Interim order in the matter of price fall in certain scrips on July 26, 2012

DIRECTIONS UNDER SECTIONS 11 AND 11B OF THE SECURITIES AND EXCHANGE BOARD OF INDIA ACT, 1992 IN THE MATTER OF TRADING IN THE SCRIPS OF PIPAVAV DEFENCE AND OFFSHORE ENG. LIMITED, PARSVNATH DEVELOPERS LIMITED, TULIP TELECOM LIMITED AND GLODYNE TECHNOSERVE LIMITED ON JULY 26, 2012. 1. On July 26, 2012, Securities and Exchange Board of India (SEBI) noticed a downward movement in prices of certain scrips as compared to their closing prices on July 25, 2012 at the National Stock Exchange of India (NSE) and Bombay Stock Exchange Limited (BSE). The percentage of such price variation in those scrips at NSE and BSE was noted as under: Table 1: Price variation Scrip % price variation BSE NSE Pipavav Defence and Offshore Eng. Ltd. -19.96 -19.99 Parsvnath Developers Ltd -19.91 - 19.93 Tulip Telecom Ltd. - 25.97 - 26.02 Glodyne Technoserve Ltd. - 19.98 - 19.99

2. It is noted that the prices of the above scrips had seen a sharp downward movement within the time from 09:15 to 09:49 on July 26, 2012 as enumerated below. Table 2: Time Slots of price fall Scrip Time Slot (NSE) Time Slot (BSE) Pipavav Defence and Offshore Eng. Ltd. 09:15 to 09:35 09:32:35 to 09:35:15 Parsvnath Developers Ltd. 9:35:47 to 9:42:47 09:36:06 to 09:41:20 Tulip Telecom Ltd. 9:40:00 to 9:49:00 09:32:30 to 09:47;32 Glodyne Technoserve Ltd. 09:15:09 to 09:29:51 09:15:54 to 09:23:45

3. During 15 days prior to July 26, 2012, no corporate announcements/price sensitive information was disclosed to the stock exchanges by the aforesaid companies which could have impacted the share prices negatively. However, on July 26,2012, at NSE and BSE both similar sharp intra-day price volume movement in the above scrips was observed. For illustration, the intra-day price volume movement of the above scrips at NSE is as follows:

Pipavav Defence and Offshore Eng Limited.

Parsvnath Developers Limited

Tulip Telecom Limited

Glodyne Technoserve Limited.

. 4. The trading activity of major clients on the basis of net sell at NSE and BSE on July 26, 2012 (during the price fall period) in aforesaid scrips was analyzed by NSE and BSE, respectively. It was observed that some of these clients were not only common across the above scrips but they also traded on both the exchanges. The top identified clients whose sell volume constituted a significant share of the total sale transactions in those scrips at NSE and BSE during the price fall period are as under: Table 3: Top net sellers during the price fall period Exchange Client Name Client PAN Net Sell % to market quantity Net Pipavav Defence and Offshore Eng. Limited NSE Manish Agarwal APLPA3819B 151,843 38.37 NSE Umang Nemani ABOPN7213K 145,165 36.68 NSE Narayan Sriram Investments Pvt Ltd AAACN1115A 50,000 12.63 BSE Manish Agarwal APLPA3819B 199309 33.58 BSE Umang Nemani ABOPN7213K 50000 8.43 Parsvnath Developers Limited NSE Gajria Jayna Precision Industries Pvt Ltd AABCG5915E 158557 51.15 NSE Manish Agarwal APLPA3819B 100000 32.26 NSE Neelanchal Mercantile Pvt Ltd AAACN8842N 20000 6.45 NSE Kuvam Plast Private Limited AADCK8653K 17799 5.74 BSE Ravinder Shroff AAUPS0285M 35002 16.46 BSE Neelanchal Mercantile Pvt Ltd AAACN8842N 20000 9.4 BSE Manish Agarwal APLPA3819B 11208 5.27 Glodyne Technoserve Limited NSE Umang Nemani ABOPN7213K 25000 37.21 NSE Ramkripa Securities Pvt Ltd AADCR3436K 10292 15.32 NSE Yashika Holding Pvt. Ltd. AAACY0171H 10000 14.89 NSE Littlestar Vanijya Private Limited AABCL2630H 10000 14.89 NSE White Horse Trading Company Private AAACW8451G 4064 6.05 Limited BSE Ramkripa Securities Pvt Ltd AADCR3436K 21100 53.35 BSE Umang Nemani ABOPN7213K 2081 5.26

Exchange Client Name Client PAN Net Sell % to market quantity Net Tulip Telecom Limited NSE Ajit Kumar Jain ACNPJ9264G 200000 25.46 NSE Passion System Solutions Private Limited AAECP3609F 113000 14.39 NSE Gajria Jayna Precision Industries Pvt Ltd AABCG5915E 90000 11.46 BSE Ajit Kumar Jain ACNPJ9264G 90000 28.14 BSE Manish Agarwal APLPA3819B 50000 15.63

5. From the above table, it is observed that the net sell by the above mentioned top clients during the price fall period in each scrip was in the range of 51% to 95% of total market net sell at NSE and 31% to 58% of total market net sell at BSE.

6. The observations of the analysis carried out by the NSE and BSE in these scrips are described in the following paragraphs.

7. Observations with regard to Pipavav Defence and Offshore Eng Limited a. Observations of NSE i. During the day, client Mr. Manish Agarwal placed 11 sell orders (all limit orders) with original sell volumes ranging between 735 and 300,000 shares and disclosed volumes ranging from fully disclosed to partly disclosed. During the period between 9:15:00 to 9:35:00, it was observed that he had placed 4 sell limit orders ranging between -2.84% and 0.15% of the Last Traded Price (LTP), each with original volume of 50,000 shares with disclosed quantity of 5000 shares. ii. Mr. Manish Agarwal trading through Nirmal Bang Securities Private Limited sold 1.51 Lac Shares during 9:32:15 AM - 9:34:53 AM which accounted 14.84% of gross market sale and 44.61% of net market sale. Price of the scrip moved in the range of Rs. 77.75 to Rs. 63.60 and his trades were executed in the price range of Rs. 77.75 to Rs. 65.00. iii. During the day, Mr. Umang Nemani placed 5 sell orders (all limit orders) with original sell volumes ranging between 50,000 and 200,000 shares and the orders were fully disclosed. During the period between 9:15:00 to 9:35:00, it was observed that he had placed 2 sell limit order ranging between -1.23% and -4.15% of the LTP with original volumes ranging between 50000 to 100000 shares and the orders were fully disclosed. iv.

Mr. Umang Nemani trading through Kotak Securities Ltd. net sold 1.45 lac shares during 9:34:06 AM - 9:34:59 AM which accounted 18.01% of gross market sale and 48.26% of net market sale. Price of the scrip moved in the range of Rs. 69.80 to Rs. 63.60 and his trades were executed in the price range of Rs. 69.80 to Rs. 64.00. b. Observations of BSE i. Mr. Manish Agarwal trading through Nirmal Bang Securities Pvt. Ltd. sold 1.99 Lac shares during 09:33:06 AM to 09:34:45 AM which accounted for 33.58% of the total market volume. Price of the scrip moved in the range of Rs.77.65 to Rs.62.15 and his trades were executed in the price range of Rs.75.75 to Rs.65. ii. Mr. Umang Nemani trading through Kotak Securities Limited sold 50000 shares during 09:34:45 AM to 09:34:53 AM which accounted 8.43% of total market volume. Price of the scrip moved in the range of Rs.77.65 to Rs.62.15 and his trades were executed in the price range of Rs.65 to Rs.64. 8. Observations with regard to Parsvnath Developers Ltd. a. Observations of NSE i. Mr. Neelanchal Mercantile Pvt. Ltd. trading through IFCI Financial Services Limited had placed 3 sell orders (2 limit orders and 1 market order) with original sell volumes ranging between 8985 and 15000 shares and with entire quantity disclosed.

It was observed that all orders were placed during the time patch 9:35:47 and 9:42:47. ii. Mr. Neelanchal Mercantile Pvt Ltd trading through IFCI Financial Services Limited sold 20,000 shares during 9:36:46 AM to 9:39:09 AM which accounted 9.64% of gross market sale and 31.86% of net market sale. Price of the scrip moved in the range of Rs.55.00 to Rs.48.05 and this client trades were executed in the price range of Rs.53.75 to Rs. 48.05. iii. Mr. Gajria Jayna Precision Industries Pvt. Ltd. trading through Edelweiss Securities Limited had placed 3 sell orders (all market orders) with original sell volumes ranging between 40,000 and 174,000 shares (entire volume of 174,000 was fully disclosed). It was observed that all sell orders were placed during the time patch 09:38:36 AM to 09:40:37 AM. iv. Mr. Gajria Jayna Precision Industries Pvt Ltd trading through Edelweiss Securities Limited sold 1.58 Lac shares during 9:39:34 AM to 9:40:39 AM which accounted 32.95% of gross market sale and 84.96% of net market sale. Price of the scrip moved in the range of Rs.53.35 to Rs.46.20 and his trades were executed in the price range of Rs.53.00 to Rs. 46.20. v. Mr. Manish Agarwal trading through Nirmal Bang Securities Pvt Ltd had placed 2 sell orders (all limit orders) with original sell volume of 100,000 shares per order and with entire quantity disclosed.

Out of these 2 orders during the time patch 09:41:01 AM to 09:44:56 AM, first order was placed with sell order level LTP variation of -4.74%. vi. Mr. Manish Agarwal trading through Nirmal Bang Securities Limited sold 1 Lac shares during 9:41:01 AM to 9:41:45 AM which accounted 49.43% of gross market sale and 100% of net market sale. Price of the scrip moved in the range of Rs.48.05 to Rs.46.20 and his trades were executed in the price range of Rs.48.05 to Rs. 46.20. vii. Kuvam Plast Private Limited trading through Kaynet Finance Limited sold 17,799 shares during 9:40:05 AM to 9:40:42 AM which accounted 10.92% of gross market sale and 27.84% of net market sale. Price of the scrip moved in the range of Rs.52.05 to Rs.46.20 and this client trades were executed in the price range of Rs.52.00 to Rs.49.00. b. Observations of BSE i. Neelanchal Mercantile Pvt. Ltd. trading through IFCI Financial Services Limited sold 20,000 shares during 09:36:44 AM to 09:39:08 AM which accounted 9.40% of gross market sale. Price of the scrip moved in the range of Rs. 57.30 to Rs. 46.25 and this client trades were executed in the price range of Rs. 54.35 to Rs. 50. ii.

Mr. Manish Agarwal trading through Nirmal Bang Securities Pvt. Ltd. sold 11,208 shares at 09:41:20 AM which accounted 5.27% of gross market sale Price of the scrip moved in the range of Rs. 57.30 to Rs. 46.25 and his trades were executed in the price range of Rs.46.60 to Rs. 46.25. 9. Observations with regard to Glodyne Technoserve Limited a. Observations of NSE i. White Horse Trading Company Private Limited trading through Basant Securities Ltd. sold 4064 shares during 9:16:09 AM to 9:21:02 AM which accounted 19.95% of gross market sale and 63.22% of net market sale. Price of the scrip moved in the range of Rs. 337.30 to Rs. 330.10 and this client trades were executed in the price range of Rs. 337.00 to Rs. 330.50. ii. Yashika Holding Pvt. Ltd. trading through Basant Securities Ltd. sold 10343 shares during 9:17:03 AM to 9:24:09 AM which accounted 9.08% of gross market sale and 34.95% of net market sale. Price of the scrip moved in the range of Rs. 337.30 to Rs. 274.20 and this client trades were executed in the price range of Rs. 337.30 to Rs. 275.00. iii. Ramkripa Securities Pvt. Ltd. trading through A. G. Shares & Securities Ltd. sold 10292 shares during 9:22:17 AM to 9:29:46 AM which accounted 7.11% of gross market sale and 26.19% of net market sale.

Price of the scrip moved in the range of Rs. 320.40 to Rs. 274.20 and this client trades were executed in the price range of Rs. 320.40 to Rs. 274.20. iv. Mr. Umang Nemani trading through Citigroup Global Markets India Pvt. Ltd. sold 25000 shares during 9:23:23 AM to 9:29:48 AM which accounted 16.65% of gross market sale and 48.46% of net market sale. Price of the scrip moved in the range of Rs. 293.70 to Rs. 274.20 and his trades were executed in the price range of Rs. 293.70 to Rs. 274.20. v. Littlestar Vanijya Private Limited trading through UPSE Securities Limited sold 10000 shares during 9:29:48 AM to 9:29:51 AM which accounted 23.92% of gross market sale and 47.85% of net market sale. Price of the scrip was at Rs. 274.20 and this client trades were executed at Rs. 274.20. vi. The clients Umang Nemani, Yashika Holding Pvt. Ltd. and White Horse Trading Company Private Limited contributed to the price fall by placing sale orders at or below LTP. The following are the details of the order log analysis for the aforesaid clients: Table 4: Order log analysis Client Name No of No of Sell No of Sell Percentage Min of Max of Sell Limit Limit orders order placed Order Order Limit orders placed & at or below LTP% LTP% orders placed & executed at & LTP placed executed below LTP White Horse Trading 16 16 9 56.25% (0.80%) 9.41% Company Pvt Ltd Yashika Holding Pvt. Ltd 4 4 4 100.00% (18.46%) 0.22% Umang Nemani 3 1 1 100.00% (13.77%) 0.00% vii.

Further from the analysis of order-trade data, the following were observed. a) During the time slot 9:16:09 AM to 9:21:02 AM White Horse Trading Company Private Limited trading through Basant Securities Ltd had placed 16 sell limit orders with original sell volumes ranging between 1 and 10,000 shares with disclosed volumes ranging between fully disclosed and 100 shares. These orders were placed at prices ranging between -0.80% and 9.41% of the LTP and out of 16 sell limit orders, 9 orders were placed at or below LTP. The client alone sold 4064 shares during 9:16:09 AM to 9:21:02 AM contributing 63.22% of net market sale. b) During the time slot 9:21:50 AM, to 9:24:09 AM, Yashika Holding Pvt. Ltd. trading through Basant Securities Ltd had placed 4 sell limit orders with original sell volumes ranging between 1 and 10000 shares with disclosed volumes ranging between fully disclosed and 200 shares. These orders were placed at prices ranging between -18.46% and 0.22% of the LTP and out of 4 sell limit orders, all orders were placed at or below LTP. The client sold 10,000 shares during 9:21:50 AM to 9:24:09 AM and contributing 40.46% of net market sale.

The price of the scrip moved from a high of Rs.337.30 to a low of Rs.275.00. c) During the time slot 9:23:40 AM to 9:24:14 AM, Umang Nemani trading through Citigroup Global Markets India Pvt. Ltd. had placed 2 sell limit orders with original sell volumes ranging between 1 and 25000 shares with fully disclosed volumes. These orders were placed at prices ranging between -13.77% to 0% of the LTP and both the sell limit orders were placed at or below LTP. The client sold 4939 shares during this slot contributing 32.14% of net market sale. The price of the scrip moved from a high of Rs.293.70 to low of Rs.274.20. b. Observations of BSE i. White Horse Trading Company Private Limited trading through Networth Portfolio and Finance sold 1142 shares during 09:15:54 AM to 09:21:15 AM contributing 2.89% of gross market sale. ii. Ramkripa Securities Pvt. Ltd. trading through Seema Securities Pvt. Ltd. and Networth Portfolio and Finance sold 21100 shares during 09:17:03 AM to 09:23:45 AM which accounted 53.34% of gross market sale. Price of the scrip moved in the range of Rs.337 to Rs.273.60 and this client trades were executed in the price range of Rs.336.05 to Rs.274.70. iii.

Mr. Umang Nemani trading through Citigroup Global Markets sold 2081 shares during 09:23:22 AM to 09:23:33 AM which accounted 5.26% of gross market sale. Price of the scrip moved in the range of Rs.337 to Rs.273.60 and his trades were executed at Rs.292. 10. Observations with regard to Tulip Telecom Limited a. Observations of NSE i. Mr. Ajit Kumar Jain trading through Nirmal Bang Securities Pvt. Ltd. sold 2 Lac shares during 9:41:43 AM to 9:47:32 AM which accounted 11.04% of gross market sale and 32.16% of net market sale. Price of the scrip moved in the range of Rs. 116.90 to Rs. 63.65 and his trades were executed in the price range of Rs. 116.90 to Rs. 65.00. ii. During the day, Mr. Ajit Kumar Jain had placed 2 sell limit orders at 9:41:43 (limit order) and 9:47:21 (market order) with sell original volume ranging between 45917 shares to 100000 shares (full disclosed quantity). The sell limit order was originally placed with sell order LTP of 5.98%. The said order was modified thrice by the client with sell LTP of ranging -18.80% to -31.62% respectively. iii. Mr. Manish Agarwal had placed only one sell order with at 9:35:44 with sell original volume ranging of 50000 shares.

The said order was modified four times with sell order LTP ranging -1.06% to -36.58%. iv. Mr. Manish Agarwal trading through Nirmal Bang Securities Pvt. Ltd. sold 24,672 shares during 9:41:11 AM to 9:46:37 AM which accounted 2.41% of gross market sale and 6.63% of net market sale. Price of the scrip moved in the range of Rs. 117.00 to Rs. 76.65 and his trades were executed in the price range of Rs. 117.00 to Rs. 77.30. v. During the day, Gajria Jayna Precision Industries Pvt. Ltd. had placed 5 sell orders out of which 3 sell orders were placed at 9:37:08 (marker order), 9:43:35 and 9:47:50 (limit order) with sell original volume ranging between 32238 shares to 50000 shares. The sell limit orders were placed with sell order LTP ranging between -0.96% to -17.74%. vi. Gajria Jayna Precision Industries Pvt. Ltd. trading through Edelweiss Securities Limited sold 90,000 shares during 9:42:02 AM to 9:48:03 AM which accounted 4.26% of gross market sale and 12.61% of net market sale. Price of the scrip moved in the range of Rs. 106.10 to Rs. 63.65 and this client trades were executed in the price range of Rs. 106.00 to Rs. 71.00.

vii. Passion System Solution Pvt. Ltd. trading through Fairwealth Securities Pvt. Ltd sold 1.13 Lac shares during 9:44:29 AM to 9:47:21 AM which accounted 8.76% of gross market sale and 25.97% of net market sale. Price of the scrip moved in the range of Rs. 87.75 to Rs. 68.20 and this client trades were executed in the price range of Rs. 86 to Rs. 72. viii. Kran Properties Private Limited trading through Religare Securities Ltd. sold 79,586 shares during 9:44:35 AM to 9:47:44 AM which accounted 4.99% of gross market sale and 14.80% of net market sale. Price of the scrip moved in the range of Rs. 86.50 to Rs. 63.35 and this client trades were executed in the price range of Rs. 85.25 to Rs. 70. b. Observations of BSE i. Mr. Manish Agarwal trading through Nirmal Bang Securities Pvt. Ltd. sold 50,000 shares during 09:35:54 AM to 09:38:22 AM which accounting 15.63% of total market volume. Price of the scrip moved in the range of Rs.118.55 to Rs.65.65 and his trades were executed in the price range of Rs.116.55 to Rs.115. ii. Mr. Ajit Kumar Jain trading through the trading member, Nirmal Bang Securities Pvt. Ltd. sold 90,000 shares during 09:41:59 AM to 09:46:55 AM which accounted 28.14% of the total market volume.

Price of the scrip moved in the range of Rs.118.55 to Rs.65.65 and his trades were executed in the price range of Rs.107 to Rs.71.40. 11. A summary of the sell orders placed by those clients on July 26,2012 is as under: Table 5: Summary of the sell order placement SE Client Name Traded Total sell Total Total % to Price Price time order market traded market variation variation range by quantity traded quantity of gross range by the client placed by quantity the client during the client during the the client during the during the sub patch during the sub patch during the sub patch sub patch of time sub patch of time sub patch of time of time of time of time Glodyne Technoserve Limited BSE Ramkripa Securities 09:17:03 to 89600 39554 21100 53.34 Rs.337 to Rs.336.05 to Pvt Ltd 09:23:45 Rs.273.60 Rs.274.70 BSE Umang Nemani 09:23:22 to 50000 39554 2081 5.26 Rs.337 to Rs.292 to 09:23:33 Rs.273.60 Rs.292 BSE White Horse Trading 09:15:54 to 1400 39554 1142 2.89 Rs.337 to Rs.338 to Company Private 09:21:15 Rs.273.60 Rs.332 Limited NSE White Horse Trading 9:16:09 to 9658 10186 4064 19.95 Rs. 337.30 Rs. 337.00 Company Private 9:21:02 to Rs. to Rs. Limited 330.10 330.50 NSE Yashika Holding Pvt. 9:17:03 to 3500 56934 10343 9.08 Rs. 337.30 Rs. 337.30 Ltd. 9:24:09 to Rs. to Rs. 274.20 275.00

SE Client Name Traded Total sell Total Total % to Price Price time order market traded market variation variation range by quantity traded quantity of gross range by the client placed by quantity the client during the client during the the client during the during the sub patch during the sub patch during the sub patch sub patch of time sub patch of time sub patch of time of time of time of time NSE Littlestar Vanijya 9:29:48 to 0 20900 10000 23.92 Rs. 274.20 Rs. 274.20 Private Limited 9:29:51 to Rs. to Rs. 274.20 274.20 NSE Ramkripa Securities 9:22:17 to 27000 72356 10292 7.11 Rs. 320.40 Rs. 320.40 Pvt Ltd 9:29:46 to Rs. to Rs. 274.20 274.20 NSE Umang Nemani 9:23:23 to 25000 75092 25000 16.65 Rs. 293.70 Rs. 293.70 9:29:48 to Rs. to Rs. 274.20 274.20 Parsvnath Developers Limited BSE Neelanchal 09:36:44 to 20000 212670 20000 9.4 Ra. 57.30 to Rs. 52.35 to Mercantile Pvt Ltd 09:39:08 Rs. 46.25 Rs. 50 BSE Manish Agarwal 9:41:20 100000 212670 11208 5.27 Ra. 57.30 to Rs.46.60 to Rs. 46.25 Rs. 46.25 NSE Neelanchal 9:36:46 to 20000 103681 20000 9.64 Rs.55.00 to Rs.53.75 to Mercantile Pvt Ltd 9:39:09 Rs. 48.05 Rs. 48.05 NSE Gajria Jayna Precision 9:39:34 to 214000 240632 158557 32.95 Rs. 53.35 to Rs. 53.00 to Industries Pvt Ltd 9:40:39 Rs. 46.20 Rs. 46.20 NSE Kuvam Plast Private 9:40:05 to 20000 81501 17799 10.92 Rs. 52.05 to Rs. 52.00 to Limited 9:40:42 Rs. 46.20 Rs. 49.0\20 NSE Manish Agarwal 9:41:01 to 100000 101160 100000 49.43 Rs. 48.05 to Rs. 48.05 to 9:41:45 Rs. 46.20 Rs. 46.20 Pipavav Defence and Offshore Eng.

Limited BSE Manish Agarwal 09:33:06 to 200000 593462 199309 33.58 Rs.77.65 to Rs.75.75 to 09:34:45 Rs.62.15 Rs.65 BSE Umang Nemani 09:34:45 to 50000 593462 50000 8.43 Rs.77.65 to Rs.65 to 09:34:53 Rs.62.15 Rs.64 NSE Umang Nemani 9:34:06 to 150000 402966 145165 18.01 Rs. 69.80 to Rs. 69.80 to 9:34:59 Rs. 63.60 Rs. 64.00 NSE Agarwal Manish 9:32:15 to 200000 511711 151843 14.84 Rs. 77.75 Rs. 77.75 to 9:34:53 to Rs. 63.60 Rs. 65.00 Tulip Telecom Limited BSE Ajit Kumar Jain 09:41:59 to 90000 319803 90000 28.14 Rs.118.55 Rs.107 to 09:46:55 to Rs.65.65 Rs.71.40 BSE Manish Agarwal 09:35:54 to 50000 319803 50000 15.63 Rs.118.55 Rs.116.55 to 09:38:22 to Rs.65.65 Rs.115 NSE Gajria Jayna Precision 9:42:02 to 80895 1057328 90000 4.26 Rs. 106.10 Rs. 106.00 Industries Pvt Ltd 9:48:03 to Rs. to Rs. 71.00 63.35 NSE Manish Agarwal 9:41:11 to 0 511515 24672 2.41 Rs. 117.00 Rs. 117.00 9:46:37 to Rs. 76.65 to Rs. 77.30

SE Client Name Traded Total sell Total Total % to Price Price time order market traded market variation variation range by quantity traded quantity of gross range by the client placed by quantity the client during the client during the the client during the during the sub patch during the sub patch during the sub patch sub patch of time sub patch of time sub patch of time of time of time of time NSE Ajit Kumar Jain 9:41:43 to 200000 906043 200000 11.04 Rs. 116.90 Rs. 116.90 9:47:32 to Rs.63.35 to Rs.65.00 NSE Passion System 9:44:29 to 50000 644955 113000 8.76 Rs. 87.75 to Rs. 86.00 to Solution Pvt Ltd 9:47:21 Rs. 68.20 Rs. 72.00

12. From the above table, it is observed that Mr. Umang Nemani placed sell orders in the scrip of Pipavav Defence and Offshore Eng. Ltd. after the sell orders placed by Mr. Manish Agarwal in the said scrip got executed. Similarly, Mr. Manish Agarwal placed sell orders in the scrip of Parsvnath Developers Ltd after the sell orders placed by Neelanchal Mercantile Pvt. Ltd. got executed. 13. It has also been observed that while the clients were selling during the day the entity related to them viz. Neelanchal Mercantile Pvt. Ltd. purchased a large quantity of shares of Pipavav Defence and Offshore Eng. Ltd. The details of such purchases are as under: Table 6: Counterparties of Neelanchal Mercantile Pvt. Ltd. in the scrip of Pipavav Defence and Offshore Eng Ltd Client Name Quantity Total quantity sold % of total sold by seller on SE sell BSE Premium Hospitality Services Private Limited 150000 173500 86.46 Adish Jain 87179 95000 91.77 4a Financials Securities Private Limited 80450 80450 100.00 Ajit Jain 30282 730282 4.15 Manish Agarwal 16000 516000 3.10 Venus Infosoft Limited 5000 155000 3.23 NSE Manish Agarwal 950000 1200735 79.12 Venus Infosoft Limited 283329 459148 61.71 Gajria Jayana Precision Industries Private Limited 262613 1227340 21.40 G N Credits Private Limited 235000 235000 100.00 Premium Hospitality Services Private Limited 221130 339500 65.13 Adish Jain 163000 163000 100.00 A To Z Steel Pvt Ltd 90000 241025 37.34 Umang Nemani 88146 500000 17.63 Cheminare Tradecomm Pvt Ltd 50000 422262 11.84 Milestone Shares & Stock Broking Pvt Ltd 50000 120000 41.67

Client Name Quantity Total quantity sold % of total sold by seller on SE sell Passion System Solution Pvt ltd 26000 437228 5.95

14. The analysis of the order pattern reveals that the sell orders placed by the clients in the scrips were below the best buy or sell order price available in the exchange system at the time of either order entry or order amendment by them as brought out below: Table 7: Order pattern Analysis SE Client PAN Order Time of order Order Order Best price available at time type entry / Volume Price of order entry /amendment amendment Best Buy Best Sell Glodyne Technoserve Limited NSE Umang Nemani ABOPN7213K Sell 09:23:23.266861 25000 292 293.7 293.9 BSE Ramkripa Securities AADCR3436K Sell 09:17:03.728888 2000 335.05 336.05 338.75 Pvt Ltd BSE Ramkripa Securities AADCR3436K Sell 09:22:03.57016 5000 320 332 325 Pvt Ltd NSE Yashika Holding AAACY0171H Sell 09:16:58.687149 10000 320 337 337.25 Pvt. Ltd. NSE Yashika Holding AAACY0171H Sell 09:21:50.951187 10000 328 328.4 328.9 Pvt. Ltd. NSE Yashika Holding AAACY0171H Sell 09:22:45.851517 1000 315 318 318.9 Pvt. Ltd. NSE Ramkripa Securities AADCR3436K Sell 09:22:53.911896 5000 315 317.55 317.95 Pvt Ltd NSE Ramkripa Securities AADCR3436K Sell 09:25:38.872055 1000 274.2 274.9 275 Pvt Ltd Parsvnath Developers Limited NSE Manish Agarwal APLPA3819B Sell 09:41:01.181259 100000 46.2 48.05 48.5 BSE Neelanchal AAACN8842N Sell 09:36:44.602207 10000 50 52.35 52.9 Mercantile Pvt Ltd NSE Neelanchal AAACN8842N Sell 09:39:08.307755 10000 52 53.75 54 Mercantile Pvt Ltd Tulip Telecom Limited BSE Ajit Jain ACNPJ9264G sell 09:41:59.810502 90000 95.25 107 107.3 NSE Ajit Jain ACNPJ9264G sell 09:47:21.942139 100000 70 71.85 72.7 NSE Ajit Jain ACNPJ9264G sell 09:47:30.942276 54789 65 69.7 69.8 NSE Gajria Jayna AABCG5915E sell 09:44:25.08606 40895 85 87.35 88 Precision Industries Pvt Ltd NSE Gajria Jayna AABCG5915E sell 09:47:50.886978 40000 72 72.1 72.7 Precision Industries Pvt Ltd Pipavav Defence and Offshore Eng. Limited NSE Umang Nemani ABOPN7213K sell 09:34:54.042618 50000 64 64.55 64.8

15. The above analysis reveals that the clients were instrumental in pushing the prices of the aforesaid scrips down as they were observed to be placing the sell orders below the best sell prices as well as the best buy prices available on various occasions. For instance at NSE in Pipavav Defence & Offshore Eng Limited the client Manish Agarwal entered at 9:32:35 sell order no. 2012072650203718 for 50,000 shares at Rs. 77 when the last traded price was Rs. 77.55. Client order resulted in sale of 30,279 shares in the price range of Rs. 77.60 to Rs. 77.00. For the residual 19,721 shares the client modified the original selling price of Rs. 77 twice to Rs. 70 initially and then to Rs. 65, thus bringing the price down by 15.58% in comparison to last traded price within a span of 2 minutes. Similarly, at NSE in Pipavav Defence &Offshore Eng Limited the client Umesh Nemani entered at 09:34:06 sell order no. 2012072650215729 for 1 Lac shares at Rs. 67 when the last traded price was Rs. 69.9. Client order resulted in sale of 44,651 shares in the price range of Rs. 69.80 to Rs. 67.00. For the residual 55,349 shares the client modified the original selling price to Rs. 65. 16. During the day, many entities related to the some of the clients were the top net sellers in the aforesaid scrips.

The details of the top net sellers at NSE and BSE are as under: Table 8: Top sellers during the day SE PAN Name Gross Buy Gross Sell Net traded Quantity Quantity Quantity Glodyne Technoserve Limited BSE A ADCR3436K Ramkripa Securities Pvt Ltd 2200 35448 -33248 BSE B CMPP5437K Mayoor J Purohit 0 10154 -10154 BSE A ADPI8931K Shridhar Iyer 0 6000 -6000 BSE A BOPN7213K Umang Nemani 0 2081 -2081 NSE A BOPN7213K Umang Nemani 0 25000 -25000 NSE A ADCR3436K Ramkripa Securities Pvt Ltd 0 23292 -23292 NSE A ABCL2630H Littlestar Vanijya Private Limited 0 20000 -20000 NSE A AACN1115A Narayan Sriram Investments Pvt Ltd 0 10000 -10000 NSE A AACY0171H Yashika Holding Pvt. Ltd. 343 10343 -10000 NSE A ACCS4582N Siddhesh Capital Market Services Pvt 0 9431 -9431 Ltd NSE A AACW8451G White Horse Trading Company 0 4064 -4064 Private Limited Parsvnath Developers Limited BSE A PLPA3819B Manish Agarwal 0 100000 -100000 BSE A AUPS0285M Ravinder Kumar Shroff 2 45002 -45000 BSE A AACN8842N Neelanchal Mercantile Pvt Ltd 0 23630 -23630 NSE A PLPA3819B Manish Agarwal 0 200000 -200000 NSE A ABCG5915E Gajria Jayna Precision Industries Pvt 0 158557 -158557 Ltd NSE A CNPJ9264G Ajit Jain 0 100000 -100000

SE PAN Name Gross Buy Gross Sell Net traded Quantity Quantity Quantity NSE A AACN8842N Neelanchal Mercantile Pvt Ltd. 0 35000 -35000 NSE A ADCK8653K Kuvam Plast Private Limited. 0 17799 -17799 NSE A AFCM7386P Milestone Shares & Stock Broking Pvt 22275 32275 -10000 Ltd. Pipavav Defence And Offshore Eng Limited BSE A CNPJ9264G Ajit Jain 0 730282 -730282 BSE A BOPN7213K Umang Nemani 0 550000 -550000 BSE A PLPA3819B Manish Agarwal 0 516000 -516000 BSE A AECP3609F Passion System Solutions Priv 0 268449 -268449 BSE A AACP6934D Premium Hospitality Services Private 0 173500 -173500 Limited. BSE A ACCV5360M Venus Infosoft Private Limited. 0 155000 -155000 BSE A AFCS6801I Religare Finvest Ltd 0 153000 -153000 BSE A AACZ3020E 4a Financials Securities Private Limited 0 80450 -80450 NSE A ABCG5915E Gajria Jayna Precision Industries Pvt 0 1227340 -1227340 Ltd NSE A PLPA3819B Manish Agarwal 0 1200735 -1200735 NSE A AACN1115A Narayan Sriram Investments Pvt Ltd. 0 600000 -600000 NSE A BOPN7213K Umang Nemani 0 500000 -500000 NSE A ACCV5360M Venus Infosoft Private Limited 0 459148 -459148 NSE A AECP3609F Passion System Solutions Private Ltd. 0 437228 -437228 NSE A ACCC1546Q Cheminare Tradecomm Pvt Ltd. 0 422262 -422262 NSE A FRPG4254L Mitsu Janardan Pakvasa 0 389234 -389234 NSE A AACP6934D Premium Hospitality Services Private 0 339500 -339500 Limited NSE A AACA2331D A To Z Steel Pvt Ltd. 0 241025 -241025 Tulip Telecom Limited BSE A ACCM7105R Merrill Lynch Capital Markets Espana 53864 214603 -160739 SA SV BSE A ABCB1518L Bajaj Auto Finance Ltd 0 105973 -105973 BSE A AECP3609F Passion System Solutions Private Ltd 0 100000 -100000 BSE A AETS9556K IDFC Classic Equity Fund 0 94195 -94195 BSE A CNPJ9264G Ajit Jain 0 90000 -90000 BSE A AACN2728F Narayan Securities Limited 0 53056 -53056 BSE A AACN6958M North Eastern Publishing And 0 50000 -50000 Advertising Company Limited BSE A AACR0021K Rapid Credit And Holdings Private 0 50000 -50000 Limited BSE A PLPA3819B Manish Agarwal 0 50000 -50000 BSE A ABCG5915E Gajria Jayna Precision Industries Pvt 0 38000 -38000 Ltd NSE A AETS9556K IDFC Classic Equity Fund 0 375805 -375805

SE PAN Name Gross Buy Gross Sell Net traded Quantity Quantity Quantity NSE A AACP6934D Premium Hospitality Services Private 18000 371000 -353000 Limited NSE A AACG2179F G N Credits Private Limited 0 335000 -335000 NSE A AECP3609F Passion System Solutions Priv 0 271500 -271500 NSE A ABCG5915E Gajria Jayna Precision Industries Pvt 0 245000 -245000 Ltd NSE A AACZ3020E 4a Financials Securities Private Limited 0 214000 -214000 NSE A CNPJ9264G Ajit Jain 0 200000 -200000 NSE A AHCA9621P Ashlar Securities Private Limited 71416 231916 -160500 NSE A ACCV5360M Venus Infosoft Private Limited 0 160000 -160000

17. The relationships as discussed below among some of the clients are derived from DWBIS system, KYC details as uploaded on the NSE/BSE, MCA databases and other publicly available sources.

Table 9: Relationships among entities Name PAN Remarks (common links) Neelanchal Mercantile AAACN8842N  Common phone number 9831541124, 9831032277 between Neelanchal Private Limited Mercantile Private Limited and Milestone Shares & Stock Broking Pvt Ltd  Neelanchal Mercantile Private Limited and Milestone Shares & Stock Broking Pvt Ltd has common address 14 Princep Street,1st Floor, Nr Flex Trade Private AAACF6723A Canara Bank, Kolkata Limited North Eastern AAACN6958M Thus Neelanchal Mercantile Private Limited and Milestone Shares & Publishing & Stock Broking Pvt Ltd are related to each other Advertising Company Limited  Common phone number 033-22255077 between Flex Trade Private Cheminare Trade AACCC1546Q Limited, Adish Jain and Manish Agarwal. Comm Private Limited  Flex Trade Private Limited and Manish Agarwal. have common address Kuvam Plast Private AADCK8653K 2nd Floor, Room No 205, 13, Bipin Bihari Ganguly Street, Kolkata. Limited Thus Flex Trade Private Limited, Adish Jain and Manish Agarwal. are related to each other Milestone Shares & AAFCM7386P Stock Broking Pvt Ltd  Common phone number 9832052577 between Milestone Shares & Umang Nemani ABOPN7213K Stock Broking Private Limited, Ajit Kumar Jain and Manish Agarwal Ajit Kumar Jain ACNPJ9264G Thus Milestone Shares & Stock Broking Private Limited, Ajit Kumar Adish Jain AGZPJ0317Q Jain and Manish Agarwal are related to each other Manish Agarwal APLPA3819B  Common phone number 9831152460 between Ajit kumar Jain and Kuvam Plast Pvt. Ltd  Ajit kumar Jain is also director of Kuvam Plast Pvt. Ltd Thus Ajit kumar Jain and Kuvam Plast Pvt. Ltd are related to each other

 He is director in Mukesh Trade & Finance Limited. As per MCA database the phone number of Mukesh Trade & Finance Limited is 033-

Name PAN Remarks (common links) 22306695 which is same as that of Divya Drishti traders Pvt Ltd.,  Divya Drishti Traders Pvt Ltd, Divya Drishti Merchants Pvt Ltd, Wheelers Developers Pvt Ltd share same address 163 B M G Road 3rd Floor, Kolkata- 700007  Divya Drishti traders Pvt Ltd, Divya Drishti Merchants Pvt Ltd, and Wheelers Developers Pvt Ltd., were debarred from trading in securities market in the matter of creation of artificial market and price manipulation in scrip of Tijaria polypipes ltd. Thus Ajit Kumar Jain appears to be related to the entities that are debarred from trading in securities market in the past.

 One of the addresses of North Eastern Publishing & Advertising Company Limited is 5 Gorky Terrace, 2nd Floor Kolkata- 700017.  Mr. Ajit Kumar Jain is director in various companies including Infinity Tracom Private Limited, Linkwise Agencies Private Limited which have same address 5 Gorky Terrace, 2nd Floor Kolkata- 700017 as that of North Eastern Publishing & Advertising Company Limited and Kamini Finance & Investment Company Limited.  Mr. Manish Agarwal is director in various other companies including Dove Barter Private Limited, Snowfall Tracom Private Limited, Parichay Agencies Private Limited which have same address 5 Gorky Terrace, 2nd Floor Kolkata- 700017 as that of North Eastern Publishing & Advertising Company Limited and Kamini Finance & Investment Company Limited Thus Ajit Kumar Jain and Manish Agarwal are related to North Eastern Publishing & Advertising Company Limited

 As per MCA database the Annual Return (AR) for the year ending 2010 has been digitally signed by a CA whose email id is ashok@steptwo.in.  Email id of Step Two Corporation Limited as per KYC details as uploaded on the NSE/BSE is admin@steptwo.in.  Thus the person who had signed the AR is related to Step Two Corporation Limited. Thus Step Two Corporation Limited is related to Neelanchal Mercantile Private Limited and Milestone Shares & Stock Broking Pvt Ltd

 Umang Nemani share common addresses/phone numbers with Step Two Corporation Limited as C/o Ms Finflow Investment Pvt Ltd, A-206 Phoenix House 2nd Floor, Senapati Bapat Marg Lower Parel, Mumba-13 & phone number 24982000. Thus Umang Nemani and Step Two Corporation Limited are related to each other. Step Two Corporation Limited is related to Neelanchal Mercantile Private Limited and Milestone Shares & Stock Broking Pvt Ltd while Umang Nemai is related to Step Two Corporation Limited, Hence Umang Nemai is related to Neelanchal Mercantile Private Limited and Milestone Shares & Stock Broking Pvt Ltd.

 Common phone number and email id 9831550000,

Name PAN Remarks (common links) umang_nemani@yahoo.co.in between Cheminare Trade Comm Private Limited and Umang Nemani  Nemani Umang is director in Cheminare Trade Comm Private Limited  Further as per MCA the address of Cheminare Trade Comm Private Limited is No 9 Abhoy Guha Roadliluah, Howrah-711204 which is same as that of Vikash Financial Services Pvt Ltd.  Vikash Financial Services Pvt Ltd. is a shareholder in Cheminare Trade Comm Private Limited  In Vikash Financial Services Pvt Ltd both Cheminare Trade Comm Private Limited and Flex trade Pvt Ltd are shareholders Thus Vikash Financial Services Pvt Ltd, Cheminare Trade Comm Private Limited and Flex trade Pvt Ltd, Umang Nemani are related to each other.

Thus based on above entities Neelanchal Mercantile Private Limited, Flex Trade Private Limited, Kuvam Plast Private Limited, Milestone Shares & Stock Broking Pvt Ltd, Ajit Kumar Jain, Cheminare Trade Comm Private Limited, Adish Jain, Nemani Umang, Step Two Corporation Limited, North Eastern Publishing and Advertising Company Limited and Manish Agarwal are related to each other A to Z Steels P Ltd AAACA2331D  Common phone number 9911050665, 9971099091 & 01140541518 G N Credits Private AAACG2179F among various entities. Ltd  Further phone number 01140541518 is common to 4a Financials Securities Private Limited. Premium Hospitality AAACP6934D Services Private  Common phone number 9871927842 & 9810371809 between entities A Limited To Z Steels Pvt Ltd, Premium Hospitality Services Pvt Ltd and Gajria Jayna Precision Industries Pvt Ltd. Gajria Jayna Precision AABCG5915E  Common address as 203, Pankaj House, pocket Shopping Complex, Industries Private sarita Vihar, Delhi- 110076 for entities A To Z Steels Pvt Ltd, Premium Limited. Hospitality Services Pvt Ltd,Gajria Jayna Precision Industries Pvt 4a Financials Securities AAACZ3020E Ltd,Venus Infosoft Private Limited and Passion System Solutions Private Private Limited. Ltd Venus Infosoft Private AACCV5360M Limited Hence the entities A To Z Steels Pvt Ltd, Premium Hospitality Services Pvt Ltd, Gajria Jayna Precision Industries Pvt Ltd, Venus Infosoft Passion System AAECP3609F Private Limited, 4a Financials Securities Private Limited, G N Credits Solution Private Private Ltd and Passion System Solutions Private Ltd appear to be Limited related to each other.

18. Thus, it is observed that A To Z Steels Pvt Ltd, G N Credits Private Ltd, Premium Hospitality Services Pvt Ltd, 4a Financials Securities Private Limited, Gajria Jayna Precision Industries Pvt Ltd, Venus Infosoft Private Limited and Passions System Solution Private Limited are related to each other. Similarly, the entities Neelanchal Mercantile Private Limited, Flex Trade Private Limited, Kuvam Plast Private Limited, Milestone Shares & Stock Broking Pvt Ltd, Ajit Kumar Jain, Cheminare Trade Comm Private Limited, Adish Jain, Nemani Umang, Step Two Corporation Limited, North Eastern Publishing and Advertising Company Limited and Manish Agarwal are related to each other.

19. A comparison of the trading pattern with the income details captured in KYC of the clients, whose KYC records are available, reveals that for certain clients the trading pattern does not appear to be commensurate with income shown in the KYC records.

Table 10: Trading pattern vis-à-vis Income details Sr. Name of the Entity PAN Income Gross Trading across No. mentioned in market from January 01, KYC Form 2012 till July 25, 2012 1. Manish Agarwal APLPA3819B ₹ 1 to ₹ 5 Lacs ₹ 490.96 Crs. 2. Neelanchal Mercantile Pvt Ltd. AAACN8842N Not Mentioned ₹ 1508.35 Crs. 3. Ramkripa Securities Pvt Ltd AADCR3436K Not Mentioned ₹ 93.79 Crs. 4. Umang Nemani ABOPN7213K > ₹ 25 Lacs ₹ 209.42 Crs. 5. White Horse Trading AAACW8451G < ₹ 1 Lac ₹ 36.68 Crs. Company Private Limited 6. Gajria Jayna Precision AABCG5915E Not Mentioned ₹ 170.82 Crs. Industries Pvt Ltd 7. Kuvam Plast Private Limited AADCK8653K Not Available ₹ 86.68 Crs. 8. Littlestar Vanijya Private AABCL2630H Not Available ₹ 36.04 Crs. Limited 9. Yashika Holding Pvt. Ltd. AAACY0171H ₹ 10 to ₹ 25 Lacs ₹ 0.86 Crs. 10. A To Z Steel Pvt Ltd AAACA2331D Not Mentioned ₹ 63.53 Crs. 11. G N Credits Private Limited AAACG2179F Not Available ₹ 116.03 Crs. 12. North Eastern Publishing And AAACN6958M ₹ 10 to ₹ 25 Lacs ₹ 271.97 Crs. Advertising Company Limited 13. Premium Hospitality Services AAACP6934D 0 ₹ 71.23 Crs. Private Limited (As per income statement for the yr 2010-2011) 14. 4A Financials Securities AAACZ3020E Not Available ₹ 47.03 Crs. Private Limited 15. Cheminare Tradecomm Pvt AACCC1546Q < ₹ 1 Lac ₹ 70.56 Crs. Ltd (As per income statement for the yr 2010-2011) 16. Venus Infosoft Private AACCV5360M 0 ₹ 145.36 Crs. Limited (As per income statement for the yr 2010- 2011) 17. Passion System Solutions AAECP3609F Not Available ₹ 112.20 Crs. Private Ltd. 18. Ajit Kumar Jain ACNPJ9264G ₹ 1 to ₹ 5 Lacs ₹ 426.50 Crs.

20. The concentration pattern of the clients who sold heavily in the price fall period on July 26, 2012 was also analyzed for period from January 01, 2012 till July 25, 2012. Substantial concentration of trading of these clients was observed in the four scrips viz. Pipavav Defence and Offshore Eng Ltd., Glodyne Technoserve Ltd., Tulip

Telecom Limited and Parsvnath Developers Ltd. The concentration of trading by each client in these four scrips was calculated as a percentage of their total trading in the market during January 01, 2012 till July 26, 2012 and is observed as under:

Table 11: % concentration Sr Entity % concentration in these 4 scrips 1. Yashika Holding Pvt. Ltd. 100 2. Cheminare Tradecomm Pvt Ltd 96.78 3. Kuvam Plast Private Limited 96.37 4. White Horse Trading Company Private Limited 94.52 5. North Eastern Publishing & Advertising Company Limited 94.48 6. Ramkripa Securities Pvt Ltd 93.70 7. Neelanchal Mercantile Pvt Ltd 90.52 8. Manish Agarwal 86.08 9. Umang Nemani 85.72 10. Ajit Jain 84.73 11. Milestone Shares & Stock Broking Pvt Ltd 81.99 12. Gajria Jayna Precision Industries Pvt Ltd 65.25 13. Littlestar Vanijya Private Limited 59.17 14. 4a Financials Securities Private Limited 49.08 15. A To Z Steel Pvt Ltd 33.01 16. G N Credits Private Limited 31.37 17. Premium Hospitality Services Private Limited 29.76 18. Passion System Solutions Priv 27.18 19. Venus Infosoft Private Limited 26.23

21. I note from the aforesaid analysis of the trading pattern of the aforesaid clients during the price fall period on July 26, 2012 in the above-mentioned four scrips viz. Pipavav Defence and Offshore Eng Ltd., Glodyne Technoserve Ltd., Tulip Telecom Limited and Parsvnath Developers Ltd, that:- (i) Net sell volume of these clients taken together was significant ranging from 51% to 95% of total market net sell at NSE and 31% to 58% of total market net sell at BSE. (ii) Their sale orders of substantial quantities were mainly placed as fully disclosed orders with a view to create an impression of huge selling pressure at the time of start of the trading. (iii) Several times the limit orders were placed at a price significantly below the Last Traded Price (LTP) thereby bringing down the price of the scrips. (iv) In some of the scrips, percentage of sell quantity by identified clients during the price fall patch was significant to their total sell quantity during the day. This was in the range of 50-100%.

(v) Prior to July 26, 2012; the trading of the some of the aforesaid clients during past 6 months was mainly concentrated in these scrips only.

22. In my view, generally, a seller would rationally seek a higher price to sell his shares; however, in this case the clients were placing sale orders at prices lower than LTP, thereby bringing down the price of the scrips. More importantly, normally a seller would desist from revealing its entire sell quantity since that may cause the supply-demand balance to immediately become unfavourable to the seller. The data for the short period of time in each scrip indicates several instances of fully disclosed orders which were also a significant factor in causing the sharp decline of approximately 20% in price of each scrip.

23. One basic premise that underlies trading on the stock exchanges is that the clients conform to standards of transparency and ethical behavior prescribed in the various regulations and statutes, relevant in this regard and do not indulge in fraudulent, manipulative and unfair trade practices while dealing in securities. In this case, the above trading pattern of the clients’ prima-facie indicates that there was a concerted attempt to artificially manipulate/depress the prices of these scrips in a disorderly fashion thereby adversely affecting the integrity of the securities market.

24. Thus, from the foregoing, it appears that the aforesaid entities have prima facie violated section 12A of the Securities and Exchange Board of India Act, 1992, regulations 3 and 4 of the Securities and Exchange Board of India (Prohibition of the Fraudulent and Unfair Trade Practices Relating to Securities Market) Regulations 2003.

25. In the facts and circumstances narrated above, abounding in several abnormal suspicious features which otherwise are likely to pass-off as normal buy and sell transactions in the market and in the context of unprecedented price fall, traded quantity by the identified clients on July 26, 2012, there is a prima facie case for conducting a detailed investigation in the matter with respect to the role of various entities. It is noted that the trading pattern of few of the above clients along with other entities in various scrips including some of the aforesaid scrips for different periods is under examination of SEBI.

26. Protection of the market mechanism is not only the primary duty of SEBI but is also an imperative for long term stability and growth in the capital markets of the country. Further the trading pattern of the entities is prima facie found to be instrumental in depressing the prices of certain scrips at the beginning of the trading in the market on July 26, 2012. If they are allowed to continue to operate in the market, the same is fraught with danger of immense mischief and incalculable damage to the securities market besides undermining the confidence of the investors in the fairness and integrity of the market. It is, therefore, my considered opinion that immediate and urgent intervention to prevent the continuance of such operations is warranted.

27. In the light of the preliminary findings in this matter as mentioned above, I am of the view that this is a fit case where, pending detailed investigation, effective and expeditious action is required to be taken to prevent any further harm to investors and securities market and in order to protect the interest of investors and the integrity of the securities market, by way of an ad interim ex -parte order under sections 11 and 11B of SEBI Act, 1992.

28. I, therefore, in exercise of the powers conferred upon me by virtue of section 19 of the SEBI Act, hereby restrain the following entities from accessing the securities market and further prohibit from buying, selling or dealing in securities in any manner whatsoever, till further directions:

Sr. Name PAN 1. 4a Financials Securities Private Limited AAACZ3020E 2. A To Z Steels Pvt Ltd AAACA2331D 3. Ajit Kumar Jain ACNPJ9264G 4. Cheminare Trade Comm Private Limited AACCC1546Q 5. G N Credits Private Ltd AAACG2179F 6. Gajria Jayna Precision Industries Pvt Ltd AABCG5915E 7. Kuvam Plast Private Limited AADCK8653K 8. Littlestar Vanijya Private Limited AABCL2630H 9. Manish Agarwal APLPA3819B 10. Milestone Shares & Stock Broking Pvt Ltd AAFCM7386P 11. Neelanchal Mercantile Private Limited A A A C N 8 8 4 2 N 12. North Eastern Publishing & Advertising Company AAACN6958M Limited 13. Passions System Solution Private Limited AAECP3609F 14. Premium Hospitality Services Pvt Ltd AAACP6934D 15. Ramkripa Securities Pvt Ltd AADCR3436K 16. Umang Nemani ABOPN7213K 17. Venus Infosoft Private Limited AACCV5360M 18. White Horse Trading Company Private Limited AAACW8451G 19. Yashika Holding Pvt. Ltd. AAACY0171H

29. The Stock Exchanges and the Depositories are directed to ensure that the above directions are strictly enforced. SEBI shall conclude the investigations in the matter expeditiously

30. The persons/entities against whom this order is passed may file their objections, if any, within twenty one days from the date of this order and, if they so desire, avail an opportunity of personal hearing before the Securities and Exchange Board of India, Mumbai on a date and time to be fixed on a specific request, received from the said persons.

31. This order shall come into force with immediate effect.

DATE: August 03,2012 RAJEEV KUMAR AGARWAL PLACE: MUMBAI WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA