and Banks to ensure necessary compliance; II. Big Client, Nuvama and Motilal, enabling them to take appropriate actions for strengthening their internal controls to prevent occurrence of violations noted in the present Order; Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

III. Concerned departments of SEBI which deal with the regulation of registered intermediaries involved in the instant matter such as the funds of Big Client, Nuvama, Motilal, Salasar Stock Broking Limited and GRD Securities Limited for examination of violation of other securities laws, if any.

PLACE: MUMBAI KAMLESH C. VARSHNEY DATE: JANUARY 02, 2025 WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

LIST OF FIGURES MENTIONED IN THE ORDER

Figure no. 1 Screenshot of WhatsApp chat between Sanjay Taparia and Ketan Parekh ..................................................................................................................................24 Figure no. 2 Establishing identity of Ketan Parekh ....................................................25 Figure no. 3 WhatsApp chat showing instructions given by Ketan Parekh in the group Jack-ST .....................................................................................................................30 Figure no. 4 Screenshot of a message in the WhatsApp group “Jack-ST” ................38 Figure no. 5 Screenshot of a message in the WhatsApp group “Jack-Saro” .............39 Figure no. 6 Flow of NPI-based trading instructions from Ketan Parekh to FRs .......43 Figure no. 7 Flow of NPI regarding the trades of the Big Client ................................67 Figure no. 8 Depiction of Buy-Buy-Sell-Buy (BBSB) Strategy .................................145 Figure no. 9 Depiction of Sell-Sell-Buy-Sell (SSBS) Strategy .................................146 Figure no. 10 Depiction of Buy-Sell-Buy (BSB) Strategy .........................................146 Figure no. 11 Depiction of Buy-Sell-Buy (BSB) Strategy .........................................147

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

LIST OF TABLES MENTIONED IN THE ORDER

Table no. 1 Details of entities whose premises were searched by SEBI .................... 3 Table no. 2 Details of contact numbers as obtained from various devices ................12 Table no. 3 IMEI analysis of various phone numbers of Ketan Parekh .....................19 Table no. 4 Location analysis of various phone numbers of Ketan Parekh ...............20 Table no. 5 Details confirmed by Hotels ....................................................................22 Table no. 6 Flight Details of Ketan Parekh ................................................................24 Table no. 7 Details of the WhatsApp group “Jack-ST” ..............................................31 Table no. 8 Details from CDR of Sanjay Taparia and Damanis ................................32 Table no. 9 Placement of orders in the trading account of GRD Securities Limited ..33 Table no. 10 Pattern of buying by FR1 and FR3 on November 11, 2022 ..................38 Table no. 11 Details of the members of the WhatsApp group “Jack-Saro”................40 Table no. 12 Placement of orders in the prop account of Salasar Stock Broking Limited ..................................................................................................................................41 Table no. 13 Details from CDR of Ashok Kumar Poddar ...........................................42 Table no. 14 Details of trades executed by FRs before and during the Investigation Period ........................................................................................................................44 Table no. 15 Trading profile of Salasar Stock Broking Limited (FR 2) .......................46 Table no. 16 Trading profile of GRD Securities Limited (FR1) ..................................48 Table no. 17 Trading profile of Anirudh Damani (FR 3) .............................................49 Table no. 18 Trading profile of Ashok Kumar Damani (FR4) .....................................50 Table no. 19 Trading profile of Basukinath Properties Private Limited (FR5) ............51 Table no. 20 Trading profile of APR Properties Private Limited (FR6) ......................52 Table no. 21 Extract of Bloomberg chat between Rohit Salgaocar and Trader of Big Client .........................................................................................................................56 Table no. 22 Change in Gross Traded Value (GTV) in the order flow of the Big Client to Motilal ....................................................................................................................60 Table no. 23 Clients referred to Nuvama by SCPL during the Investigation Period ..62 Table no. 24 Change in Gross Traded Value (GTV) in the order flow of the Big Client to Nuvama .................................................................................................................63 Table no. 25 Extract of Bloomberg chat between Rohit Salgaocar and Trader of Motilal on September 16, 2021 .............................................................................................65 Table no. 26 Bloomberg chat between Big Client trader and Rohit Salgaocar on Dec 08, 2021 ....................................................................................................................68 Table no. 27 Summary of trades undertaken by FR2 and FR5 on December 08, 2021 ..................................................................................................................................69 Table no. 28 Matching between the big client and the FRs on December 08, 2021 .70 Table no. 29 Long positions built by each of the FR during the day ..........................70 Table no. 30 Trades undertaken by the FR1 and Big Client ......................................73

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Table no. 31 Instruction with respect to the positions taken by FR1 prior to entry of the Big Client ...................................................................................................................74 Table no. 32 Instructions with respect of the positions taken by the FR1 and BC, when matching took place ..................................................................................................77 Table no. 33 Calculation of unlawful gains made under this illustration ....................81 Table no. 34 Trades undertaken by FR 1 and the Big Client in on April 06, 2023 .....81 Table no. 35 Trades undertaken by the FR2 and Big Client during aforesaid time period ..................................................................................................................................83 Table no. 36 Instructions in respect of the positions taken by the FR2, prior to the entry of the Big Client .........................................................................................................84 Table no. 37 Instructions with respect of the positions taken by the FR2 and Big Client, when matching took place .........................................................................................86 Table no. 38 Calculation of unlawful gains made under this illustration ....................89 Table no. 39 Trades undertaken by FR2 and Big Client ............................................90 Table no. 40 Instructions in respect of the positions taken by the FR2, prior to the entry of the Big Client .........................................................................................................91 Table no. 41 Instructions with respect to the positions taken by the FR2 and Big Client ..................................................................................................................................94 Table no. 42 Trades undertaken by the FR1, FR2, FR3 and Big Client ....................97 Table no. 43 Instructions with respect to the positions taken by the FR2 and Big Client, when matching took place .........................................................................................99 Table no. 44 Calculation of unlawful gains made under this illustration ..................104 Table no. 45 Trades undertaken by the FR2, FR5 and Big Client ...........................105 Table no. 46 Bloomberg chats between Rohit Salgaocar and the trader of Big Client on January 06, 2023................................................................................................107 Table no. 47 Instruction with respect to the positions to be taken in the scrip on January 09, 2023 ..................................................................................................................108 Table no. 48 Instructions with respect to the positions taken by the FR2 and Big Client ................................................................................................................................109 Table no. 49 Calculation of unlawful gains made under this illustration ..................113 Table no. 50 Trades undertaken by the FR2, FR6 and Big Client during aforesaid Patch ................................................................................................................................114 Table no. 51 Instruction with respect to positions taken by the FR2, prior to entry of the Big Client .................................................................................................................117 Table no. 52 Instructions with respect to the positions taken by the FR2, FR6 and Big Client, during matching phase .................................................................................119 Table no. 53 Calculation of unlawful gains made under this illustration ..................122 Table no. 54 Profit earned by FRs during the Investigation Period .........................124 Table no. 55 Cash transfer of INR 25 lakhs from Ketan Parekh (Jack New) to Sumit Sonthalia .................................................................................................................126 Table no. 56 Cash transfer of INR 50 lakhs from Sumit Sonthalia to Ketan Parekh (Jack New) ........................................................................................................................129 Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others

Table no. 57 Bank transfer of INR 65 lakhs from Ketan Parekh (Jack Latest.New) to Sanjay Taparia ........................................................................................................130 Table no. 58 Cash transfer of INR 20 lakhs from Ketan Parekh to Sanjay Taparia .132 Table no. 59 Fund transfers between Ketan Parekh and various entities of Rachit Poddar .....................................................................................................................134 Table no. 60 Summary of the transactions between Realstone and Classic Share 135 Table no. 61 Summary of bank transfers made between Realstone and bank accounts of various FRs/ facilitators .......................................................................................136 Table no. 62 Proof of information sharing between various entities ........................138 Table no. 63 Liability of the directors for contraventions committed by FR companies ................................................................................................................................159 Table no. 64 Joint and several liabilities of Noticees for impounding of wrongful gains ................................................................................................................................178

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others