Interim order in the matter of Radford Global Ltd.

WTM/RKA /ISD /161 /2014 SECURITIES AND EXCHANGE BOARD OF INDIA ORDER UNDER SECTION 11(1), 11(4) AND 11B OF THE SEBI ACT, 1992 AND SECTION 12A OF THE SECURITIES CONTRACTS (REGULATION) ACT, 1956 - IN THE MATTER OF RADFORD GLOBAL LIMITED AND OTHERS

1. Pursuant to preliminary examination by Bombay Stock Exchange Limited ("BSE") in the dealings in the shares of Radford Global Limited {hereinafter referred to as "Radford"}, Securities and Exchange Board of India ("SEBI") undertook a preliminary inquiry in the dealings in the shares of Radford for the period January 28, 2013 to March 24, 2014 {hereinafter referred to as "the examination period"}. 2. On January 28, 2013, pursuant to a stock split, the face value of each share of ₹10/- was reduced to ₹2/- per share. Post stock-split, during the period January 29, 2013 to July 23, 2013 ("Patch I"), the price of the scrip of Radford opened at ₹49.20, rose to a high of ₹86.00 and closed at ₹74.95. During the period July 24, 2013 to March 24, 2014 ("Patch II"), the price of the scrip continuously fell from ₹74.10 to ₹4.89. An illustration of price/volume movement in the scrip of Radford during the examination period is given below:

No.of Shares Close Price 2000000 90 1800000 80 1600000 70 1400000 60 1200000 50 1000000 40 800000 30 600000 400000 20 200000 10 0 0

*It was noticed that during the period February 27, 2012 to January 28, 2013("Pre-Patch I") the price of the shares of Radford was at ₹3.20, rose to a high of ₹241.35 and closed at ₹241.35.

Order in the matter of Radford Global Ltd.

3. The preliminary examination revealed that there was a pattern in which the shares of Radford were being traded. The modus operandi adopted by the traders in the scrip is as under : i. Firstly, shares were allotted on preferential basis in Pre-Patch I to entities connected/related directly or indirectly to Radford. ii. Then, just prior to the expiry of lock-in of shares issued on preferential basis, Radford announced a stock-split to make a passage for preferential allottees to exit on expiry of the lock-in since the stock split would reduce the per share price and increase liquidity. iii. After the expiry of lock-in, it was noted that after the stock split, the preferential allottees sold the shares to entities connected/related, directly or indirectly, to Radford Group/Suspected Entities, thereby raking in huge profits. iv. It was also noted that the said price movement was not backed by fundamentals of the company and its financials. 4. During the beginning of Pre-Patch I, on February 16, 2012, Radford had allotted 91,00,000 equity shares of ₹10/- each at a premium of ₹5/- on preferential basis to 48 entities aggregating to 13.65 cr. (list provided in Annexure A). Out of these 48 entities, 4 entities viz. Brij Bhushan Singal, Neeraj Singal, Ritu Singal and Uma Singal are connected to the Radford and 19,00,000 shares (20.87% of total number of shares allotted) were allotted to these four entities. The shares allotted on preferential basis to aforesaid allottees were locked-in for a period of 1 year in compliance with Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2009. Thus, these shares held by the said 48 allottees pursuant to preferential allotment and split were not tradable in this lock in period. 5. On analysing the financial statements of Radford, the following was observed:- Table: I - Financial year-wise particulars of Radford FY 2011-12 FY 2012-13 FY 2013-14 Total Number of paid 1,40,62,300(₹10) 7,03,11,500(₹2) 7,03,11,500(₹2) up Shares (Face Value) Total Revenue 3.04 crore 22.28 crore 11.04 crore Profit after tax 0.06 crore 0.46 crore 0.18 crore Earning per share 0.01 0.07 0.03

6. From Table I, it is observed that the total number of paid up shares of Radford, after taking into account the stock-split dated January 28, 2013, increased by 5 times to 70,311,500. From the Annual Reports of Radford for FY 2011-12 and FY 2012-2013, it was observed that it is in the business of Staffing Services, Textile and Real Estate and it had earned a profit of ₹6,17,264/-during 2011-12 and ₹45,87,092/- during FY 2012-13. From the Annual Report of Radford for the FY 2012-2013 it is observed that for the FY ended 2012 the EPS was ₹0.01/- and for the FY ended March 31, 2013 EPS was ₹0.07/-. It was further noted that during the Pre-Patch I there was no material corporate announcement made by Radford which could support such price rise in its scrip. It is observed from the above facts that the price rise of 7442% during Pre- Patch I was not justified and aberrant. Also the movement was extremely aberrant vis-a-vis the movement of the stock market as the Sensex only moved from 17,645 to 20,103. 7. The sharp price rise in the scrip as discussed above was not supported by fundamentals of Radford or any other external factor. The price in the scrip increased prior to the expiry of the lock-in period on the shares held by the aforesaid allottees pursuant to preferential allotment and split. After the expiry of the lock-in period, the price and volume in the scrip increased substantially. Considering such pattern, the trading in the scrip in three patches as mentioned above was analyzed. The analysis of the trading during the patches was carried out with a focus on the following:-  The trading frequency;  The volume generated;  Contribution to price rise;  Buying behavior as observed from Last Traded Price ("LTP") data.

8. On analysis of trading activity in the Scrip, it was observed that certain entities was primarily involved in pushing the price up during the lock in period, which is Pre-Patch I, by contributing to positive LTP through first trades with negligible volumes. Another group of entities were acting as buyers in Patch-I in order to provide exit to preferential allottees and in the process creating artificial volume which has been dealt with in detail subsequently.

9. During Pre-Patch I, the scrip opened at ₹3.20 (pre-split price) on February 27, 2012 and rose to a high of ₹241.35 and closed at ₹241.35 on January 28, 2013. During this period, the scrip was traded with an average volume of 98 shares per day and total volume of 11,950 shares in 121 trading days with an average of 1.6 trades per day. It was observed that price of the scrip was influenced by certain entities primarily through first trades during this period. It was noticed that these entities by putting 1 or 2 trades per day with negligible/ very less quantity of buy orders contributed significantly to the price rise. From LTP analysis, it is observed that price of the scrip increased from ₹3.20 to ₹241.35 mainly through first trades in 121 instances. 10. It was observed that in Pre-Patch I, out of a total of 121 instances of trades establishing new high price in the scrip, certain entities established new high price on 91 instances (75.21% to total instances). The contribution of these entities in establishing new high price was ₹204.3/- out of total price rise of ₹ 246.7/-, which constitutes 82.81% of the total new high prices. The details of contribution to price rise by these entities during Pre-Patch I are as under: Table II : Details of entities and their contribution to price rise in Pre-Patch I

Pos LTP No. % to Tot Pos Contri Sr. Trading Member of I Total Pos Contr Clnt Name Clnt Pan of the No. Name nsta Insta Contri i (in Client nces nces In Sec %) as a buyer Taran Kumar 1 ASVPR5947G 14 11.57 45.21 246.7 18.33 Rungta Shilpa Stock Broker Pvt. Ltd. 2 Prem Lata Nahar AFAPN8764M 25 20.66 43.3 246.7 17.55 Manjulaben Sanghavi Brothers 3 ALVPP7764J 15 12.4 32 246.7 12.97 Sukhdev Pandya Brokerage Ltd. Rajat Share Broking Shilpa Stock Broker 4 AAACR2695B 6 4.96 25.5 246.7 10.34 Pvt Ltd Pvt.Ltd. Rajesh Pravinkumar Monarch Research & 5 ACWPJ4705B 7 5.79 24.85 246.7 10.07 Jasani Brokerage Pvt.Ltd. Bcb Brokerage 6 Bharat Bagri Bagri AADHB8488A 16 13.22 17.86 246.7 7.24 Pvt.Ltd. Jayesh Narendra Bharti Thakkar India 7 AAEHJ1610D 8 6.61 15.58 246.7 6.32 Kesharia Securities Pvt.Ltd. Total 91 75.21 204.3 246.7 82.81

11. It was also observed that most of these aforementioned entities had also traded and were instrumental in contributing to the price rise of other stocks. It was further observed that Taran Kumar Rungta, Prem Lata Nahar and Rajat Share Broking Pvt. Ltd are related /connected to Shilpa Stock Broker Pvt. Ltd and Bharat Bagri Bagri is related to BCB Brokerage Pvt. Ltd. through whom they have traded. Ms. Prem Lata Nahar is the Mother of Rakesh Nahar who is the owner/director of Shilpa Stock Broker Pvt. Ltd. and Bharat Bagri is the Promoter/ director of BCB Brokerage Pvt. Ltd and share common address with BCB Brokerage Pvt. Ltd. 12. The selection of scrips for trading, the trading pattern and connectivity with brokers cast doubt on the intent of these entities while trading in the securities market. The sheer number of scrips with such dubious price-rise track record in which the said entities and their connected brokers are involved also cast doubts on their conduct in the securities market. 13. On analysis of trading activity during Patch I, certain related/connected entities ("Radford Group") to Radford were found to be net buyers to the preferential allottees and thereby created artificial demand for the supply of shares from preferential allottees. Further, it was also noticed that a group of entities connected/related ("Suspected Entities") to each other, by virtue of common address;/e-mail id. were trading in the shares of Radford amongst themselves. During the Patch I, significant increase in the trading volume was observed and it appears that most of the entities were acting as counterparty to the preferential allottees. Also on further examination direct/ indirect relationship were established among these entities through Know Your Client (KYC) details, their bank statements, off-market transactions amongst themselves, and information available on the Ministry of Corporate Affairs (MCA) website. List of such entities are annexed as Annexure - B and hereinafter referred to as the "Radford Group & Suspected Entities".

14. It is observed that during Patch I, the preferential allottees were net sellers and entities forming part of the Radford Group & Suspected Entities were net buyers, a snapshot of which is given below:-

Table III - Exit provided by Radford Group & Suspected Entities to allottees

Shares Total % of purchased % of shares Shares Total % of Net from preferential bought in sold allotted Buy preferential shares Sold the Patch I shares allottees by Preferential 4,15,99,539 91.43% - - - - Allottees Radford Group 2,76,84,200 70.01% & Suspected - - (refer table 67.77% 4,08,51,126 (refer table Entities IV) IV)

15. It is observed from Table III that most of the trades were taking place between the preferential allottees and the entities of Radford Group & Suspected Entities. During this period, the allottees were found to be selling and in the process gaining a huge profit/gain. It was observed that Radford Group & Suspected Entities contributed 70.01% to the net buy trade during this patch. The details of counter parties for sale transactions by preferential allottees is given below:

Table - IV: Details of counter parties for sale transactions Shares % of shares purchase bought Vol of d from from Sr. Net Buy Net preferenti preferential Client Name Clnt Pan No. in Patch I Buy in al allottes allottes to Patch I during the Net post split Buy in period Patch I 1 2 3 4 5 6 7=6/4*100 Radford Group Amrusha Mercantile 1 AALCA0340D 3317965 5.69 2281121 68.75 Private Limited Spice Merchants Private 2 AAPCS7492G 3287475 5.63 2422355 73.68 Limited Shelter Sales Agency Private Limited Shelter 3 Sales Agency Private AASCS1797F 3122146 5.35 2312395 74.06 Limited Shelter Sales Agency Private Limited Udbal Mercantile Private 4 AABCU2648C 2767601 4.74 1588720 57.40 Limited Devakantha Trading 5 AADCD7044B 2475491 4.24 1705206 68.88 Private Limited Winall Vinimay Private 6 AAACW8004B 2144989 3.68 1764206 82.25 Limited Ltd 7 Pine Animation Limited AAECM0267A 1858368 3.18 1081586 58.20 Limestone Properties 8 AACCL0133G 1764054 3.02 1357040 76.93 Private Limited Runicha Merchants 9 AAECR0580M 1584913 2.72 1325164 83.61 Private Limited Dhanleela Investments 10 & Trading Company AAACR1770P 1464988 2.51 680586 46.46 Limited Apex Commotrade 11 AAJCA4459K 1223735 2.10 1033114 84.42 Private Limited Ltd Shivkhori Construction 12 AAPCS7850L 926220 1.59 896440 96.78 Private Limited Signet Vinimay Private 13 AAMCS1712Q 903711 1.55 913195 101.05 Limited Anjali Suppliers Private 14 AAJCA1784D 893000 1.53 747275 83.68 Limited Sanklap Vincom Private 15 AAMCS1711P 892600 1.53 613910 68.78 Limited 16 Rangan Vincom Private AAGCR1715E 725705 1.24 720970 99.35

Limited Pyramid Trading And 17 AAACP2548R 647675 1.11 518992 80.13 Finance Ltd Divyadrishti Merchants 18 AABCD8147K 537000 0.92 499448 93.01 Pvt Ltd Divya Drishti Traders 19 AABCD8146J 532000 0.91 450691 84.72 Pvt Ltd Ladios Trading Private 20 AACCL3868N 507160 0.87 473093 93.28 Limited Skm Travels Private 21 AAICS0688K 494050 0.85 443724 89.81 Limited Avlokan Dealcom 22 AALCA1583G 389706 0.67 368706 94.61 Private Limited Topwell Properties 23 AADCT8403C 250000 0.43 160600 64.24 Private Limited Esquire Enclave Private 24 AACCE7065J 225000 0.39 87233 38.77 Limited Natural Housing Private 25 AADCN6251G 200000 0.34 183926 91.96 Limited Radison Properties 26 AAFCR2818B 160125 0.27 114517 71.52 Private Limited 27 Ridhi Vincom Pvt Ltd AAECR9858C 115000 0.20 115000 100.00 Dhanraksha Vincom 28 AADCD6028P 113390 0.19 112390 99.12 Pvt Ltd Kingfisher Properties 29 AAECK3394G 95000 0.16 92400 97.26 Private Limited Vibgyor Financial 30 AAACV8378B 82000 0.14 37840 46.15 Servicepvt Ltd Blue Circle Services 31 AAACB2131L 64073 0.11 60323 94.15 Limited Amrit Sales Promotion 32 AACCA3220D 47000 0.08 47000 100.00 Pvt Limited Burlington Finance 33 AABCB2575P 34500 0.06 30000 86.96 Limited Bazigar Trading Private 34 AABCB3052B 34500 0.06 32347 93.76 Limited Katyani Commodities 35 AAECK6244R 25000 0.04 70000 280.00 Private Limited Manimudra Vincom 36 AADCM4316K 23500 0.04 23200 98.72 Private Limited Devatma Distributors 37 AADCD7140G 11950 0.02 11950 100.00 Private Limited Symphony Merchant Pvt 38 AADCS5411K 5000 0.01 5000 100.00 Ltd 39 Scope Vyapar Pvt. Ltd. AAICS6023N 0 0.01 11000 0.00 Total (I) 33946590 58.18 25392663 74.80

Suspected Entities Jayant Security & 1 1535303 44.75 Financeltd AAACJ4848G 3430961 5.88 2 Trimurthi Finvest Ltd AAACT6383N 1051222 1.80 329978 31.39 3 Purvi Finvest Limited AABCP6564C 1077750 1.85 129253 11.99 East West Finvest India 4 224803 20.01 Limited AAACE6834D 1123353 1.92 East West Finvest India 5 72200 32.63 Limited AADCE1236G 221250 0.38 Total (II) 6904536 11.83 2291537 33.19 Grand Total (I+II) 40851126 70.01 27684200 67.77

16. It is observed that 46 allottees made a collective profit of ₹313.01 Crore on their total investment of ₹12.99 crore, a substantial return of approximately 2309 % on their investment in a period of 18 months (including the lock in period). It is evident from the above analysis of trading in Patch I that the entities of Radford Group & Suspected Entities provided a hugely profitable exit to the allottees, who also were related directly/indirectly to Radford. The profit/gain earned by the allottees during Patch I is given below:-

Table V: Details of the trades carried out by allottees and profit calculation Qty Post Price Qty Qty Client Qty Stock after Bought Sold in Total Sum of Sell Profit Earned Bala SrNo PAN Qty in SOLD nce Name Allotted Split (Jan Stock in Off Off Rate (₹) Hand QTY Qty 29, 2013) Split Market Market Achal ABAPB8 6094 Chand 150000 750000 3 0 500000 250000 189060 80.36 14625025 617M 0 Balar Abhishek AATPB8 8400 Achalcha 0 0 3 250000 0 250000 166000 85.22 13648846 1 811B 0 nd Balar Piyush AEMPB6 1100 Kumar 0 0 3 250000 0 250000 140000 83.39 11254028 394Q 00 Balar AfsarZaid AADPZ8 2 100000 500000 3 0 0 500000 500000 80.04 38522857 0 i 571G Amresh AACPM4 Anantrai 100000 500000 3 0 450000 50000 50000 79.85 3842500 0 024E Mody 3 Hasumati AJSPM79 Anantrai 0 0 3 450000 0 450000 450000 83.85 36381293 0 35P Mody Anil Rajat Agarwal AAFHA0 4 60000 300000 3 0 0 300000 300000 69.11 19831633 0 & Sons 709M (Huf)

Qty Post Price Qty Qty Client Qty Stock after Bought Sold in Total Sum of Sell Profit Earned Bala SrNo PAN Qty in SOLD nce Name Allotted Split (Jan Stock in Off Off Rate (₹) Hand QTY Qty 29, 2013) Split Market Market Ashok AACPJ36 5 250000 1250000 3 0 0 1250000 1250000 79.18 95222911 0 Jiwrajka 10K Babita AAIPG4 6 150000 750000 3 0 0 750000 750000 79.34 57254421 0 Mittal 573G Bimal AAKPD3 7 200000 1000000 3 9001 0 1009001 1009001 83.22 80945955 0 Desai 160A Brij AEFPS62 8 Bhushan 580000 2900000 3 0 0 2900000 2900000 82.12 229451547 0 98M Singal Dalsukh ACDPT3 9 Ujamshi 100000 500000 3 0 0 500000 500000 81.3 39148937 0 428N Trevadia Dilip AADPM 10 Chotalal 200000 1000000 3 0 0 1000000 1000000 55.79 52788678 0 9919M Morzaria Dilip AAGPJ87 11 250000 1250000 3 0 0 1250000 1250000 79.2 95246103 0 Jiwrajka 56J G M AEYPM5 12 200000 1000000 3 0 0 1000000 1000000 71.91 68913912 0 Lingaraju 850Q G M AHEPG0 13 Prasanna 200000 1000000 3 0 0 1000000 1000000 76.72 73720095 0 025A Kumar G S Anith ADPPK9 14 200000 1000000 3 0 0 1000000 1000000 77.8 74800649 0 Kumar 874N Harikisha AAJPV47 15 n S 100000 500000 3 0 0 500000 500000 82.99 39994974 0 54H Virmani Hitesh AABPJ28 16 100000 500000 3 0 0 500000 500000 82.64 39819781 0 Jain 35R Hukamsi ngh Bhawarsi AABPR9 17 100000 500000 3 0 0 500000 500000 81.16 39080552 0 nghji 949J Rajpurohi t Jyoti Anil ABWPT8 18 100000 500000 3 0 0 500000 500000 81.39 39195997 0 Trevadia 000C Jyotsna AHPPD4 19 Jitendra 200000 1000000 3 0 9001 990999 990999 70.65 67041531 0 223L Desai Kalpita AAAPL9 20 Suresh 100000 500000 3 0 0 500000 500000 58.83 27916282 0 611J Luniya Kamal AFFPP52 21 Indur 100000 500000 3 0 0 500000 500000 79.31 38156782 0 07G Punwani Mayuri Darshan AKJPB85 22 100000 500000 3 0 0 500000 500000 72.34 34669719 0 Bhanusha 72F li Mohan APFPM0 23 150000 750000 3 0 0 750000 750000 79.86 57648728 0 Mittal 496Q Mohit ADSPA9 24 150000 750000 3 0 0 750000 750000 76.29 54964382 0 Aggarwal 301K Mukesh AJGPM2 25 150000 750000 3 0 0 750000 750000 80.1 57826737 0 Mittal 125D Naresh ACRPS01 26 Nemchan 400000 2000000 3 0 0 2000000 2000000 78.78 151568641 0 82J d Shah Neeraj ANRPS7 27 580000 2900000 3 0 0 2900000 2900000 79.61 222156517 0 Singal 986B

Qty Post Price Qty Qty Client Qty Stock after Bought Sold in Total Sum of Sell Profit Earned Bala SrNo PAN Qty in SOLD nce Name Allotted Split (Jan Stock in Off Off Rate (₹) Hand QTY Qty 29, 2013) Split Market Market Nishit Agarwal AABTN3 28 200000 1000000 3 0 0 1000000 1000000 78.55 75549009 0 Beneficiar 350K y Trust Pinky ACGPA7 29 200000 1000000 3 0 0 1000000 1000000 82.47 79471984 0 Agarwal 438L Pratik Agarwal AABTP7 30 200000 1000000 3 0 0 1064874 1064874 79.01 76033232 0 Beneficiar 516K y Trust Praveen ACSPA4 5000 31 Kumar 200000 1000000 3 0 0 1000000 500000 78.47 37735000 725A 00 Agarwal Praveen Kumar AAIHP6 32 200000 1000000 3 0 0 1000000 1000000 82.6 79600930 0 Agarwal 229C Huf Rajendra ACPPJ98 33 Mangilal 100000 500000 3 0 0 500000 500000 82.61 39805257 0 53R Jain Renu AAEPA1 34 150000 750000 3 0 0 750000 750000 79.96 57719482 0 Aggarwal 694C Renu AGMPM 35 150000 750000 3 0 0 750000 750000 81.27 58703897 0 Mittal 1488Q Ritu ABHPS3 36 515000 2575000 3 0 0 2575000 2575000 82.77 205404070 0 Singal 711M Santosh ABAPA4 37 150000 750000 3 0 0 750000 750000 80.11 57833909 0 Aggarwal 548E Shailesh AAAPJ67 38 Mangilal 100000 500000 3 0 0 500000 500000 82.4 39700599 0 65F Jain Shilpa AEXPA1 39 150000 750000 3 0 0 750000 750000 75.32 54238750 0 Aggarwal 230M Surendra AACPJ43 40 250000 1250000 3 0 0 1250000 1250000 79.2 95249153 0 Jiwrajka 16L Sushant ACAFS8 1010 41 Investme 250000 1250000 3 0 0 1250000 239604 78.75 18149101 650G 396 nts Tanvi AFAPT5 42 Bhavik 100000 500000 3 0 0 500000 500000 80.07 38535769 0 888A Trevadia Tarun AOQPA9 43 150000 750000 3 0 0 750000 750000 79 57001648 0 Aggarwal 034E Ujwala AAEPM5 44 Namdev 100000 500000 3 0 0 500000 500000 46.16 21577500 0 924H Mane Uma ANRPS7 45 225000 1125000 3 0 0 1125000 1125000 78.6 85053164 0 Songal 987A Yogesh AAPPT1 46 Popatlal 200000 1000000 3 0 0 1000000 1000000 80.15 77154413 0 825P Thakkar 1765 Total 8660000 43300000 959001 959001 43300000 41599539 ₹313,01,56,898 336

17. The transactions wherein the entities of Radford Group & Suspected Entities bought most of the shares sold by the allottees cannot be just a coincidence particularly when sellers by virtue of being allotees and prima facie connected / have nexus with Radford and its promoters/ directors and buyers are the entities connected with Radford and its promoters /directors. From the analysis presented for Pre-Patch I, it is observed that the shares of Radford were not in demand by the general investors of the market and saw very low volume on most of the trading days and hence could not have commanded the price as observed in Patch I. In any market, a sudden supply, if not matched by similar demand, leads to price fall. Considering the same, any rational investor would not have dumped a large number of shares without facing the risk of a significant price fall until and unless he was sure of the demand side absorbing the supply. In this peculiar case, the entities of Radford Group & Suspected Entities created the demand against the supply from the preferential allotters. In the whole process, the principle of price discovery was kept aside and the market lost its purpose. It is evident from the above analysis that the Radford Group & Suspected Entities provided a hugely profitable exit to the allottees. This could be only possible if the allottees, Radford Group & Suspected Entities and Radford and its promoter/ directors were hand in glove with each other. The said finding is also corroborated by the fact that in few instances/ cases, it is observed that the buyers are related /connected entities of preferential allottees.

18. From the facts stated above, it can be safely assumed that the entire modus operandi of allotting preference shares at a premium, announcing a stock split and then bringing in connected entities to provide exit was a scheme devised to rake in ill-gotten gains.

19. In Patch II, the price of the shares of Radford has decreased from ₹74.10 to ₹4.89, i.e. a fall of approximately 93.4%. Also the volumes have again decreased by 67% of the volume of Patch I. On analysis of the top 20 sellers during the period, it was noted that 9 entities of the Radford Group & Suspected Entities have sold approximately 37% of the net traded volume. Also on analysis of the negative LTP contribution, it was noted that the top 20 entities had contributed 72% of the price fall of which only 13% was contributed by Radford Group & Suspected Entities. It indicates that a sizeable quantum of gullible investors had started trading in the shares of Radford and were disposing at any possible price.

20. From the analysis of the trading across Patches, it can be comfortably stated that the modus operandi of allotting shares on preferential basis at a premium, pumping the share price artificially and then dumping the price so that the same cycle could be repeated, demonstrates the mala fide of the Radford Group & Suspected Entities. Also the mechanism is being presumably used to deceive the authorities by laundering black money and raking in tax-free profits.

21. It was noted that the price movement of the shares are negligible Post examination period till the date of this order.

22. From the above examination and factors as described in Annexure B, I note that the allottees, Radford and Radford Group & Suspected Entities are connected to each other. In this regard, I note that the Hon'ble SAT has, in many cases such as Classic Credit Ltd. vs. SEBI (SAT Appeal no. 68/2003, Order dated December 8, 2006), Classic Credit Ltd. vs. SEBI (SAT Appeal no. 76/ 2003, Order dated January 9, 2007) and Veronica Financial Services Ltd. vs. SEBI (SAT Order dated August 24, 2012), held that connection/relations can be established on the basis of factors including the common addresses, common directors/ shareholders, etc. 23. It is pertinent to mention that the key to the scheme of operations employed by Radford Group & Suspected Entities prima facie lies in the preferential allotment of shares made by Radford. Due to a lock-in of one year on shares any gains made on the sale of such shares makes them eligible for long term capital gains ("LTCG"). From the observations of the preliminary inquiry it is inter alia noted that :- a) the fund brought in by way of preferential allotment was utilised for purposes other than those disclosed; b) even when substantial number of shares i.e. 91 lakh shares (455 lakh shares after split) were locked-in and non transferable / tradable, price of the scrip increased substantially to the extent of 7442% with a very small chunk of volume / purchases by certain entities; c) After the expiry of the lock-in period (i.e. in Patch I), the average volume increased astronomically to the extent of 505066% (5050 times).

Such increase in volume was mainly on account of matched trading amongst Radford Group & Suspected Entities and allottees. d) 46 out of the 48 preferential allottees sold 91.43% shares allotted to them by Radford at the price increased on account of the aforesaid manipulative trading in Pre-Patch I. 24. From the above facts and circumstances it can reasonably be inferred that the preferential allottees acting in concert with Radford Group & Suspected Entities have misused the stock exchange system to generate fictitious LTCG. It is pertinent to note that LTCG is tax exempt. 25. In the facts and circumstances of this case, I am of the view that preferential allotment was used as a tool for implementation of the dubious plan, device and artifice of Radford Group & Suspected Entities and preferential allottees. One could argue that in order to make LTCG, the preferential allottees in question could have bought in secondary market and waited for a year before selling the shares. In the instant case, probably the preferential allotment route was preferred over secondary market route because the share capital of Radford prior to preferential allotment was very small, i.e., 1,40,62,300 shares (Face Value: ₹ 10) to accommodate the required fictitious

LTCG of ₹313 crore approximately. As such the capital expansion through preferential allotment and stock split provided much bigger source to the persons involved in terms of volume and price manipulation to facilitate the whole operation. 26. Since prior to the trading in its scrip during the Examination Period, Radford did not have any significant financial standing in the securities market, in my view, the only way it could have increased its share value is by way of market manipulation. In this case, it is noted that the traded volume and price of the scrip increased substantially only after Radford Group & Suspected Entities and allottees started trading in the scrip. The average volume increased by 5,05,066 % (5050 times) during the Patch I, i.e., from 98 shares per day to 4,95,063 shares per day and the price increased by 74.8% during the same period, i.e., from ₹49.2 to ₹86. Radford Group & Suspected Entities were trading in the scrip above the LTP and their trades created artificial volumes and manipulated the price of the scrip during the examination period. It is further noted that on the days when Radford Group & Suspected Entities were not trading, the trading volumes in the scrip were very low and the substantial increase in traded volumes as observed in this case was mainly due to their trading.

I further note that Radford Group & Suspected Entities and allottees traded amongst themselves as substantiated by their matching contribution to net buy and net sell in Patch I. There was no change in the beneficial ownership of the substantial number of traded shares as the buyers and sellers both were part of the common group and were acting in league/concert to provide LTCG benefits to the allottees. In view of the above, I prima facie find that Radford Group & Suspected Entities and allottees used securities market system to artificially increase volume and price of the scrip for making illegal gains to and to convert ill-gotten gains into genuine one. 27. I am of the considered view that the scheme, plan, device and artifice employed in this case, apart from being a possible case of money laundering or tax evasion which could be seen by the concerned law enforcement agencies separately, is prima facie also a fraud in the securities market inasmuch as it involves manipulative transactions in securities and misuse of the securities market. The manipulation in the traded volume and price of the scrip by a group of connected entities has the potential to induce gullible and genuine investors to trade in the scrip and harm them.

As such the acts and omissions of Radford Group & Suspected Entities and allottees are ‘fraudulent’ as defined under regulation 2(1)(c) of the SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003 (‘PFUTP Regulations’) and are in contravention of the provisions of regulations 3(a), (b), (c) and (d) and 4(1), 4(2)(a), (b), (e) and (g) thereof and section 12A(a), (b) and (c) of the SEBI Act, 1992. The said regulations are reproduced hereunder:-

SEBI ACT Prohibition of manipulative and deceptive devices, insider trading and substantial acquisition of securities or control. "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;"

PFUTP REGULATIONS, 2003 "Prohibition of certain dealings in securities 3. No person shall directly or indirectly— (a) buy, sell or otherwise deal in securities in a fraudulent manner; (b) use or employ, in connection with issue, purchase or sale of any security listed or proposed to be listed in a recognized stock exchange, any manipulative or deceptive device or contrivance in contravention of the provisions of the Act or the rules or the regulations made there under; (c) employ any device, scheme or artifice to 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 or issue of securities which are listed or proposed to be listed on a recognized stock exchange in contravention of the provisions of the Act or the rules and the regulations made there under. 4. Prohibition of manipulative, fraudulent and unfair trade practices (1) Without prejudice to the provisions of regulation 3, no person shall indulge in a fraudulent or an unfair trade practice in securities. (2) Dealing in securities shall be deemed to be a fraudulent or an unfair trade practice if it involves fraud and may include all or any of the following, namely:- (a) indulging in an act which creates false or misleading appearance of trading in the securities market;

(b) dealing in a security not intended to effect transfer of beneficial ownership but intended to operate only as a device to inflate, depress or cause fluctuations in the price of such security for wrongful gain or avoidance of loss; (c)……………………………………………………………… (d)…………………………………………………… …………… (e)any act or omission amounting to manipulation of the price of a security; (f)…………………………………………………… ………………. (g) entering into a transaction in securities without intention of performing it or without intention of change of ownership of such security; " 28. I note that the directors of Radford during the relevant time (i.e. Prakash Bhawarlal Biyani, Manish Nareshchandra Shah, Rajesh Kumar Maheshwari and Nitin Shivratan Murarjka), being in control of the day to day affairs of Radford, had the knowledge of its acts and omissions. They were also under an obligation to ensure that acts and transactions of Radford were not in violation of any of the applicable provisions of SEBI Regulations or other applicable laws. I, therefore, prima facie find that these directors were responsible for Radford 's acts and omissions in this case.

29. I am of the opinion that a detailed investigation of the entire scheme employed in this case is necessary to find out the role of any other entity therein including LTP contributors, Suspected entities, connection amongst the concerned entities and the ultimate owners of funds used for manipulating the price of the scrip. Therefore, while SEBI would investigate into the probable violations of the securities laws, the matter may also be referred to other law enforcement agencies such as Income Tax Department, Enforcement Directorate and Financial Intelligence Unit for necessary action at their end as may be deemed appropriate by them. 30. SEBI strives to safeguard the interests of a genuine investor in the Indian securities market. The acts of artificially increasing the price of scrip mislead investors and the fundamental tenets of market integrity get violated with impunity due for such acts. Under the facts and circumstances of this case, I prima facie find that the acts and omissions of Radford Group & Suspected Entities and allottees as described above is inimical to the interests of participants in the securities market.

Therefore, allowing the entities that are prima facie found to be involved in such fraudulent, unfair and manipulative transactions to continue to operate in the market would shake the confidence of the investors in the securities market. 31. Considering these facts and the indulgence of a listed company in such a fraudulent scheme, plan, device and artifice as prima facie found in this case, I am convinced that this is a fit case where, pending investigation, effective and expeditious preventive and remedial action is required to be taken by way of ad interim ex -parte in order to protect the interests of investors and preserve the safety and integrity of the market.

32. In view of the foregoing, in order to protect the interest of the investors and the integrity of the securities market, I, in exercise of the powers conferred upon me in terms of section 19 read with section 11(1), section 11 (4) and section 11B of the SEBI Act, 1992, pending inquiry/investigation and passing of final order in the matter, hereby restrain the following persons/entities from accessing the securities market and buying, selling or dealing in securities, either directly or indirectly, in any manner, till further directions:-

Sr. No. Client Name Client PAN Company 1 Radford Global Ltd. AABCM5771E Directors of Radford Global Ltd. 2 Prakash Bhawarlal Biyani AJNPB0702E 3 Manish Nareshchandra Shah AELPS8560A 4 Rajesh Kumar Maheshwari ACJPM4653L 5 Nitin Shivratan Murarka AMBPM9321M Promoters of Radford Global Ltd. 6 Radford InvestmentServicesPvtLtd AACCG9982A Director of Radford Investment Services Pvt. Ltd. 7 Roshan Dwarkani ATXPD7040B 8 Suresh Kumar Saini BCXPS0818J Preferential Allottees 9 AachalchandBalar ABAPB8617M 10 PiyushKumarBalar AEMPB6394Q 11 AbhishekKumarBalar AATPB8811B 12 AfsarZaidi AADPZ8571G 13 AmreshA.Mody AACPM4024E 14 HasumatiA.Mody AJSPM7935P 15 AnilRajatAgarwal&Sons.Huf. AAFHA0709M 16 AshokBJiwrajka AACPJ3610K 17 BabitaMittal AAIPG4573G 18 BimalJDesasi AAKPD3160A 19 BrijBhushanSingal AEFPS6298M

20 DalsukhUjamshiTrevadia ACDPT3428N 21 DilipBJiwrajka AAGPJ8756J 22 DilipChotalalMorzaria AADPM9919M 23 GMPrasannaKumar AHEPG0025A 24 GSAnithKumar ADPPK9874N 25 HariKishanSuderlalVermani AAJPV4754H 26 HiteshMangilalJain AABPJ2835R 27 HukamsinghB.Rajpurohit AABPR9949J 28 JyotiAnilTrevadia ABWPT8000C 29 JyotsnaJitendraDesai AHPPD4223L 30 KalpitaLuniya AAAPL9611J 31 KamalPunwani AFFPP5207G 32 LingarajuGM AEYPM5850Q 33 MayuriDarshanBhanushali AKJPB8572F 34 MohanMittal APFPM0496Q 35 MohitAggarwal ADSPA9301K 36 MukeshMittal AJGPM2125D 37 NareshNemchandShah ACRPS0182J 38 NeerajSingal ANRPS7986B 39 NishitAgarwalBenTrust AABTN3350K 40 PinkyAgarwal ACGPA7438L 41 PratikAgarwalBenTrust AABTP7516K 42 PraveenKumarAgarwal ACSPA4725A 43 PraveenKumarAgarwalHuf AAIHP6229C 44 RajendraMangilalJain ACPPJ9853R 45 RenuAggarwal AAEPA1694C 46 RenuMittal AGMPM1488Q 47 RituSingal ABHPS3711M 48 SantoshAggarwal ABAPA4548E 49 ShaileshMangilalJain AAAPJ6765F 50 ShilpaAggarwal AEXPA1230M 51 SmtUjwalaNamdevMane AAEPM5924H 52 SurendraBJiwrajka AACPJ4316L 53 SushantInvestments ACAFS8650G 54 TanviBhavikTrevadia AFAPT5888A 55 TarunAggarwal AOQPA9034E 56 UmaSingal ANRPS7987A 57 YogeshPopatlalThakkar AAPPT1825P

Radford Group 58 Amrit Sales Promotion Pvt Limited AACCA3220D 59 Amrusha Mercantile Private Ltd AALCA0340D 60 Anjali Suppliers Private Limited AAJCA1784D 61 Apex Commotrade Private Limited AAJCA4459K 62 Avlokan Dealcom Private Limited AALCA1583G 63 Bazigar Trading Private Limited AABCB3052B 64 Blue Circle Services Limited AAACB2131L 65 Burlington Finance Limited AABCB2575P 66 Devakantha Trading Private Limited AADCD7044B 67 Devatma Distributors Private Limited AADCD7140G Dhanleela Investments & Trading Company 68 AAACR1770P Limited 69 Dhanraksha Vincom Pvt Ltd. AADCD6028P 70 Divya Drishti Traders Pvt Ltd AABCD8146J 71 Divyadrishti Merchants Pvt Ltd AABCD8147K 72 Esquire Enclave Private Limited AACCE7065J 73 Katyani Commodities Private Limited AAECK6244R 74 Kingfisher Properties Private Limited AAECK3394G 75 Ladios Trading Private Limited AACCL3868N 76 Limestone Properties Private Limited AACCL0133G 77 Manimudra Vincom Private Limited AADCM4316K 78 Natural Housing Private Limited AADCN6251G 79 Pine Animation Limited AAECM0267A 80 Pyramid Trading And Finance Ltd AAACP2548R 81 Radison Properties Private Limited AAFCR2818B 82 Rangan Vincom Private Limited AAGCR1715E 83 Ridhi Vincom Pvt Ltd AAECR9858C 84 Runicha Merchants Private Limited AAECR0580M 85 Sanklap Vincom P Ltd AAMCS1711P 86 Scope Vyapar Private Limited AAICS6023N 87 Shelter Sales Agency Pvt Ltd # AASCS1797F 88 Shivkhori Construction Private Limited AAPCS7850L 89 Signet Vinimay Private Limited AAMCS1712Q 90 SKM Travels Private Limited AAICS0688K 91 Spice Merchants Private Limited AAPCS7492G 92 Symphony Merchant Pvt Ltd AADCS5411K 93 Topwell Properties Private Limited AADCT8403C 94 Udbal Mercantile Private Limited AABCU2648C

95 Vibgyor Financial Service Pvt Ltd AAACV8378B 96 Winall Vinimay Private Limited AAACW8004B Suspected Entities 97 Jayant Security & Financeltd AAACJ4848G 98 Trimurthi Finvest Ltd AAACT6383N 99 Purvi Finvest Limited AABCP6564C 100 East West Finvest India Limited AAACE6834D 101 East West Finvest India Limited AADCE1236G Other 102 Taran Kumar Rungta ASVPR5947G 103 Prem Lata Nahar AFAPN8764M 104 Manjulaben Sukhdev Pandya ALVPP7764J 105 Rajat Share Broking Pvt Ltd AAACR2695B 106 Rajesh Pravinkumar Jasani ACWPJ4705B 107 Bharat Bagri Bagri AADHB8488A 108 Jayesh Narendra Kesharia AAEHJ1610D

33. This order is without prejudice to the right of SEBI to take any other action that may be initiated against the aforementioned entities in accordance with law.

34. This order shall come into force with immediate effect. The Stock exchanges and the depositories are directed to ensure that all the above directions are strictly enforced.

35. 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 themselves of an opportunity of personal hearing before the Securities and Exchange Board of India, on a date and time to be fixed on a specific request, received from the said persons/entities.

Sd/- DATE:DECEMBER 19, 2014 RAJEEV KUMAR AGARWAL PLACE: MUMBAI WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA

Annexure A: List of Preferential Allottees as received from BSE

Permanent No. of Qty Post Stock Sr. Name of the Allottee Account shares Split (Jan 29, No. Number (PAN) allotted 2013) ABAPB8617M/ AachalchandBalar/PiyushKumarBal 1 AEMPB6394Q/ 150000 750000 ar/AbhishekKumarBalar AATPB8811B 2 AfsarZaidi AADPZ8571G 100000 500000 AACPM4024E/ 3 AmreshA.Mody/HasumatiA.Mody 100000 500000 AJSPM7935P 4 AnilRajatAgarwal&Sons.Huf. AAFHA0709M 60000 300000 5 AshokBJiwrajka AACPJ3610K 250000 1250000 6 BabitaMittal AAIPG4573G 150000 750000 7 BimalJDesasi AAKPD3160A 200000 1000000 8 BrijBhushanSingal AEFPS6298M 580000 2900000 9 DalsukhUjamshiTrevadia ACDPT3428N 100000 500000 10 DilipBJiwrajka AAGPJ8756J 250000 1250000 11 DilipChotalalMorzaria AADPM9919M 200000 1000000 12 GloryInvestmentServicesPvtLtd AACCG9982A 340000 1700000 13 GMPrasannaKumar AHEPG0025A 200000 1000000 14 GSAnithKumar ADPPK9874N 200000 1000000 15 HariKishanSuderlalVermani AAJPV4754H 100000 500000 16 HiteshMangilalJain AABPJ2835R 100000 500000 17 HukamsinghB.Rajpurohit AABPR9949J 100000 500000 18 JyotiAnilTrevadia ABWPT8000C 100000 500000 19 JyotsnaJitendraDesai AHPPD4223L 200000 1000000 20 KalpitaLuniya AAAPL9611J 100000 500000 21 KamalPunwani AFFPP5207G 100000 500000 22 LingarajuGM AEYPM5850Q 200000 1000000 23 MayuriDarshanBhanushali AKJPB8572F 100000 500000 24 MohanMittal APFPM0496Q 150000 750000 25 MohitAggarwal ADSPA9301K 150000 750000 26 MukeshMittal AJGPM2125D 150000 750000 27 NareshNemchandShah ACRPS0182J 400000 2000000 28 NeerajSingal ANRPS7986B 580000 2900000

29 NishitAgarwalBenTrust AABTN3350K 200000 1000000 30 PinkyAgarwal ACGPA7438L 200000 1000000 31 PratikAgarwalBenTrust AABTP7516K 200000 1000000 32 PraveenKumarAgarwal ACSPA4725A 200000 1000000 33 PraveenKumarAgarwalHuf AAIHP6229C 200000 1000000 34 RajendraMangilalJain ACPPJ9853R 100000 500000 35 RamchandraSatre ACAPS9829D 100000 500000 36 RenuAggarwal AAEPA1694C 150000 750000 37 RenuMittal AGMPM1488Q 150000 750000 38 RituSingal ABHPS3711M 515000 2575000 39 SantoshAggarwal ABAPA4548E 150000 750000 40 ShaileshMangilalJain AAAPJ6765F 100000 500000 41 ShilpaAggarwal AEXPA1230M 150000 750000 42 SmtUjwalaNamdevMane AAEPM5924H 100000 500000 43 SurendraBJiwrajka AACPJ4316L 250000 1250000 44 SushantInvestments ACAFS8650G 250000 1250000 45 TanviBhavikTrevadia AFAPT5888A 100000 500000 46 TarunAggarwal AOQPA9034E 150000 750000 47 UmaSingal ANRPS7987A 225000 1125000 48 YogeshPopatlalThakkar AAPPT1825P 200000 1000000 Total 9100000 45500000

Annexure B: Radford Group & Suspected Entities and the basis of connection /relationship amongst them.

Based on the KYC and Bank Statement analysis, off market analysis, data available with the exchange and MCA details, Radford Group & Suspected Entities were observed to be dealing in the scrip during the period of examination. Their basis of connection and transaction details is given below:

Sr Client Name and Member Name Basis of Connection No PAN and Code Radford Group On analyzing the bank statement submitted by the Dhanleela trading member ‘Gepl Capital Pvt. Ltd ’ for its Investments & client ‘Dhanleela Investments & Trading Company Trading Company GEPL Capital Pvt. Limited’, it was observed that the client has 1 Limited Ltd. (724) received / transferred funds from / to the company ‘Radford Global Limited’. It was also (AAACR1770P) observed that it has transferred funds to ‘Neeraj Singal’, ‘Brij Bhushan Singal’ and ‘Ritu Singal’ On analyzing the bank statement submitted by the Pyramid Trading trading member ‘C.D Equisearch Pvt Ltd’ for its And Finance Ltd C.D.Equisearch client ‘Pyramid Trading and Finance Limited’, it 2 Pvt.Ltd. (87) was observed that the client has received / (AAACP2548R) transferred funds from / to the company ‘Radford Global Limited’ On analyzing the bank statement submitted by the trading member ‘C.D Equisearch Pvt Ltd’ for its Pine Animation client ‘Pyramid Trading and Finance Limited’, it Limited Mehta Equities was observed that the client has transferred funds 3 Ltd. (122) to the ‘Pine Animation Limited’. From the analysis of bank statement of Pine Animation Limited, it (AAECM0267A) was observed that funds were transferred to one Entity Blue Circle Services Ltd. Amrit Sales From the analysis of bank statement of Amrit Sales Promotion Pvt Arch Finance Ltd. 4 Promotion Pvt. Ltd., it was observed that funds Limited (3257) were received from Blue Circle Services Ltd. (AACCA3220D) Burlington Finance Arch Finance Ltd. 5 Limited As per bank statement of the client 'Amrit Sales (3257) (AABCB2575P) Promotion Pvt Limited', it has received / Symphony transferred funds from / to 'Burlington Finance Arch Finance Ltd. 6 Merchant Pvt Ltd Limited' and 'Symphony Merchant Pvt Ltd'. (3257) (AADCS5411K)

The client 'Bazigar Trading Private Limited' and the Bazigar Trading client 'Amrit Sales Promotion Pvt Limited' have Private Limited Arch Finance Ltd. 7 common phone number and email-id viz, (3257) '9831714151' and 'apareek1@hotmail.com, (AABCB3052B) naloo.kol@gmail.com' respectively. Manimudra As per UCC database updated by the trading Vincom Private member ‘Arch Finance Ltd’ for its clients entity viz. Limited Arch Finance Ltd. Bazigar Trading Private Limited (S.No 41) and 8 (3257) ‘Manimudra Vincom Private Limited have same (AADCM4316K) address viz, ‘19 R.N. Mukherjee Lane, 2nd Floor, Kolkata, West Bengal-700001’ Blue Circle Mehta Equities 9 Services Limited Ltd. (122) (AAACB2131L) Devatma The clients 'Blue Circle Services Limited', 'Devatma The Calcutta Distributors Distributors Private Limited' and 'Anjali Suppliers 10 Stock Exchange Private Limited Private Limited' has common email id viz, Ltd. (990) (AADCD7140G) dhruvonarayan.jha@rediffmail.com' Anjali Suppliers Madhya Pradesh 11 Private Limited Stock Exchange (AAJCA1784D) Ltd. (991) Rangan Vincom The Calcutta Rangan Vincom Private Limited' has transferred 12 Private Limited Stock Exchange shares to 'Devatma Distributors Private Limited' in (AAGCR1715E) Ltd. (990) the off market. Katyani As per the MCA website, ‘Rangan Vincom Private The Calcutta Commodities Limited’ and ‘Katyani Commodities Private 13 Stock Exchange Private Limited Limited’ have common address viz, ‘4, N.S Road, Ltd. (990) (AAECK6244R) 1st Floor, Kolkata, West Bengal-700001’. Ladios Trading The Calcutta 14 Private Limited Stock Exchange Rangan Vincom Private Limited', 'Ladios Trading (AACCL3868N) Ltd. (990) Private Limited', 'Avlokan Dealcom Private Avlokan Dealcom The Calcutta Limited' has common phone number viz, 15 Private Limited Stock Exchange '9831432937'. (AALCA1583G) Ltd. (990)

On analyzing the bank statement of the client it was observed that the client has received / transferred funds from / to 'Esquire Enclave Private Limited’, ‘Fairlink Housing Pvt Ltd’. Further, from the bank statement analysis, the client 'Kingfisher Properties Pvt. Ltd.' has also transferred the funds to 'Signet Vinimay Pvt Ltd'. On analyzing the bank statement Kingfisher of the Fairlink Housing Pvt. Ltd., it was observed Properties Private that the client had received / transferred funds Limited from / to group entities viz, 'Kingfisher Properties Private Limited', 'Divyadrishti Merchants Private Limited', 'Divyadrishti Traders Pvt Ltd'. Further, the client has also received / transferred funds to Gateway Financial its other connected / related entities viz, ‘Topwell 16 Services Ltd. Properties Pvt Ltd’. On analyzing the bank (3199) statement received from the trading member ‘Korp Securities Ltd’ for its client ‘Fairlink Housing Private Limited’, it was observed that the said entity has received funds from an entity viz, ‘Venkatesh Sales Pvt Ltd’ which as per the MCA website has the common address as that of one of the director viz, ‘Dhruv Narayan Jha’ of the company ‘Blue (AAECK3394G) Circle Services Limited’ viz, ‘P-27, Princep Street, 3rd Floor, Kolkata, West Bengal – 700072’.

Further, as per MCA website the email address of ‘Venkatesh Sales Pvt Ltd’ and ‘Blue Circle Services Ltd’ is common viz, ‘dhruvonarayan.jha@rediffmail.com’. On analyzing bank statement of the Topwell Properties Private Limited, it was observed that Topwell Properties funds were received/transferred among Esquire Private Limited Enclave Private Limited, Radison Properties Gateway Financial Private Limited, Kingfisher Properties Private 21 Services Ltd. Limited, Shivkhori Construction Pvt. Ltd. Natural (3199) Housing Private Limited And Limestone Properties (AADCT8403C) Private Limited. Funds were also transferred to Signet Vinimay Pvt. Ltd.and Sankalp Vincom Pvt. Ltd. Esquire Enclave Gateway Financial The clients 'Kingfisher Properties Private Limited', 17 Private Limited Services Ltd. ‘Esquire Enclave Private Limited’, 'Radison (AACCE7065J) (3199) Properties Private Limited', 'Shivkhori Construction Radison Properties Gateway Financial Private Limited', 'Limestone Properties Private 18 Private Limited Services Ltd. Limited', 'Topwell Properties Private Limited' and (AAFCR2818B) (3199) 'Natural Housing Private Limited' has common Shivkhori Gateway Financial address, email id and common directors viz, ‘95A – 19 Construction Services Ltd. C.R Avenue, 1st Floor, Kolkata, West Bengal – Private Limited (3199) 700073’, ‘roc2011@in.com’ and ‘Vishal Sharma’

(AAPCS7850L) and ‘Chiranjit Mahanta’. Limestone Gateway Financial Properties Private 20 Services Ltd. Limited (3199) (AACCL0133G) Natural Housing Gateway Financial 22 Private Limited Services Ltd. (AADCN6251G) (3199) Millennium Stock Divyadrishti Broking Private Merchants Pvt Ltd 23 Limited (6151) Korp Securities (AABCD8147K) Ltd. (6213) As per the KYC submitted by the trading member Millennium Stock Divya Drishti 'Korp Securities Ltd.' for its clients 'Divyadrishti Broking Private Traders Pvt Ltd Merchants Pvt Ltd', 'Divya Drishti Traders Pvt 24 Limited (6151) Ltd', 'Dhanraksha Vincom Pvt Ltd.' and 'Ridhi Korp Securities (AABCD8146J) Vincom Pvt Ltd', all the clients have common Ltd. (6213) address viz, '163 B, M.G Road, 3rd Floor, Kolkata Dhanraksha Korp Securities – West Bengal – 700007'. 25 Vincom Pvt Ltd. Ltd. (6213) (AADCD6028P) Ridhi Vincom Pvt Korp Securities 26 Ltd Ltd. (6213) (AAECR9858C) Runicha The Calcutta Merchants Private 27 Stock Exchange Limited As per the KYC submitted by the trading member Ltd. (990) (AAECR0580M) 'The Calcutta Stock Exchange Ltd' for its clients Signet Vinimay The Calcutta 'Runicha Merchants Private Limited', 'Signet 28 Private Limited Stock Exchange Vinimay Private Limited', 'Winall Vinimay Private (AAMCS1712Q) Ltd. (990) Limited' and 'Sanklap Vincom P Ltd' and as per the Winall Vinimay The Calcutta MCA Website, all the clients have common address 29 Private Limited Stock Exchange viz, '23/1, Principal Khudiram Bose Road, Kolkata, (AAACW8004B) Ltd. (990) West Bengal – 700006’ and common directors viz, Sanklap Vincom P The Calcutta ‘Abhiset Basu’ and ‘Pradip Dey’. 30 Ltd Stock Exchange (AAMCS1711P) Ltd. (990) Spice Merchants The Calcutta As per the KYC submitted by the trading member 31 Private Limited Stock Exchange 'The Calcutta Stock Exchange Ltd' for its clients (AAPCS7492G) Ltd. (990) 'Runicha Merchants Private Limited', 'Signet Apex Commotrade Vinimay Private Limited', 'Winall Vinimay Private Private Limited The Calcutta Limited', 'Spice Merchants Private Limited' and 32 Stock Exchange 'Apex Commotrade Private Limited Ltd', all clients (AAJCA4459K) Ltd. (990) have common email id viz, ‘limited_kol@yahoo.in’ and common phone number viz, ‘9836488845’

Devakantha As per the bank statement submitted by the trading Trading Private member 'Vishesh Capital Pvt.Ltd.' for its client Vishesh Capital 33 Limited # 'Devakantha Trading Pvt Ltd', it was observed that Pvt.Ltd. (3272) the client has received / transferred fund from / to (AADCD7044B) 'Spice Merchants Pvt Ltd'. Anand Rathi Share Shelter Sales As per the KYC submitted by the trading member & Stock Brokers Agency Pvt Ltd # 'Vishesh Capital Pvt.Ltd.' for its client 'Devakantha Ltd. (949) Trading Pvt Ltd' and 'Anand Rathi Share & Stock Progressive Share 34 Brokers Ltd.' and 'Comfort Securities Ltd' for its (AASCS1797F) Brokers Pvt.Ltd. client 'Shelter Sales Agency Pvt Ltd', both the (967) clients have common phone number viz, Comfort Securities '8108780561'. Ltd. (3186) As per the KYC submitted by the trading member Sunteck 'Vishesh Capital Pvt.Ltd.' for its client 'Devakantha Udbal Mercantile Wealthmax Capital Trading Pvt Ltd' and 'Sunteck Wealthmax Capital Private Limited # Private Limited Private Limited' and 'Vishesh Capital Pvt.Ltd.' for (3070) its client 'Udbal Mercantile Private Limited', ‘Rekha 35 Arvind Gaud’ and ‘Kalavatidevi Pratap Narayan Gaud’ who are directors of ‘Devakantha Trading Private Limited’ and ‘Udbal Mercantile Private Vishesh Capital (AABCU2648C) Limited’ respectively has common address viz, Pvt.Ltd.

(3272) ‘Safalya 806 A, Mahavir Nagar, Kandivali West, Mumbai – 400067’. Amrusha Anand Rathi Share As per the KYC submitted by the trading member Mercantile Private & Stock Brokers 'Vishesh Capital Pvt.Ltd.' for its client 'Udbal Ltd # Ltd. (949) Mercantile Private Limited' (S.No 16) and 'Anand Progressive Share 36 Rathi Share & Stock Brokers Ltd.' and 'Comfort (AALCA0340D) Brokers Pvt.Ltd. Securities Ltd' for its client 'Amrusha Mercantile (967) Private Ltd', both the clients has common phone Comfort Securities number viz, ‘8108780562’. Ltd. (3186) SKM Travels Gateway Financial The company 'Winall Vinimay Private Limited’ 37 Private Limited Services Ltd. (S.No 9) and 'SKM Travels Private Limited' have (AAICS0688K) (3199) common director viz, 'Abhiset Basu’. As per the bank statement submitted by the trading Scope Vyapar Gateway Financial member ‘The Calcutta Stock Exchange Ltd' for its Private Limited 38 Services Ltd. client 'Winall Vinimay Pvt Ltd', it was observed that (3199) the client has received / transferred fund from / to (AAICS6023N) Scope Vyappar Pvt Ltd' Vibgyor Financial The client ‘Vibgyor Financial Service Pvt Ltd’ has India Infoline Ltd 39 Service Pvt Ltd received shares in off market from ‘Scope Vyapar (AAACV8378B) Private Limited’.

Suspected Entities Trimurthi Finvest Exclusive As per the KYC submitted by the trading member 1 Limited Securities Ltd. 'Exclusive Securities Ltd.' for its clients 'Trimurthi (6369) Finvest Limited' and 'Purvi Finvest Limited', both the company have common address viz, '9, Bhoj ATS Share Nagar, Annpurna Road, Indore - 452009' (AAACT6383N) Brokers Pvt. Ltd. (6481) India Infoline Limited (179) ATS Share Purvi Finvest Brokers Pvt. Ltd. Limited (6481) 2 Exclusive (AABCP6564C) Securities Ltd. (6369) As per the MCA website and also as per the KYC East West Finvest submitted by the trading member 'Exclusive Exclusive India Limited Securities Ltd.' for its clients 'Trimurthi Finvest 3 Securities Ltd. Limited' (S.No 1) and 'East West Finvest India (6369) (AAACE6834D/ Limited', both the companies have common AADCE1236G) director viz, 'Sharad Kumar Darak'. Exclusive Jayant Security & Securities Ltd. As per the MCA website 'Trimurthi Finvest Finance Ltd (6369) Limited' (S.No 1) and 'Jayant Security & Finance 4 ATS Share Ltd', both the companies have common email id (AAACJ4848G) Brokers Pvt. Ltd. viz, 'caashwinsethi@gmail.com' (6481)

Sd/- DATE:DECEMBER 19, 2014 RAJEEV KUMAR AGARWAL PLACE: MUMBAI WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA