Interim Order in the matter of Mr. Suneel Kumar Patel and Ms. Duiji Patel

WTM/MPB/IMD/WRO/ 159/2020

BEFORE THE SECURITIES AND EXCHANGE BOARD OF INDIA CORAM: MADHABI PURI BUCH, WHOLE TIME MEMBER INTERIM ORDER Under Sections 11, 11(4), 11B (1) and 11D of the Securities and Exchange Board of India Act, 1992 In Re: Violation of provisions of Securities and Exchange Board of India (Investment Advisers) Regulations, 2013 In respect of:

Sr. Name of the Entities PAN No. 1 Suneel Kumar Patel DFQPP5370N

2 Duiji Patel PAN not available; Address: W/o Ram Khelavan Patel, Karaiya-Post, Hinauta Gajgauna, KaraiyaDevri, Satna, Madhya Pradesh-485774

1. Securities and Exchange Board of India (“SEBI”) received a complaint dated February 02, 2020 against Goodwill Research (“Goodwill”) alleging that it is involved in unauthorized Investment Advisory activities. 2. In view of the complaint received, SEBI carried out a preliminary examination to ascertain whether unregistered investment advisory activities are being carried out by Goodwill. To that end the website of Goodwill i.e. www.goodwillresearch.in and particulars of its bank accounts were perused to gather information. It is noted that above website is not active however, the print out of the web pages of the website were taken when it was active, and have been placed on record.

Interim Order in respect of Mr. Suneel Kumar Patel and Ms. Duiji Patel

3. SEBI’s preliminary examination found as follows: i. As per the information mentioned on the website, the entity is providing advisory services to the investors who subscribe to their packages mentioned on the website. ii. As per the Bank details mentioned on the website, entity is having bank account with ICICI Bank (Account Number: 004101575680) in the name of Mr. Suneel Kumar Patel and another account is with State Bank of India in the name of Ms.Duiji Patel (Account number 34949510591). The said bank accounts are mentioned in the website for the purpose of receiving consideration for the services advertised to be rendered in the website. The beneficiaries of the website viz., www.goodwillresearch.in are Mr. Suneel Kumar Patel and Ms.Duiji Patel iii. Neither Mr. Suneel Kumar Patel nor Ms.Duiji Patel are registered with SEBI.

CONSIDERATION & PRIMA FACIE FINDINGS 4. I have perused the material available on record such as investor complaint, information available on the website www.goodwillresearch.in and information obtained from ICICI Bank and State Bank of India in the names of Mr. Suneel Kumar Patel and Ms.Duiji Patel respectively. A preliminary examination of the material available on record was made in order to verify whether Mr. Suneel Kumar Patel and Ms.Duiji Patel have offered investment advisory services and collected money from various investors without registration from SEBI. In this context, prima facie, the following issues arise for determination in the instant matter:

1) Whether Mr. Suneel Kumar Patel and Ms.Duiji Patel are holding themselves out and/or acting as investment advisers? 2) If answer to the aforesaid issue is in affirmative, whether Mr. Suneel Kumar Patel and Ms.Duiji Patel have, prima facie, violated any provisions of SEBI Act, 1992 (“SEBI Act) read with SEBI (Investment Advisers) Regulations, 2013 (“IA Regulations”)?

Interim Order in respect of Mr. Suneel Kumar Patel and Ms. Duiji Patel

3) If answers to Issue Nos. (1) & (2) are affirmative, who are responsible for the violations? 4) If answer to Issue No. (2) is in affirmative, whether urgent directions, if any should be issued against those who are responsible for the violations?

Issue No. 1: Whether Mr. Suneel Kumar Patel and Ms.Duiji Patel are holding themselves out and/or acting as investment advisers?

5. As regards the first issue, I note the following from the material available on record:

5.1 As per the information gathered from the website of Mr. Suneel Kumar Patel and Ms.Duiji Patel, the following claims are noted: “Goodwill Research, a trusted name in the financial research services who provides you with the entire gamut of financial research services under one hub. It is one of the few organizations providing research and information on Indian capital markets mainly based on Technical Analysis and enjoys a strong reputation amongst investors, brokers and researchers. Our team is highly skilled with experienced analysis. Our efforts are to provide you more & more profit in every trade Welcome to Goodwill Research Its India’s most popular best commodity advice tips, MCX Tips, We are making money for you by our calls by an expert, We Support to our Client to take MCX Live Calls, live mcx, world market, forex signal”

5.2 Mr. Suneel Kumar Patel and Ms.Duiji Patel through their website are offering services of commodities, equity service, HNI service, forex trading through its website.

5.3 The pricing for the products mentioned on its website are given below:

Sl no Product Monthly Quarterly Half Yearly package Package Yearly Package In Rs. In Rs. Package In Rs. In Rs.

Interim Order in respect of Mr. Suneel Kumar Patel and Ms. Duiji Patel

1 Stock cash 21500 65000 81700 95000 2 Premiium cash 60000 250000 450000 780000 3 Intra day future 10000 25000 30000 50000 4 HNI Future 25000 60000 80000 100000 5 Premium Future 50000 115000 220000 350000 6 Call and put option 7000 20000 35000 50000 7 Premium option 50000 110000 220000 350000 8 Premium HNI 35000 51000 75000 110000

From the above, it is seen that Mr. Suneel Kumar Patel and Ms.Duiji Patel charge amounts from its clients through various service packages ranging from Rs. 7,000/- to Rs. 7,80,000/-per service package.

6. The bank details mentioned on website for receiving payments from clients are as under: Bank account 1 Bank account 2 Name: Suneel Kumar Patel Name: Duiji Patel Bank: ICICI Bank Bank: State Bank of India Account number: 004101575680 Account number: 34949510591 Type of account: Savings Type of account: Savings IFSC: ICIC0000041 IFSC: SBIN0000417 Branch: Malviya Parisar, Indore

7.1 The following information is gathered from the bank account statements:

7.1.1 It is observed that there are numerous UPI payments have been made into these accounts. 7.1.2 From the following narratives of the transactions in the ICICI Bank account in the name of Mr. Suneel Kumar Patel, it appears that the payments have, prima facie, come from various investors / clients. Credit Amount Date of transaction Narration In Rs. BIL/INFT/001758367248/MIB- 22-07-2019 Advisory/ 1200.00 BIL/INFT/001663954835/Investment/ 15-03-2019 /ICICI 3000.00 03-06-2019 BIL/INFT/001722603799/Investment/ 5000.00

Interim Order in respect of Mr. Suneel Kumar Patel and Ms. Duiji Patel

Credit Amount Date of transaction Narration In Rs. 07-06-2019 BIL/INFT/001725792925/Investment/ 10000.00 13-06-2019 BIL/INFT/001730298729/Investment/ 7000.00

7.1.3 Similarly, credit transactions for commodity market services have been noted in the Bank account of Ms.Duiji Patel. 7.1.4 At this stage there is no sufficient material on record to determine the total amount collected as fee for the services mentioned in the website and the same requires further examination.

8. Considering the above analysis of the details on the website of Mr. Suneel Kumar Patel and Ms.Duiji Patel and information from the accounts opened with the Banks mentioned above, I, prima facie, observe that Mr. Suneel Kumar Patel and Ms.Duiji Patel have represented through their website that it is an investment advisory firm for advice on stocks and commodity markets.

9. It is, prima facie, observed that Mr. Suneel Kumar Patel and Ms.Duiji Patel are placing information in public domain/ advertising by using its website www.goodwillresearch.in about various services offered by it in the securities market. Further, it is also, prima facie, observed that various packages are being offered by Mr. Suneel Kumar Patel and Ms.Duiji Patel through its website to avail its services. The website categorically mentions “the advantages of availing its services in various fields of securities market” and the “independent advice” they offer to their clients in the securities market through telephone calls and SMSes. Considering the above facts and circumstances, especially the contents of the website of Goodwill coupled with the credit transactions in the Bank Accounts as detailed in preceding paragraphs, prima facie, there is evidence to indicate that the bank accounts have been used for receipt of fee for providing the services indicated on the website of Goodwill. 10. In this factual matrix, I have perused the definition of Investment Adviser as given in Regulation 2(m) of the IA Regulations, which states that Investment Adviser means “any

Interim Order in respect of Mr. Suneel Kumar Patel and Ms. Duiji Patel person, who for consideration, is engaged in the business of providing investment advice to clients or other persons or group of persons and includes any person who holds out himself as an investment adviser, by whatever name called”. Further, I have perused Regulation 2(l) of the IA Regulations which defines Investment Advice as “advice relating to investing in, purchasing, selling or otherwise dealing in securities or investment products, and advice on investment portfolio containing securities or investment products, whether written, oral or through any other means of communication for the benefit of the client and shall include financial planning.”

11. In light of the aforesaid definitions, it is observed from the contents of the website of Goodwill that Mr. Suneel Kumar Patel and Ms.Duiji Patel are holding itself out as investment adviser by prima facie offering to provide investment advice as defined under regulation 2(l) of IA Regulations by offering to give advice related to investing in, purchasing and selling in securities and is also offering various investment packages for subscription. Further, as noted from the said bank accounts that there are multiple credit entries which when seen together with the contents of the websites lead to, on preponderance of probability basis, that there is evidence to indicate that the said bank accounts have been used for receipt of fee for the investment advice given by Mr. Suneel Kumar Patel and Ms.Duiji Patel to its clients. Thus, prima facie, Mr. Suneel Kumar Patel and Ms.Duiji Patel are investment advisers as defined under regulation 2 (m) of IA Regulations.

12. Therefore, Mr. Suneel Kumar Patel and Ms.Duiji Patel have not only held themselves out as investment advisers but have also acted as investment advisers for consideration.

Issue No.2: If answer to the aforesaid issue is in affirmative, whether Mr. Suneel Kumar Patel and Ms.Duiji Patel have, prima facie, violated any provisions of SEBI Act read with IA Regulations?

Interim Order in respect of Mr. Suneel Kumar Patel and Ms. Duiji Patel

13. In order to ensure that the investors who receive investment advice are protected, it is imperative that any person carrying out investment advisory activities has to necessarily obtain registration from SEBI and conduct its activities in accordance with the provisions of SEBI Regulations. Section 12(1) of the Securities and Exchange Board of India Act, 1992 (“SEBI Act”) reads as under:

“No stock broker, sub-broker, share transfer agent, banker to an issue, trustee of trust deed, registrar to an issue, merchant banker, underwriter, portfolio manager, investment adviser and such other intermediary who may be associated with securities market shall buy, sell or deal in securities except under, and in accordance with, the conditions of a certificate of registration obtained from the Board in accordance with the regulations made under this Act:” Further, as per Regulation 3(1) of the SEBI (Investment Advisers) Regulations, 2013 (hereinafter referred to as the IA Regulations), the registration of the investment advisers is mandatory. It provides that, “On and from the commencement of these regulations, no person shall act as an investment adviser or hold itself out as an investment adviser unless he has obtained a certificate of registration from the Board under these regulations”.

14. The activities of Mr. Suneel Kumar Patel and Ms.Duiji Patel, as brought out from the various materials described above, seen in the backdrop of the aforesaid provisions show that Mr. Suneel Kumar Patel and Ms.Duiji Patel are holding themselves out and acting as investment advisers. However, no material is available on record to indicate that Mr. Suneel Kumar Patel or Ms. Duiji Patel are holding a certificate of registration as investment advisers. In this context, it is noted that neither Mr. Suneel Kumar Patel nor Ms. Duiji Patel in their individual capacity are registered with SEBI in any capacity. The characteristics and features of the business activity carried out by Mr. Suneel Kumar Patel and Ms.Duiji Patel, as discussed in the preceding issue, prima facie, leads to the conclusion that they are holding themselves out and acting as investment advisers without a certificate of registration.

Interim Order in respect of Mr. Suneel Kumar Patel and Ms. Duiji Patel

15. In my view, these activities/ representations without holding the certificate of registration as investment adviser is prima facie, in violation of Section 12(1) of SEBI Act read with Regulation 3(1) of the IA Regulations.

Issue No. 3: If answers to Issue Nos. (1) & (2) are affirmative, who are all responsible for the violations?

16. I note from the details mentioned on the website of Goodwill, that payments have to be made to the bank accounts in the name of Mr. Suneel Kumar Patel and/or Ms. Duiji Patel. The narrations of the transactions in these accounts shows that Mr. Suneel Kumar Patel and Ms. Duiji Patel are carrying out unregistered Investment advisory services in the name of Goodwill Research. Hence, in the present case, the activities carried out in the name of Goodwill Research are basically the activities of Mr. Suneel Kumar Patel and Ms. Duiji Patel. In view of the same, I find that Mr. Suneel Kumar Patel and Ms. Duiji Patel are jointly and severally liable for the acts done in the name of Goodwill Research.

Issue No. 4: If answer to Issue No. (2) is affirmative, whether urgent directions, if any should be issued against those responsible for the violations?

17. SEBI has a statutory duty to protect the interests of investors in securities and promote the development of, and to regulate, the securities market. Section 11 of the SEBI Act has empowered it to take such measures as it thinks fit for fulfilling its legislative mandate. The PFUTP Regulations and the IA Regulations have been formulated with the main objective of preventing fraud and regulating Investment Advisory Services to safeguard the interests of investors and hence registration of such activities with SEBI has been made mandatory. The IA Regulations, inter alia, seek to create a structure within which investment advisers will operate and also make them duly accountable for their investment advice by requiring investment advisers to comply with the criteria set out in the relevant provisions of the IA

Interim Order in respect of Mr. Suneel Kumar Patel and Ms. Duiji Patel

Regulations. The same is imperative for the protection of interests of investors and to safeguard the integrity of the securities market.

18. In the instant case, Mr. Suneel Kumar Patel and Ms.Duiji Patel are soliciting and inducing the investors to deal in securities market on the basis of investment advice, stock tips etc., prima facie, without having the requisite registration/certification as mandated under the IA Regulations. Further, it is noted from material available on record of that money has been credited to the Bank accounts mentioned on the website of Goodwill i.e., Bank Accounts of Mr. Suneel Kumar Patel and Duiji Patel during the period of examination. The account is active and can continue to be used to collect fees from unsuspecting investors.

19. Considering the facts and circumstances of the present matter and on the basis of the prima facie findings, it is necessary to take urgent preventive action in this matter and to take immediate steps to prevent Mr. Suneel Kumar Patel and Ms.Duiji Patel from collecting any more fees from the public and indulging in unauthorized investment advisory activities. I note that the investors can also reach them (+919753441770) through telephone also. Therefore, the threat of investors getting lured towards the unregistered activity of Mr. Suneel Kumar Patel and Ms.Duiji Patel in the securities market is still in existence and imminent. 20. It is noted that permitting the investors to receive an investment advisory service from an unregistered entity, in effect means, the same is received from the unqualified person without following the safeguards mentioned in the IA Regulations. An investor receiving a service from unregistered investment advisor vis-a-vis an investor who receives such service from a registered investment adviser in consonance with the IA Regulations stands at a disadvantageous position in respect of his protection as an investor as envisaged under the IA regulations. An unregistered investment adviser has not even satisfied the Regulator that he is a fit and proper person to hold the certificate of registration as investment adviser. Availing of service from such persons is detrimental to investors and such unqualified service would result in irreparable damage as the investors’ money is invested based on unqualified and un-regulated service. Exposing investors to such service also has the effect

Interim Order in respect of Mr. Suneel Kumar Patel and Ms. Duiji Patel of interfering with the development of securities market, as victims of such services tend to lose faith in the securities market. Such an injury/detriment to the development of the securities market also qualifies as an “irreparable injury”. The objective of SEBI as enshrined in the SEBI Act is not only the protection of investors but also orderly development of securities market.

21. Further if an ex-parte order is not passed, many prospective investors may have to part with large fees and investments resulting into irreparable injury to themselves as discussed earlier. However, if an ex-parte order is passed, what is at stake is right of the current entity herein vis-a-vis multitude of prospective and current clients of the entity. It may be noted that one of the underlying differences between the ex-parte orders in the case of private suits and ex-parte public enforcement actions, is the identification of the injured party. In private damage suits, the injured individual, as “whole”, is identifiable whereas ex-parte public enforcement actions, seeks to protect the floating multitude of investing public by preventing, continuous and imminent violations of the securities laws. Though, it can be argued that a final remedy by way of refund is available, as against the step of passing an ex-parte interim order, the potential loss of investment by the investors by following the advice from an unqualified person and resultant loss of investor’s confidence and reliability of securities market, cannot be retrieved, if prima facie unregistered investment advice is permitted to be extended to the investors by not passing an exparte-interim order at this stage. Therefore, I consider the balance of convenience is also not in favour of the entities.

22. Considering the facts and circumstances of the present matter and on the basis of the prima facie findings, it is necessary to take urgent preventive action in this matter and to take immediate steps to prevent Mr. Suneel Kumar Patel and Ms. Duiji Patel from collecting any more fees from the public and from indulging in unauthorized investment advisory activities.

23. In light of the same, I find that there is no other alternative but to take recourse through an interim ex-parte order against Mr. Suneel Kumar Patel and Ms. Duiji Patel for preventing them from collecting funds by indulging in unauthorized investment advisory services

Interim Order in respect of Mr. Suneel Kumar Patel and Ms. Duiji Patel without obtaining the mandatory registrations from SEBI in accordance with the law. As the bank account of Mr. Suneel Kumar Patel and Ms.Duiji Patel are still active, the balance of convenience demands the preventive measure of stopping the collection of money in the bank accounts of Mr. Suneel Kumar Patel and Ms. Duiji Patel from investors. The same can be effectively achieved by an appropriate direction of stopping the credit into the said bank accounts of Mr. Suneel Kumar Patel and Ms. Duiji Patel. As Mr. Suneel Kumar Patel and Ms. Duiji Patel have already evaded the jurisdiction of SEBI by prima facie, acting as unregistered investment advisers, the balance of convenience also demands that Mr. Suneel Kumar Patel and Ms. Duiji Patel need to be prevented from diverting the funds collected from the investors through unauthorized investment advisory activity. Accordingly, an appropriate direction stopping the debit from the bank accounts of Mr. Suneel Kumar Patel and Ms. Duiji Patel have been incorporated. 24. With the initiation of quasi-judicial proceedings, given the fact that Mr. Suneel Kumar Patel and Ms. Duiji Patel have already evaded the jurisdiction of SEBI by prima facie, acting as unregistered investment advisers, it is imminent that the Noticees may divert the money collected from the subscribers / clients.

The same may result in defeating the effective implementation of the direction of refund, if any, to be passed after deciding the matter on merits. It therefore becomes necessary for SEBI to take urgent steps to prevent Noticees from diverting the money collected from the subscribers / clients. It is also essential to take urgent steps to prevent them from alienating any assets, whether movable or immovable, or any interest or investment or charge in any of such assets, so that the final remedies, if any, do not become infructuous. In view of the facts and circumstances discussed hereinabove, and considering the interests of already existing clients of these Noticees and also the interests of those who may fall prey to the unregistered investment advisory by reaching him through telephone calls, the balance of convenience lies against the Noticees, and requires immediate action against it including not to divert the money collected from the subscribers / clients / investors. 25. I note that at this stage there is not enough information available to determine the total amount credited/ collected in the bank accounts belonging to Mr. Suneel Kumar Patel and Ms.Duiji Patel as fee for the unregistered investment advisory activities, although, there

Interim Order in respect of Mr. Suneel Kumar Patel and Ms. Duiji Patel is, prima facie, evidence that its bank accounts are being used for receiving payments from the investors for the same. Hence, SEBI is directed to ascertain the quantum of fee collected in these bank accounts. Thereafter, SEBI shall issue additional Show Cause Notice directing to show cause why the amount collected by Mr. Suneel Kumar Patel and Ms.Duiji Patel, as fee for investment advisory services not be refunded to the investors. Appropriate direction in this regard is incorporated.

Order

26. In view of the above, pending conclusion of enquiry on granting of hearing opportunity to Mr. Suneel Kumar Patel and Ms. Duiji Patel, I, in exercise of the powers conferred upon me by virtue of Section 19 read with Sections 11, 11(4), 11B(1) and 11D read with Section 19 of the SEBI Act, 1992, hereby issue by way of this interim ex-parte order, the following directions:

26.1Mr. Suneel Kumar Patel and Ms. Duiji Patel are directed to:

i. Cease and desist from acting as an investment advisor including the activity of acting and representing through any media (physical or digital) as an investment advisor, directly or indirectly, and cease to solicit or undertake such activity or any other activities in the securities market, directly or indirectly, in any matter whatsoever, until further orders. ii. Not to divert any funds raised from investors, kept in bank account(s) and/or in their custody until further orders. iii. Not to dispose of or alienate any assets, whether movable or immovable, or any interest or investment or charge on any of such assets held in their name, including money lying in bank accounts except with the prior permission of SEBI. iv. Immediately withdraw and remove all advertisements, representations, literatures, brochures, materials, publications, documents, communications etc. physical or Interim Order in respect of Mr. Suneel Kumar Patel and Ms. Duiji Patel digital in relation to their investment advisory activity or any other unregistered activity in the securities market until further orders. v. Not to access the securities market and buy, sell or otherwise deal in securities in any manner whatsoever, directly or indirectly, until further orders. vi. To provide a full inventory of all assets held in their name, whether movable or immovable, or any interest or investment or charge on any of such assets, including details of all bank accounts, demat accounts and mutual fund investments, immediately but not later than 5 working days from the date of receipt of this order. vii. To submit the number and details of clients who have availed their investment advisory services and to submit details of fees collected from each such client, immediately but not later than 5 working days from the date of receipt of this order.

26.2 If Mr. Suneel Kumar Patel/Ms. Duiji Patel have any open positions 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. Mr. Suneel Kumar Patel/Ms. Duiji Patel 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.

26.3 ICICI Bank (Account Number:004101575680) and State Bank of India (Account Number: 34949510591) wherein Mr. Suneel Kumar Patel and Ms. Duiji Patel are holding bank accounts are directed not to allow any debits/ withdrawals from and not to allow any credits to the said accounts, without the permission of SEBI. The above Banks are directed to ensure that all the above directions are strictly enforced. 26.4 The Depositories are directed to ensure, till further directions, that they neither permit any debits nor any credits in the demat accounts held by: a. Mr. Suneel Kumar Patel either individually or jointly, b. Ms. Duiji Patel either individually or jointly.

Interim Order in respect of Mr. Suneel Kumar Patel and Ms. Duiji Patel

26.5 The Registrar and Transfer Agents are directed to ensure, till further directions, that they neither permit any transfer nor redemption of the securities, including Mutual Fund units, held by: a. Mr. Suneel Kumar Patel either individually or jointly, b. Ms. Duiji Patel either individually or jointly.

27. This Order shall also be treated as a Show Cause Notice and Mr. Suneel Kumar Patel and Ms. Duiji Patel are show caused as to why the investment advisory plans floated by them should not be held as “Investment Advisory Services” in terms of the IA Regulations and thereby the activity of Mr. Suneel Kumar Patel and Ms.Duiji Patel not be treated as unregistered activity under the SEBI Act and relevant Regulations.

28. Mr. Suneel Kumar Patel and Ms. Duiji Patel are also show caused as to why appropriate directions, under Sections 11, 11(4), 11B(1) and 11D of the SEBI Act and relevant SEBI Rules/Regulations, including appropriate directions for the prohibition on them from buying, selling or otherwise dealing in securities market, either directly or indirectly, in any manner whatsoever, for a particular period, and directions not to be associated with any listed public company and any public company which intends to raise money from the public, or any intermediary registered with SEBI for a particular period should not be passed against them.

29. SEBI, after ascertaining the quantum of fee collected in the bank accounts of Mr. Suneel Kumar Patel and Ms.Duiji Patel for refund, shall issue additional Show Cause Notice directing to show cause why the amount collected by Mr. Suneel Kumar Patel and Ms.Duiji Patel, as fee for investment advisory services, should not be refunded to the investors/ clients/ subscribers.

30. The prima facie observations contained in this Order are made on the basis of the material available on record. In this context, Mr. Suneel Kumar Patel and Ms. Duiji Patel may file their objections, if any, within 21 (twenty-one) days from the date of service of this Order

Interim Order in respect of Mr. Suneel Kumar Patel and Ms. Duiji Patel and, if so desire, avail an opportunity of personal hearing before SEBI, on a date and time to be fixed on a specific request to be made in that regard.

31. This order shall come into force with immediate effect and shall be in force until further orders. This Order is without prejudice to the right of SEBI to take any other action that may be initiated against the aforementioned entity in accordance with law.

32. A copy of the order shall be served upon Mr. Suneel Kumar Patel and Ms. Duiji Patel, ICICI Bank, SBI, Stock Exchanges, Depositories and Registrar and Transfer Agents for necessary action and compliance with the above directions.

Date: December 16, 2020 MADHABI PURI BUCH Place: Mumbai WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA

Interim Order in respect of Mr. Suneel Kumar Patel and Ms. Duiji Patel