Order in the matter of Spectacle Infotek Limited-1 and 2

WTM/RKA/EFD-DRA-II/ 06/2016 BEFORE THE SECURITIES AND EXCHANGE BOARD OF INDIA ORDER Under sections 11(4) and 11B of the SEBI Act, 1992 in the matter of Spectacle Infotek Ltd. – in respect of: 1. Mr. Bharat Thakkar AAZPT9542R 2. Mr. Bipin J Thaker ABYPT4984H 3. Mr. Kishore Chauhan AFPPC9703G 4. Mr. Bhavesh Pabari AKGPP8679N 5. Mr. Prem Mohanlal Parikh ALHPP3489N 6. Mr. Hemant Madhusudan Sheth ANOPS8607E 7. Ms. Mala Hemant Sheth AZXPS0694J 8. Mr. Ankit Sanchaniya BLNPS3316L 9. Mr. Narendra Prabodh Ganatra AEMPG4315C 10. Mr. Bhupesh Rathod AACPR3785K 11. Mr. Bipinkumar Gandhi AJHPG6989J

1. SEBI initiated investigation into the trading in certain scrips including Spectacle Infotek Ltd. (SIL) pursuant to the detection of a huge rise in the traded volumes and/or price of these scrips during the years 2008, 2009 and 2010. Upon analysis of the trading activity in the above scrip, it was prima facie observed that certain entities had indulged in synchronized trades, self trades and also carrying out off-market transfers among themselves for the purpose of meeting settlement obligations of another, thus contributing to creating artificial volume in the scrip. 2. In view of the above, in order to protect the interests of investors and to preserve the safety and integrity of the market, SEBI passed an interim Order dated February 02, 2011 restraining 39 persons/entities from accessing the securities market and further prohibited them from buying, selling or dealing in securities in any manner whatsoever, till further directions. SEBI initiated an investigation relating to buying, selling or dealing in the shares of the above mentioned scrips to inter alia ascertain the violation of the provisions of the SEBI Act, Rules and Regulations. The said interim order was later confirmed by SEBI vide order dated July 08, 2011 (‘Confirmatory Order’) in respect of 5 entities only which did not include the abovementioned entities. 3. SEBI initiated an investigation relating to buying, selling or dealing in the shares of the scrip of SIL inter alia to ascertain the violation of the provisions of the Securities and Exchange Board of Order in the matter of Spectacle Infotek Limited

India Act, 1992 ("SEBI Act") and the Rules and Regulations made there under. The period of investigations were taken as from May 29, 2009 to April 30, 2010 (hereinafter referred to as "Investigation period SIL-1") and from May 01, 2010 to January 31, 2011 hereinafter referred to as "Investigation period SIL-2"). Investigation inter alia revealed that – (i) Certain connected/ related entities had entered into manipulative trades in the scrip of SIL during the aforementioned periods. The relationship/ connection between the entities were determined based on at least one of the following parameters: (a) Similarities in the particulars/details in the KYC documents such as common telephone number, addresses, electronic mail (e-mail) addresses, etc. (b) Trading activity in terms of buy/sell among the group and the frequency and off-market transfers between them (c) Fund transfers between the members of the said group. (ii) On the basis of the said criteria, one group was identified as the "Pabari-Parikh" group ("PP group"). The members of the PP group and the basis of relationship/connection amongst them are as follows: Table 1: Relationship among the PP group entities Sl. No. Client Name KYC Relation Fund Share Movement movement through off market 1. G emstone Sl. no.10 is the director in sl. Investments Ltd No.1. Sl. no.10 and 17 have common office address. Sl. no.10 introduced sl. no.17 for trading a/c. 2. Bh upesh Rathod Introduced sl. no.22, 19, 17, 12 With Sl. No. 27 for trading a/c and knows sl. No. 25 3. Ketan Babulal With sl. no.19 Shah 4. Ra jnandi Yarns Sl. no. 17 and 22 both directors of With sl. no. 5, 6, Private Limited Rajnandi Yarns Pvt. Ltd.(sl.no.4) 11, 12, 17, 19, 22, 23, 27, 28, 5. Bh arat Shantilal Sl. no. 17 is his nephew. With sl. no. 17, With sl. no. 17, 7,

Thakkar Same address with sl. no.17. 19, 27 4, Sl. no. 17 is his nominee. Joint a/c with sl. no. 17. BR* with sl. no. 6, 11, 12, 19, 22, 27, 28 6. Bi pin Jayant Same Tel. no. with sl. no. 17. With sl. no. 4, 17. With sl. no. 4, 23, Thaker BR* with sl. no. 5, 11, 12, 17, 19, 11, 17, 19, 22. 22, 27, 28, 7. V asudev Sl. no. 5 share the same address With sl. no.5 Ramchandra with sl. no.17. Kamat 8. Bh arat G Vaghela Same address and Tel.no. as sl. With sl. no. 11. no. 16 who share movement with sl.no. 17. Sl. No. 11 is nephew of sl. no. 17 and shares same Tel. no. with sl. no. 17. 9. Sa gar Janak Vyas Similar address as sl.no. 19. 10. N arendra Prabodh Sl. no.10 is the director in sl. Ganatra No.1. Sl. no.10 was a director in Spectacle (resigned from the said company on June 01, 2010). Sl. no.10 and 17 have common office address. Sl. no.10 introduced sl. no.17 for trading a/c. 11. Ch irag Rajnikant Same Tel. no. with sl.no.17. With sl. no. 17, With sl. no. 4, 6 Jariwala Sl. no. 17 is his uncle. 22, 8, 4 BR* with sl. no. 5, 6, 12, 17, 22, 27, 28. 12. K ishore Chauhan Joint a/c with sl. no. 17 With sl. no. 17, With sl. no. 4, 17, Sl. no. 17 and 22 are witness for 19, 22 19, 22, 28, demat a/c. BR* with sl. no. 5, 6, 11, 17, 19, 22, 27.

13. M anish Suresh Sl. no.10 introduced sl. no.13 for Joshi trading a/c. 14. K aushik Same Tel. no. with sl. no. 16. Sl. no. 16 has Sl. no. 16 has off- Gangaram Rathod fund movement market transfers with sl.no. 17. with sl. no. 17. 15. Sa ntosh Vishram Has off market share and fund Ghadshi movement with Amar Premchand Walmiki, who has off market share and fund movement with sl. no. 17. 16. Bi pinkumar With sl. no. 17. Gandhi 17. Bh avesh Pabari Sl. no.10 and 17 have common With sl. no. 19, office address. 22, 4, 5, 6, 27, 28, Sl. no.10 introduced sl. no.17 for 16, trading a/c. Sl. no. 5 is his uncle and sl. no. 28 is his brother in law. Sl. no. 19 is cousin of sl. no.17 Sl. no. 17 and 22 both directors of Rajnandi Yarns Pvt. Ltd.(sl.no.4) Share common Tel. no. with sl. no. 27, 28, 6. Sl. no. 2 introduced him for trading a/c. BR* with sl. no. 6, 11, 12, 19, 22, 25, 27 18. K aushik With sl. no. 17. With sl. no. 28. Karsanbhai Patel 19. Pr em Mohanlal Sl. no. 19 is cousin of sl. no.17. With sl. no. 17, With sl. no. 17, Parikh Common email with sl. 27, 19 and 22, 12. 22, 12, 4, 5, 6, 22, 28. 23, 27, 28. Sl. no. 22 is nominee of sl. no.19. BR* with sl. no. 5, 6, 11, 12, 17, 22, 27, 28. 20. Sa ntosh Maruti Sl. no.10 introduced sl. no.20 for With sl. no. 10.

Patil opening a/c with the member Comfort Securities. 21. K aushik Rajnikant With sl. no. 24, With sl. no. 17, Mehta 15. 24. 22. H emant Sl. no. 17 and 22 both directors of With sl. no. 17, With sl. no. 17, Madhusudan Rajnandi Yarns Pvt. Ltd. 19, 12. 19, 12, 4, 25, 27, Sheth Same email with sl. no. 28. 28, 23, 6, BR* with 2, 5, 19, 27, 28, 6, 11, 12, and sl. no. 25 is his wife and sl. no. 26 is his nephew. 23. Jig ar Praful With sl. no. 4, 6, Ghoghari 19, 22, 27. 24. V ipul Hiralal Shah Sl. No. 21 has off-market With sl. No. 21. With sl. no.17. transaction with sl. No. 17. 25. M ala Hemant Sl. no. 25 is the wife of sl. no. 22 With sl. no. 17, With sl. no. 22, Sheth and sl. no. 26 is the nephew. 19..

26. G aurang Ajit Seth Has common address and Tel. no. with sl. no. 22. and sl. no. 22 and 17 both directors of Rajnandi Yarns Pvt. Ltd.(sl.no.4) 27. A nkit Sanchaniya Same Tel. no. with sl. no. 19 and With sl. no. 17, With sl. no. 4, 17, also shares Tel. no. with sl. no. 17 19. 19, 22, 11, 23, 28. who is the nominee for his a/c. BR* with sl. no.5, 6, 11, 12, 17, 19, 22, 28, 28. V ivek Kishanpal Sl. no. 17 is the brother in law and With sl. no. 22. With sl. no. 4, 17, Samant shares common Tel. no. and sl.no. 22, 11, 12, 19, 27. 17 is the nominee of sl. no. 28 for trading a/c and bank a/c. Shares email with sl. no. 22. Shares email with sl. no. 19.

(iii) The PP group entities including the above mentioned 11 entities i.e., Mr. Bharat Thakkar, Mr. Bipin J Thaker, Mr. Kishore Chauhan, Mr. Bhavesh Pabari, Mr. Prem Mohanlal Parikh, Mr. Hemant Madhusudan Sheth, Mr. Mala Hemant Sheth, Mr. Ankit Sanchaniya, Mr. Bipinkumar

Gandhi, Mr. Narendra Prabodh Ganatra and Bhupesh Rathod had traded on NSE and BSE during the 'investigation period SIL-1'. (iv) Out of the above 11 entities, 9 entities, i.e., Mr. Bharat Thakkar, Mr. Bipin J Thaker, Mr. Kishore Chauhan, Mr. Bhavesh Pabari, Mr. Prem Mohanlal Parikh, Mr. Hemant Madhusudan Sheth, Mr. Mala Hemant Sheth, Mr. Ankit Sanchaniya and Mr. Bipinkumar Gandhi had traded during the 'investigation period SIL-2'. (v) Several of the trades of these entities in the scrip of SIL were synchronized amongst themselves and the members of the group. The summary of the synchronized trades by these entities on NSE and BSE during investigation period SIL1 and SIL2 were observed as follows: Table 2- Synchronized Trades of the entities on BSE in the scrip during investigation period SIL-1 Sl. Client Name Synchroni % of % of sync to Synchroni % of % of No. sed buy Market total buy by sed sale Market sync to trade Volume client trade Volume total sale by client 1. Bharat Shantilal 472579 0.28 7.68 603777 0.36 6.35 Thakkar 2. Bipin Jayant 340208 0.2 7.15 123790 0.07 3.24 Thaker 3. Kishore Chauhan 288616 0.17 4.84 675839 0.4 8.39 4. Bipinkumar 14698 0.01 2.45 11375 0.01 1.18 Gandhi 5. Bhavesh Pabari 486521 0.29 5.2 550177 0.33 2.66 6. Prem Mohanlal 356139 0.21 3.88 315428 0.19 4.11 Parikh 7. Hemant 865351 0.51 4.27 684574 0.41 3.06 Madhusudan Sheth 8. Mala Hemant 28900 0.02 5.79 8727 0.01 1.39 Sheth 9. Ankit Sanchaniya 572209 0.34 5.5 295844 0.18 2.96 Grand Total 3425221 2.03 46.76 3269531 1.96

Table -3, Synchronized Trades of the entities on NSE in the scrip during investigation period SIL-1 Sl. Client Name Synchronised % of % of Synchronised % of % of sync to No. buy trade Market sync to sale trade Market total sale by Volume total Volume client buy by client 1. Bharat Shantilal 150328 0.67 18.67 26899 0.12 4.02 Thakkar 2. Bipin Jayant 75065 0.33 4 68722 0.3 3.48 Thaker 3. Kishore Chauhan 157814 0.7 13.69 100955 0.45 9.59 4. Bipinkumar 0 0 0 60000 0.27 24.16 Gandhi 5. Bhavesh Pabari 103491 0.46 39.67 28120 0.12 7.44 6. Prem Mohanlal 62910 0.28 6.61 59670 0.26 13.22 Parikh 7. Hemant 127167 0.56 5.06 354619 1.57 12.88 Madhusudan Sheth 8. Ankit Sanchaniya 196242 0.87 9.61 199289 0.88 8.86 Grand Total 873017 3.87 97.31 898274 3.97

Table 4, Synchronized Trades of the entities on BSE in the scrip during investigation period SIL-2 Sl. Client Name Synchronised % of % of sync Synchronised % of % of sync No. Buy Market to total Sale Market to total Volume buy by Volume sale by client client 1 Bharat Shantilal 24451 0.03 1.75 41115 0.04 2.71 Thakkar 2 Bipin Jayant 123874 0.13 2.57 211685 0.23 3.69 Thaker 3 Kishore 32156 0.03 1.46 1300 0 0.05 Chauhan 4 Bhavesh Pabari 394745 0.42 4.45 403261 0.43 3.98

5 Prem Mohanlal 268146 0.29 5.98 338972 0.36 7.39 Parikh 6 Hemant 233072 0.25 3.38 748019 0.8 7.67 Madhusudan Sheth 7 Mala Hemant 0 0 0 12560 0.01 24.19 Sheth 8 Ankit 303168 0.33 5.89 202345 0.22 4.23 Sanchaniya Grand Total 1379612 1.48 25.48 1959257 2.09

Table 5, Synchronized Trades of the entities on NSE in the scrip during investigation period SIL-2 Sl. Client Name synchroni % of % of synchronise % of % of No. sed buy Market sync to d sale trades Market sync to trades Volume total Volume total buy by sale by client client 1. Bharat Shantilal 25750 0.03 3.01 71120 0.09 8.59 Thakkar 2. Bipin Jayant Thaker 276949 0.34 5.82 322577 0.4 6 3. Kishore Chauhan 37149 0.05 1.63 143119 0.18 3.78 4. Bhavesh Pabari 126200 0.16 4.03 301140 0.37 7.69 5. Prem Mohanlal Parikh 252719 0.31 7.33 249652 0.31 6.88 6. Hemant Madhusudan 320262 0.4 5.69 544491 0.67 9.47 Sheth 7. Mala Hemant Sheth 12500 0.02 98.43 25000 0.03 93.46 8. Ankit Sanchaniya 250945 0.31 4.76 361351 0.45 5.23 Grand Total 1302474 1.62 130.7 2018450 2.5 (vi) Certain entities among the PP group entities i.e., Bhavesh Prakash Pabari, Prem Mohanlal Parikh, Hemant Madhusudan Sheth, etc. also indulged in self trades (i.e. same buy client as well as the sale client for a given trade resulting in no change of beneficial ownership). The detail of the same is presented as under: Table 6, Self Trades of the entities on BSE in the scrip during the investigation period SIL-1

Self % of % % of No of Sl. Total Total Client Name trade Total Total Market Self No. Buy Sale qty Buy Sale Volume trades Bharat Shantilal 1. 10470357 9502811 235374 2.25 2.48 0.14 115 Thakkar 2. Bipin Jayant Thaker 6631816 3822962 226362 3.41 5.92 0.13 57 3. Kishore Chauhan 9721840 8058635 197023 2.03 2.44 0.12 102 4. Bipinkumar Gandhi 1393286 962338 9121 0.65 0.95 0.01 37 5. Bhavesh Pabari 14085463 20707340 1620384 11.5 7.83 0.96 430 Prem Mohanlal 6. 12723256 7670445 531618 4.18 6.93 0.32 152 Parikh Hemant Madhusudan 7. 29962411 22356173 3274627 10.93 14.65 1.94 761 Sheth 8. Vipul Hiralal Shah 439119 236600 24800 5.65 10.48 0.01 1 9. Ankit Sanchaniya 15478199 9984834 471282 3.04 4.72 0.28 470 Grand Total 100905747 83302138 6590591 43.64 56.4 3.91 2125

Table 7, Self Trades of the entities on NSE in the scrip during investigation period SIL-1 Sl. Client Name Total Total Self % of % Total % of No of No. Buy Sale trade Total Sale Market Self qty Buy Volume trades 1. Bharat Shantilal 805119 668938 4855 0.6 0.73 0.02 8 Thakkar 2. Bipin Jayant 1877187 1977257 55039 2.93 2.78 0.24 24 Thaker 3. Prem Mohanlal 951427 451500 15000 1.58 3.32 0.07 2 Parikh 4. Hemant 2511673 2753743 5834 0.23 0.21 0.03 3 Madhusudan Sheth 5. Ankit Sanchaniya 2042411 2250538 132616 6.49 5.89 0.59 33 Grand Total 8187817 8101976 213344 11.83 12.93 0.95 70

Table 8, Self Trades of the entities on BSE in the during investigation period SIL-2 Sl. Name of the Total Total Self % of % % of No of No. entity buy sale trade Total Total Market Self qty Buy Sale Volume trades 1. Bharat Shantilal 1395519 1518102 2263 0.16 0.15 0 6 Thakkar 2. Bipin Jayant 4817677 5740151 102739 2.13 1.79 0.11 26 Thaker 3. Kishore 2208192 2540507 1100 0.05 0.04 0 2 Chauhan 4. Bhavesh Pabari 8861360 10144037 190735 2.15 1.88 0.2 77 5. Prem Mohanlal 4480527 4587734 87193 1.95 1.9 0.09 31 Parikh 6. Hemant 6890281 9754318 393404 5.71 4.03 0.42 78 Madhusudan Sheth 7. Ankit Sanchaniya 5145520 4787916 222268 4.32 4.64 0.24 61 Grand Total 33799076 39072765 999702 16.47 14.43 1.06 281

Table 9, Self Trades of the entities on NSE in the scrip during investigation period SIL-2 Sl. Name of the Total Total Self % of % % of No of No. entity buy sale trade Total Total Market Self qty Buy Sale Volume trades 1. Bharat Shantilal 856100 828413 2100 0.25 0.25 0 4 Thakkar 2. Bipin Jayant Thaker 4757443 5374442 125664 2.64 2.34 0.16 78 3. Kishore Chauhan 2278639 3790421 76387 3.35 2.02 0.09 23 4. Bhavesh Pabari 3134691 3913748 31777 1.01 0.81 0.04 22 5. Prem Mohanlal 3446372 3631238 141135 4.1 3.89 0.17 78 Parikh 6. Hemant 5633024 5748297 16934 0.3 0.29 0.02 11 Madhusudan Sheth 7. Ankit Sanchaniya 5266567 6903099 307909 5.85 4.46 0.38 310 Grand Total 25372836 30189658 701906 17.5 14.06 0.86 526 (vii) Analysis of the price volume data revealed that on BSE during the investigation period SIL-1 the scrip was traded on 228 trading days. Out of 228 trading days, the PP group entities traded among themselves on 223 days, i.e. 98% of the total no of days the scrip was traded during the period under investigation. The PP group entities contribution to daily market volume ranged from 4.94% on May 29, 2009 to 81.15% on April 30, 2010. Out of 223 trading days the PP group entities traded among themselves, on 130 trading days PP group entities contributed more than 50% of the total market volume. Further, the analysis of price volume data revealed that the scrip was traded on 36 trading days on NSE. Out of 36 trading days, the PP group entities traded among themselves on all the days the scrip was traded during the period under investigation. It was observed that the PP group entities contribution to daily market volume ranged from 91.87% on March 09, 2010 to 84.33% on April 30, 2010. Out of 36 trading days, the PP group entities traded among themselves and on 27 trading days, PP group entities contributed more than 50% of the total market volume.

(viii) Analysis of the price volume data made known that during the investigation period SIL-2 the scrip was traded 192 trading days on BSE. Out of 192 trading days the group entities traded among themselves on 167 days, i.e. 86.97% of the total no of days the scrip was traded during the period under investigation. The PP group entities contribution to daily market volume ranged from 83.74% on May 03, 2010 to 0.22% on January 31, 2011. Out of 167 trading days the PP group entities traded among themselves, on 140 trading days PP group entities contributed more than 50% of the total market volume. Out of 167 PP group trading days, on 158 trading days both buy and sell orders were placed within time difference of one minutes. The PP group entities contribution to daily market volume ranged from 7.42% on May 04, 2010 to 7.44% on January 25, 2011. Out of 158 trading days, on 32 trading days PP group entities contributed more than 50% of the total market volume by placing both buy and sale order within one minute time difference. Further, the analysis of price volume data revealed that the scrip was traded 192 trading days on NSE. Out of 192 trading days the group entities traded among themselves on 159 days, i.e. 83% of the total no of days the scrip was traded during the period under investigation. It was observed that the PP group entities contribution to daily market volume ranged from 79.12% on May 03, 2010 to 1.06% on January 17, 2011. Out of 159 trading days the PP group entities traded among themselves, on 127 trading days PP group entities contributed more than 50% of the total market volume.

(ix) Out of 170615 trades during investigation period SIL-1, the 28 PP group entities dealing through multiple brokers entered into 68455 buy transactions. Further, it was observed that out of 68455 trades 11981 trades taken place at a price less than LTP (contributing a gross fall in price by Rs. -1682.50), 44980 trades taken place at a price equal to LTP and 11494 trades at a price greater than LTP (contributing a gross increasing in price by Rs. 2,331). The detail of individual contribution to change in the price of the scrip by entering into buy transaction is placed as under:

Table 10, LTP contribution on BSE in the scrip during investigation period SIL-1 Sl. Name of the entiy No of no of Gross No of Gross No of Net No. trades trades increase trades fall in trades impact above in price less price at LTP than LTP LTP 1 Gemstone Investments Ltd 137 3 1.15 12 -2.95 122 -1.80 2 Bhupesh Rathod 10 1 0.25 3 -0.50 6 -0.25 3 Ketan Babulal Shah 56 7 0.50 11 -1.05 38 -0.55 4 Rajnandi Yarns Private Limited 7 3 1.30 2 -0.10 2 1.20 5 Bharat Shantilal Thakkar 11332 2340 508.25 2407 -353.75 6585 154.50 6 Bipin Jayant Thaker 3360 574 167.85 488 -90.80 2298 77.05 7 Vasudev Ramchandra Kamat 11 1 0.65 3 -0.30 7 0.35 8 Bharat G Vaghela 6679 1664 254.65 1181 -135.85 3834 118.80 9 Sagar Janak Vyas 20 0 0.00 2 -0.10 18 -0.10 10 Narendra Prabodh Ganatra 23 5 0.45 2 -0.35 16 0.10 11 Chirag Rajnikant Jariwala 1588 135 17.90 273 -28.10 1180 -10.20 12 Kishore Chauhan 9334 2072 406.60 1948 -261.75 5314 144.85 13 Manish Suresh Joshi 1 0 0.00 0 0.00 1 0.00 14 Kaushik Gangaram Rathod 17 0 0.00 3 -0.45 14 -0.45 15 Santosh Vishram Ghadshi 3 0 0.00 1 -1.00 2 -1.00 16 Bipinkumar Gandhi 2063 537 125.50 639 -93.75 887 31.75 17 Bhavesh Pabari 5567 827 198.10 917 -146.90 3823 51.20 18 Kaushik Karsanbhai Patel 0 0 0.00 0 0.00 0 0.00 19 Prem Mohanlal Parikh 3457 241 32.25 332 -45.85 2884 -13.60 20 Santosh Maruti Patil 969 131 17.35 392 -52.15 446 -34.80 21 Kaushik Rajnikant Mehta 5 0 0.00 2 -0.10 3 -0.10 22 Hemant Madhusudan Sheth 9389 946 220.90 1242 -178.05 7201 42.85 23 Jigar Praful Ghoghari 188 5 0.65 21 -3.65 162 -3.00 24 Vipul Hiralal Shah 99 0 0.00 13 -4.05 86 -4.05 25 Mala Hemant Sheth 334 59 11.20 34 -5.50 241 5.70 26 Gaurang Ajit Seth 47 15 3.40 8 -2.65 24 0.75 27 Ankit Sanchaniya 10275 1738 340.70 1673 -221.65 6864 119.05 28 Vivek Kishanpal Samant 3484 190 21.40 372 -51.15 2922 -29.75

Grand Total 68455 11494 2331.00 11981 - 44980 648.50 1682.50 (x) Further on NSE, it was observed that out of 69,630 trades in the scrip during investigation period SIL-1, the 14 PP group entities dealing through multiple brokers entered into 17534 buy transactions. Out of 17534 trades, 2019 trades taken place at a price less than LTP (contributing a gross fall in price by Rs. -372.15), 13209 trades taken place at a price equal to LTP and 2305 trades at a price greater than LTP (contributing a gross increasing in price by Rs. 534.60).

(xi) Out of 103443 trades during the investigation period SIL-2, 16239 trades had taken place at a price less than LTP (Summation TP-LTP= Rs. - 2738.55), 72032 trades taken place at a price equal to LTP and 15171 trades at a price greater than LTP (Summation TP-LTP= Rs. 2640.40). Further, it was observed that out of 103443 trades, the 19 PP group entities dealing through multiple brokers entered into 36613 buy transactions. Further, it was observed that out of 36613 trades 5804 trades taken place at a price less than LTP (contributing a gross fall in price by Rs. -762.75), 26319 trades taken place at a price equal to LTP and 4490 trades at a price greater than LTP (contributing a gross increasing in price by Rs. 950.70). Further on NSE, out of 130787 trades, the 18 PP group entities dealing through multiple brokers entered into 41149 buy transactions. Further, it was observed that out of 41149 trades, 8504 trades taken place at a price less than LTP (contributing a gross fall in price by Rs. - 6681.20), 24690 trades taken place at a price equal to LTP and 7955 trades at a price greater than LTP (contributing a gross increasing in price by Rs. 6229.65).

(xii) The examination of the material collected, it was revealed that the PP group entities had indulged in off-market transfer of 5,53,54,390 shares of SIL amongst themselves during the period January 01, 2009 and January 31, 2011. 4. The afore discussed actions on part of the above mentioned 11 entities i.e. execution of synchronized and self trades, creation of artificial volume and price manipulation distorted the market equilibrium and were observed to be fraudulent in nature. Consequently, a Show Cause Notice (hereinafter referred to as "the SCN") dated October 29, 2014 was issued to the above mentioned 11 entities i.e., Mr. Bharat Thakkar, Mr. Bipin J Thaker, Mr. Kishore Chauhan, Mr. Bhavesh Pabari, Mr. Prem Mohanlal Parikh, Mr. Hemant Madhusudan Sheth, Mr. Mala Hemant Sheth, Mr. Ankit Sanchaniya, Mr. Bipinkumar Gandhi, Mr. Narendra Prabodh Ganatra and Bhupesh Rathod (hereinafter collectively referred to as "the Noticees") for the violation alleged for their dealings during investigation period SIL-1 and another SCN dated December 23, 2014 was issued to 9 i.e., Mr. Bharat Thakkar, Mr. Bipin J Thaker, Mr. Kishore Chauhan, Mr. Bhavesh Pabari, Mr. Prem Mohanlal Parikh, Mr. Hemant Madhusudan Sheth, Mr. Mala Hemant Sheth, Mr. Ankit Sanchaniya and Mr. Bipinkumar Gandhi for their dealings during investigation period SIL-2, calling upon them to show cause as to why suitable directions under section 11B read with section 11(4) of the SEBI Act should not be issued against them for the alleged violation of the provisions of regulations 3 (a), (b), (c), (d), 4(1), 4(2) (a),(b) (e) and (g) of the SEBI (Prohibition of Fraudulent and Unfair Trade Practices Relating to Securities Market) Regulations, 2003 ("PFUTP Regulations").

The provisions of the Regulations alleged to have been contravened by the Noticees are reproduced hereunder: Regulation 3. 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.

Regulation 4. Prohibition of manipulative, fraudulent and unfair trade practices 4. (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;”

5. Vide separate letters the noticees submitted their reply to the SCN, details of which has been summarized as below:

(i) Bharat Shantilal Thakkar: A reply dated March 20, 2015 was submitted him which enclosed a copy of the appeal filed by him against the Adjudication Order passed in the same matter imposing a penalty of Rs. 5,00,000/- on him. He has inter alia submitted the following: (a) He has been issued six different SCN for trading in five scrips. (b) In the same matter an order was passed by the Adjudicating officer imposing a penalty of Rs. 5,00,000/- on him. He is aggrieved by the said order which he is unable to pay due to the restrain order passed by SEBI vide the Interim Order. (c) He has already suffered a prohibition period for more than four years and does not have any financial means and capacity to take service of legal consultation and represent his case in the present proceedings. (d) It is alleged in the SCN that Bavesh Pabari and he shared common address. But on a perusal of the KYC is may be noticed that his address is on the 3rd floor flat no. 32 and that of Bhavesh Pabari is 1st floor flat no. 6. (e) He placed orders on the system of the stock exchange in the normal course of trading and did not execute synchronized trades. His trades were delivery based. (f) He prayed that the prohibitory order be revoked in view of my present condition which is pathetic and deplorable.

(ii) Bipin Jayant Thaker: A reply dated March 22, 2015 was submitted by him which enclosed a copy of the appeal filed by him against the Adjudication Order passed in the same matter imposing a penalty of Rs. 5,00,000/- on him. He has inter alia submitted the following: (a) In the same matter an order was passed by the Adjudicating officer imposing a penalty of Rs. 5,00,000/- on him. He is aggrieved by the said order which he is unable to pay due to the restrain order passed by SEBI vide the Interim Order. (b) He has already suffered a prohibition period for more than four years and does not have any financial means and capacity to take service of legal consultation and represent his case in the present proceedings. (c) In the SCN it has been stated that Chirag Jariwala introduced the noticee to Arcadia Shares and Stock Brokers Ltd. However, from the KYC it is seen that he is not the introducer but the witness to the said form.

(d) It is humbly prayed that the prohibitory order be revoked in view of my present condition which is pathetic and deplorable.

(iii) Kishore Chauhan: During the adjudication proceedings in the same matter, vide letter dated November 8, 2013 Ms Rupal K. Chauhan, wife of Kishore Chauhan informed that Shri Kishore Chauhan passed away on May 29, 2013. (iv) Bhavesh Pabari: A reply dated March 22, 2015 was submitted by the noticee which enclosed a copy of the appeal filed by him against the Adjudication Order passed in the same matter imposing a penalty of Rs. 5,00,000/- on him. He has inter alia submitted the following: (a) The Noticee has been issued six different show cause notices for trading in five scrips. (b) In the same matter an order was passed by the Adjudicating officer imposing a penalty of Rs. 5,00,000/- on the Noticee. The Noticee is aggrieved by the said order which he is unable to pay due to the restrain order passed by SEBI vide the Interim Order. (c) He has already suffered a prohibition period for more than four years and does not have any financial means and capacity to take service of legal consultation and represent his case in the present proceedings. (d) Copies of trade logs and Order logs were provided in CD format and there was difficulty to purify the data which was in whole. The action proposed report was not enclosed with the documents provided. (e) There is no denial that the Noticee was a director in Rajnandi Yarns Private Limited but the decision of investment of Rajnandi Yarns Private Limited was taken in company board meeting and not at an individual level. (f) Noticee does not have any business relationship with certain other noticees involved. (g) The documents furnished have failed to provide any documentary evidence to prove the relationship. (h) A penalty of Rs. 5,00,000/- was imposed on the Noticee by the Adjudicating Officer which has been appealed against in SAT and the Noticee is aggrieved by the Interim Order and the Confirmatory order passed against him making him unable to have any financial means and capacity to take service of legal consultation and represent his case in the present proceedings. (i) It is alleged in the SCN that the noticee and the Bharat Thakkar shared common address. But on a perusal of the KYC is may be noticed that the address of Bharat Thakkar is on the 3rd floor flat no. 32 and that of the noticee is 1st floor flat no. 6.

(v) Prem Mohanlal Parikh: A reply dated March 22, 2015 was submitted by the noticee which enclosed a copy of the appeal filed by him against the Adjudication Order passed in the same matter imposing a penalty of Rs. 5,00,000/- on him. He has inter alia submitted the following: (a) In the same matter an order was passed by the Adjudicating officer imposing a penalty of Rs. 5,00,000/- on the Noticee. The Noticee is aggrieved by the said order which he is unable to pay due to the restrain order passed by SEBI vide the Interim Order. (b) He has already suffered a prohibition period for more than four years and does not have any financial means and capacity to take service of legal consultation and represent his case in the present proceedings. (c) The noticee placed orders on the system of the stock exchange in the normal course of trading and did not execute synchronized trades. His trades were delivery based. (d) The noticee’s contribution to the total trades undertaken in the scrip during the investigation period was miniscule (e) The noticee did not carry put any off market trades in the scrip and he did not have any fund movement with any other noticees.

(f) He is not Bhavesh Pabari’s cousin (vi) Hemant Madhusudan Seth: A reply dated March 22, 2015 was submitted by noticee which enclosed a copy of the appeal filed by him against the Adjudication Order passed in the same matter imposing a penalty of Rs. 5,00,000/- on him. He has inter alia submitted the following: (a) In the same matter an order was passed by the Adjudicating officer imposing a penalty of Rs. 5,00,000/- on the Noticee. The Noticee is aggrieved by the said order which he is unable to pay due to the restrain order passed by SEBI vide the Interim Order. (b) He has already suffered a prohibition period for more than four years and does not have any financial means and capacity to take service of legal consultation and represent his case in the present proceedings. (c) Hard copies of trade logs and Order logs were provided in CD format and there was difficulty to purify the data which was in whole. The action proposed report was not enclosed with the documents provided. (d) It is humbly prayed that the prohibitory order be revoked in view of my present condition which is pathetic and deplorable.

(vii) Mala Hemant Seth: A reply dated March 22, 2015 was submitted by noticee which enclosed a copy of the appeal filed by her against the Adjudication Order passed in the same matter imposing a penalty of Rs. 5,00,000/- on her. He has inter alia submitted the following: (a) In the same matter an order was passed by the Adjudicating officer imposing a penalty of Rs. 5,00,000/- on the Noticee. The Noticee is aggrieved by the said order which she is unable to pay due to the restrain order passed by SEBI vide the Interim Order. She has already suffered a prohibition period for more than four years and does not have any financial means and capacity to take service of legal consultation and represent his case in the present proceedings. (b) Hard copies of trade logs and Order logs were provided in CD format and there was difficulty to purify the data which was in whole. The action proposed report was not enclosed with the documents provided. (c) The Noticee has accepted fund movement with some other noticees. The noticee has further stated that while it is true that she is the wife of Hemant Seth, she denies having any business/ professional connection with him and submits that she is living an independent life and is taking her own independent decisions.

(d) It is humbly prayed that the prohibitory order be revoked in view of my present condition which is pathetic and deplorable. (viii) Ankit Sanchaniya: A reply dated March 22, 2015 was submitted by the noticee which enclosed a copy of the appeal filed by him against the Adjudication Order passed in the same matter imposing a penalty of Rs. 5,00,000/- on him. He has inter alia submitted the following: (a) In the same matter an order was passed by the Adjudicating officer imposing a penalty ofRs. 5,00,000/- on the noticee. The noticee is aggrieved by the said order which he is unable to pay due to the restrain order passed by SEBI vide the Interim Order. He has already suffered a prohibition period for more than four years and does not have any financial means and capacity to take service of legal consultation and represent his case in the present proceedings. (b) Hard copies of trade logs and Order logs were provided in CD format and there was difficulty to purify the data which was in whole. The action proposed report was not enclosed with the documents provided. (c) The noticee placed orders on the system of the stock exchange in the normal course of trading and did not execute synchronized trades.

His trades were delivery based. (d) The noticee’s contribution to the total trades undertaken in the scrip during the investigation period was miniscule (e) It is humbly prayed that the prohibitory order be revoked in view of my present condition which is pathetic and deplorable. (ix) Bhupesh Rathod: A reply dated March 20, 2015 was submitted by noticee which enclosed a copy of the appeal filed by him against the Adjudication Order passed in the same matter imposing a penalty of Rs. 5,00,000/- on him. He has inter alia submitted the following:

(a) In the same matter an order was passed by the Adjudicating officer imposing a penalty of Rs. 5,00,000/- on the noticee. The noticee is aggrieved by the said order which he is unable to pay due to the restrain order passed by SEBI vide the Interim Order. (b) He has already suffered a prohibition period for more than four years and does not have any financial means and capacity to take service of legal consultation and represent his case in the present proceedings. (c) Hard copies of trade logs and Order logs were provided in CD format and there was difficulty to purify the data which was in whole. The action proposed report was not enclosed with the documents provided. (d) The noticee has no business relationship with other noticees and documents furnished have failed to provide any documentary evidence to prove the relationship. (e) Although he introduced Hemant Seth, Prem Parikh, BhaveshPabari and Kishore Chauhan for their trading ccounts, the said introduction was sought by the broker S.P. Jain Securities Pvt. Ltd. which was a mere formality. (f) His fund movement with Ankit Sanchaniya was related to his cloth business.

(g) The noticee placed orders on the system of the stock exchange in the normal course of trading and did not execute synchronized trades. His trades were delivery based. (h) The noticees' contribution to the total trades undertaken in the scrip during the investigation period was miniscule 6. The hearing was scheduled on April 07, 2015 in the matter pertaining to the investigation period SIL-1 when Mr. Vikas Bengani, authorized representative of Mr. Narendra P Ganatra, appeared and submitted that- (i) The trades carried out by Mr. Narendra were miniscule in nature. The entity had bought only 13,538 shares which constituted only 0.01% of the market volume. (ii) The trade of the entity with the alleged Pabari-Parikh group was for 307 shares only. (iii) The entity had not entered into any self trades, synchronized trades reversal, circular trades or any Off market trades with the alleged group. 7. Further, hearing was scheduled on July 29, 2015 in the matter pertaining to the investigation period SIL-2 when Mr. Bhavesh Pabari appeared and made following submissions a. He is debarred from the market since 02/02.2011 (more than 4 and a half years) and he is in severe financial crisis. b. He has been deprived of his fundamental rights to carry on business in which he is proficient. c. There is neither investor complaint against him in the matter nor any loss has been caused to any investor.

d. The trades carried out were insignificant in nature and were not intended for manipulation 8. I have considered the SCNs and submissions made by the noticees and other material available on record. I note that separate SCNs were issued for two different investigation periods i.e. investigation period SIL-1 and investigation period SIL-2. Considering that these proceedings have commenced based on dealing in the same scrip by almost same entities during a continuous period i.e., May 29, 2009 to April 30, 2010 as "Investigation period SIL-1" and from May 01, 2010 to January 31, 2011 as "Investigation period SIL-2"), I am of the view that it is a fit case to pass a common order for both the proceedings.

9. At the outset, I find that the principles of natural justice have been followed in so far that all the noticees were given an opportunity to file written submission and attend hearing to present their case in the present proceedings. It is to be noted that the adjudication proceedings and the present proceedings are different and therefore separate replies have to be filed for same. The noticees have mentioned in their submissions that they are not in a position to attend personal hearing and present their case before me. I, therefore, proceed to deal with the replies/submission of the noticees before me. 10. The noticees have submitted that they have not been provided the complete investigation report, complete set of trade logs and order logs order and the action proposed chart along with the SCN. Further, some of the noticees have submitted that the relevant trade logs and order logs were provided to them in a CD format due to which they were unable to purify the data pertaining to them. In this regard, I note from the material available on record that all relevant documents that were relied upon in the SCN have been duly provided to the noticees.

The relevant extracts of the investigation report and the trade logs and order logs related to the transactions carried out by the noticees were also provided to them. Further, due to the voluminous nature of the trade logs and order logs pertaining to the respective Noticees, the same were provided in a CD. 11. I will now proceed to deliberate on the submissions made by the noticees. I note that Mr. Bhavesh Pabari has denied his relationship/connection with Mr. Narendra Ganatra and in this regard has relied upon the Hon’ble SAT order dated July 29, 2011 in the matter of Narendra Ganatra v. SEBI. I note that vide his letter to SEBI dated July 13, 2012, Mr. Bhavesh Pabari has admitted that Mr. Narendra Ganatra is his friend. A copy of the said letter was also furnished to Mr. Bhavesh Pabari during the instant proceedings. However, the said letter or its contents have not been disputed by Mr. Bhavesh Pabari. I, therefore, reject the contention of Mr. Bhavesh Pabari regarding his relationship with Mr. Narendra Ganatra. Further, it is noted from the KYC of Mr. Bhavesh Pabari that he and Mr. Ankit Sanchaniya are cousins.

Mr. Hemant Madhusudan Seth and Mr. Prem Mohanlal Parikh have fund movements as well as off market securities movement. 12. Ms. Mala Hemant Seth has admitted to fund transactions with Mr. Prem Mohanlal Parikh. Ms. Mala Hemant Seth has further contended that while it is true that she is the wife of Mr. Hemant Madhusudan Seth, she denies having any business/professional connection with him and submits that she is living an independent life and is taking her own independent decisions. I note that Ms. Mala Hemant Seth also has fund market movements and off market transactions with Mr. Bhavesh Pabari and Mr. Prem Mohanlal Parikh. Vide her letter dated July 8, 2012, Ms. Mala Hemant Seth has admitted that the transactions in the securities market in her name were handled by her husband Mr. Hemant Madhusudan Seth. 13. With respect to the submissions made by Mr. Bipin Jayant Thaker, I note that vide letter dated July 11, 2012 submitted by the Mr. Bipin Jayant Thaker to SEBI, he has accepted that Mr. Bhavesh Pabari was his nephew. Further, Mr. Bhavesh Pabari has submitted that he and Mr. Bharat Shantilal Thakkar do not share a common address since their flat numbers are different.

In this regard, I note that as per their own admission, they live in the same building but on different floors (i.e. 1 st and 3rd). Also it is not disputed that Mr. Bhavesh Pabari is the nephew of Mr. Bharat Shantilal Thakkar. Thus, even if the technical argument is accepted that they were residing on different floors of the same building, the connection between them shown in the SCN cannot be disputed. 14. I note that the details of the relationship amongst the noticees, their trade logs and their off market transactions have been sufficiently proved and were also furnished to the noticees along with the SCN. Such relations and transactions have not been disputed. Considering the factors as described in the SCN, I note that the noticees are sufficiently related /connected to each other on the basis of relationship, common addresses, e-mails, telephone numbers, fund transfer, etc. In view of these facts and circumstances, the noticees are connected to each other. 15. I note that the noticees have not disputed the trade which has been alleged in the SCNs. Placing of the sell orders with same counterparties for same quantity of shares at the same price within nil or too negligible time difference repeatedly over a period of time are clear indication that those trades of the noticees were synchronized/structured.

In this case, I note that several synchronized transactions amongst these noticees were in the nature of self–trade wherein one or the other noticee was on either side of the transaction. These self-trades clearly did not involve change in beneficial ownership of traded shares and were, therefore, illegal. It is relevant to mention that with regard to the nature and effect of self-trades the Hon’ble SAT, in the matter of M/s. Jayantilal Khandwala & Sons Pvt. Ltd. vs. SEBI (Appeal no. 24 of 2011 decided on June 8, 2011), has held that : “one cannot buy and sell shares from himself. Such transactions are obviously fictitious and meant only to create false volumes on the trading screen of the exchange.” 16. I also note that several synchronized transactions amongst these noticees were in the nature of self–trade wherein one or the other noticee was on either side of the transaction. These self-trades clearly did not involve change in beneficial ownership of traded shares and were, therefore, illegal. 17. The noticees have raised another common contention that the transactions carried out by them were genuine and bona fide and the quantities of their transactions were so minuscule that they could not have led to creation of artificial volume and price manipulation in the scrip of LGS.

In this regard, I note that the SCN clearly brings out that there have been number of transactions among the noticees which were synchronized with the orders with identical rates placed within a span of less than one minute. 18. In light of the above, I note that the noticees are in fact related to each and have connived amongst themselves for execution of synchronized and self trades, creation of artificial volume and price manipulation which not only distorted market equilibrium but was also found to be fraudulent in nature, and have therefore violated the provisions of regulations 3 (a), (b), (c), (d), 4(1), 4(2) (a), (b), (e) and (g) of the SEBI (Prohibition of Fraudulent and Unfair Trade Practices Relating to Securities Market) Regulations, 2003. 1. The noticees have submitted that based on the same set of facts and transactions as in the instant case monetary penalties were imposed against the Noticees by the adjudicating officer vide his separate order(s) and the noticees have challenged the said order(s) before SAT. For such examination it is relevant to refer to the scheme of enforcement actions that SEBI may initiate in such cases under the SEBI Act.

It is a settled position that SEBI Act empowers SEBI to take both streams of actions i.e. civil and criminal, if any person contravenes the provisions of the SEBI Act or the rules or regulations made thereunder. The civil enforcement actions include directions under section 11 and 11B of the SEBI Act and imposition of monetary penalty in adjudication proceedings under Chapter VIA of the said Act. The criminal action is by way of prosecution under section 24 of the SEBI Act. Depending on the facts and circumstances of the case, the nature, gravity and seriousness of violations involved, impact thereof on the investors or the securities market and the illegal gains made or loss avoided, etc., SEBI may initiate one or all of those three actions. It cannot be said that by initiating adjudication proceedings the Board abdicates its power to initiate other actions if the facts of the case warrant multiple enforcement actions. In the instant case, I am satisfied that the contraventions as found in this case are grave and have the potential to disturb the market integrity and disturb the fair, equitable and efficient functioning of the securities market.

In the instant case, the proceedings under sections 11 and 11B of the SEBI Act have been initiated against the Noticees in addition to the adjudication proceedings against them as the charges against the entities are grave and have larger implications on the safety and integrity of the securities market. In my view, for the serious contraventions as found in the instant case, monetary penalty alone would not be sufficient to safeguard the market integrity. In this regard, the following observations of the Hon’ble SAT in the order dated December 02, 2010, in Appeal no. 70 of 2010 – Yashraj Containeurs Ltd. v. SEBI are worth mentioning: “.... we cannot resist observing that in view of the serious allegations made against the appellants which stand established during the course of the adjudication proceedings, the Securities and Exchange Board of India (for short the Board) should not have been content with initiating only adjudication proceedings against the appellants in which only a monetary penalty could be levied. This is a fit case where the Board should have considered initiating proceedings under Sections 11 and 11B of the Securities and Exchange Board of India Act, 1992 for issuing appropriate directions against the appellants to protect the integrity of the market and the interests of the investors....

This is, indeed a very serious market illegality/irregularity and, in our view, imposing a monetary penalty alone on the company and its promoters will not meet the ends of justice. We are constrained to make these observations because the lenient view taken by the Board does not, in our opinion, protect the integrity of the market and not even the interest of the investors which is its primary duty. This kind of a lenient view will not be a deterrent for others and would send a wrong signal that the delinquent could continue with their nefarious activities by paying a monetary penalty.” 19. I note that vide the interim order dated February 02, 2011, SEBI had restrained, inter alia, the noticees herein from accessing the securities market and further prohibited them from buying, selling or dealing in securities in any manner whatsoever, till further directions. The directions in the interim order qua these noticees are still in force. I also note from the material on record that Mr. Kishore Chauhan has passed away on May 29, 2013 and, therefore, the proceedings against him is abated and the SCN dated October 29, 2014 for his dealing during investigation period SIL-1 and SCN dated December 13, 2014 for his dealing during investigation period SIL-2 are disposed of accordingly.

20. It is important to mention that some of the noticees in the present proceedings, against whom the allegations levelled in the SCNs have been established, have already been restrained by SEBI vide order dated May 13, 2015 in the matter of dealings in the shares of Goldstone Technologies Limited and /or LGS Global Limited and/or Gemstone Investments Ltd. from accessing the securities market and have been further prohibited from buying, selling or otherwise dealing in securities, directly or indirectly, or being associated with the securities market in any manner. It is noteworthy that the said restraint has been imposed on the noticees for indulging in fraudulent and manipulative acts in violation of the PFUTP Regulations as has been found in the present case. In my view, repeated fraudulent acts and delinquent behaviour of the erring noticees does not bode well for the integrity, orderly development and smooth functioning of the securities market. It, therefore, becomes incumbent to deal with contraventions, digression and demeanour of the erring noticees sternly and take appropriate actions for effective deterrence. 21. Considering the above, I, in order to protect the interest of investors and the integrity of the securities market, in exercise of the powers conferred upon me under section 19 of the Securities and Exchange Board of India Act, 1992 read with sections 11 and 11B thereof and regulation 11 of the Securities and Exchange Board of India (Prohibition of Fraudulent and Unfair Trade Practices Relating to Securities Market) Regulations, 2003 hereby restrain the following entities from accessing the securities market and further prohibit them from buying, selling or otherwise dealing in securities, directly or indirectly, or being associated with the securities market in any manner, whatsoever, for the period as mentioned in the table below:

Sl. No. Name of Entity PAN Period 1. Mr. Bharat Thakkar AAZPT9542R 7 Years 2. Mr. Bipin J Thaker ABYPT4984H 7 Years 3. Mr. Bhavesh Pabari AKGPP8679N 7 Years 4. Mr. Prem Mohanlal Parikh ALHPP3489N 7 Years 5. Mr. Hemant Madhusudan Sheth ANOPS8607E 7 Years 6. Ms. Mala Hemant Sheth AZXPS0694J 7 Years 7. Mr. Ankit Sanchaniya BLNPS3316L 7 Years 8. Mr. Narendra Prabodh Ganatra AEMPG4315C 5 Years 9. Mr. Bhupesh Rathod AACPR3785K 7 years 10. Mr. Bipinkumar Gandhi AJHPG6989J 7 years

22. The period of prohibition already undergone by the noticees, who were debarred/restrained by the interim order dated February 02, 2011, shall be taken into account for the purpose of computing the period of prohibition imposed vide this order. Further, it is clarified that the restraint/prohibition imposed on the noticees, to whomsoever applicable, shall run concurrently with the restraint/prohibition imposed by SEBI vide order dated May 13, 2015 in the matter of dealings in the shares of Goldstone Technologies Limited, June 29, 2015 in the matter of dealings in the shares of LGS Global Limited and January 04, 2016 in the matter of Gemstone Investments Ltd. 23. A copy of this order shall be served on all recognized stock exchanges and depositories to ensure that the direction given in the above para are complied with. 24. This order shall come into force with immediate effect.

Sd/-

DATE: January, 4th 2016 RAJEEV KUMAR AGARWAL PLACE: MUMBAI WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA