Adjudication Order in respect of Ram Asava HUF in the matter of Illiquid Stock Options at BSE

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Adjudication Order in respect of Ram Asava HUF in the matter of Illiquid Stock Options at BSE Page 1 of 14

BEFORE THE ADJUDICATING OFFICER

SECURITIES AND EXCHANGE BOARD OF INDIA

[ADJUDICATION ORDER NO. Order/MS/SM/2026-27/32662]

UNDER SECTION 15-I OF SECURITIES AND EXCHANGE BOARD OF INDIA ACT,

1992 READ WITH RULE 5 OF SEBI (PROCEDURE FOR HOLDING INQUIRY AND

IMPOSING PENALTIES) RULES, 1995, IN RESPECT OF:

Ram Asava HUF

(PAN: AARHR3709J)

In the matter of Trading in Illiquid Stock Options at BSE

BACKGROUND OF THE CASE

1. Securities and Exchange Board of India (hereinafter referred to as “SEBI”)

observed large scale reversal of trades in stock options segment of Bombay Stock

Exchange (hereinafter referred to as “BSE”). SEBI observed that such large scale

reversal of trades in stock options lead to creation of artificial volume at BSE. In

view of the same, SEBI conducted an investigation into the trading activities of

certain entities in illiquid stock options at BSE for the period April 1, 2014 to

September 30, 2015 (hereinafter referred to as "IP").

2. Pursuant to investigation, it was observed that total of 2,91,744 trades comprising

81.40% of all the trades executed in stock options segment of BSE during the IP

were allegedly non genuine trades. The aforesaid alleged non-genuine trades

resulted into creation of artificial volume in stock options segment of BSE during

the IP. It was observed that Ram Asava HUF (PAN – AARHR3709J) (hereinafter

referred to as the “Noticee”) was one of the various entities, which indulged in

execution of reversal trades in stock options segment of BSE during the IP. Such

trades were alleged to be non-genuine in nature and created false or misleading

appearance of trading in terms of artificial volumes in stock options and therefore

were alleged to be manipulative, deceptive in nature. In view of the same, SEBI

initiated adjudication proceedings against the Noticee for alleged violation of the

provisions of Regulations 3(a), (b), (c), (d), 4(1) and 4(2)(a) of SEBI (Prohibition of

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Fraudulent and Unfair Trade Practices Relating to Securities Market) Regulations,

2003 (hereinafter referred to as “PFUTP Regulations”).

APPOINTMENT OF ADJUDICATING OFFICER

3. The undersigned was appointed as Adjudicating Officer in the matter, conveyed

vide communique dated June 01, 2026, under section 19 read with Section 15-

I(1) of the SEBI Act, 1992 (hereinafter referred to as “SEBI Act, 1992”) and Rule

3 of SEBI (Procedure for Holding Inquiry and Imposing Penalties) Rules, 1995

(hereinafter referred to as “Adjudication Rules”) to conduct adjudication

proceedings in the manner specified under Rule 4 of Adjudication Rules read with

Section 15-I(1) and (2) of SEBI Act, 1992, and if satisfied that penalty is liable,

impose such penalty deemed fit in terms of Rule 5 of Adjudication Rules and

Section 15HA of SEBI Act, 1992.

SHOW CAUSE NOTICE, REPLY AND HEARING

4. A Show Cause Notice bearing reference no. EAD-8/AS/AK/41407/1/2022 dated

August 08, 2022 (hereinafter referred to as “SCN”) was issued to the Noticee by

the AO u/r 4(1) of the SEBI Adjudication Rules to show-cause as to why an inquiry

should not be initiated against it and why penalty, if any, should not be imposed

u/s 15HA of the SEBI Act for the violations alleged to have been committed by the

Noticee.

5. The SCN (Part B) inter-alia contained information regarding SEBI ISO Settlement

Scheme 2022.

6. It was inter alia alleged in the SCN that the Noticee had executed 4 non-genuine

trades in 2 Stock Options contract which resulted in artificial volume of total

1,50,000 units.

7. The SCN was sent through Speed Post Acknowledgment Due (SPAD) with

reference number EAD-8/AS/AK/41407/1/2022 dated August 08, 2022 at the

address of the Noticee viz., Ram Bhavan Opp Krishnapuri Sumer Nagar Ajmer

Road Madan Ganj Kishangarh 305801 Kishangarh Rajasthan India. It is noted that

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the SCN was delivered at the said address of the Noticee. It is also noted that

Noticee’s reply to the SCN has not been received till date.

8. A Hearing Notice bearing reference no. EAD-8/AS/AK/9185/3/2023 dated March

02, 2023 was issued to the Noticee. The said Hearing Notice was delivered through

Speed Post Acknowledgment Due (SPAD) at the address of the Noticee viz., Ram

Bhavan Opp Krishnapuri Sumer Nagar Ajmer Road Madan Ganj Kishangarh

305801 Kishangarh Rajasthan India.

9. Subsequently, a Post Show Cause Intimation (PSI) dated March 06, 2024 was

issued and served to the Noticee through SPAD at the aforesaid address of the

Noticee and email. The said PSI inter alia contained information regarding SEBI

ISO Settlement Scheme, 2024. However, the Noticee did not avail both the

Settlement Scheme of 2022 and 2024.

10. Upon transfer of instant proceedings to the undersigned and in the interest of

natural justice, an opportunity to file reply to the SCN and an opportunity of

personal hearing in the matter was granted to the Noticee vide Hearing Notice

dated June 15, 2026 and an email was also sent along with digitally signed Hearing

Notice on the same day informing the Noticee of the scheduled personal hearing

on June 25, 2026. The letter was undelivered through SPAD at the address of the

Noticee viz., Ram Bhavan Opp Krishnapuri Sumer Nagar Ajmer Road Madan Ganj

Kishangarh 305801 Kishangarh Rajasthan India. Further, digitally signed Hearing

Notice was also delivered to the Noticee through email on the email id

(pawan.mmpl@gmail.com) available on record. It was noted that Noticee had

failed to avail the said opportunity of hearing. In the interest of principles of natural

justice, Noticee was granted last opportunity of hearing vide email dated July 08,

2026. However, it was noted that Noticee had again failed to avail the said

opportunity of hearing. Vide Hearing Notice dated June 15, 2026, the Noticee was

inter alia also informed that if no reply to the SCN was received from the Noticee

and no appearance was made by the Noticee for hearing, the matter shall be

proceeded with on the basis of facts /material available on record in terms of Rule

4(7) of the SEBI Adjudication Rules.

11. In this regard, I note that despite having been provided with sufficient opportunities

to submit reply to the SCN and appear for hearing, as detailed in the foregoing,

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neither any reply to the SCN was received from the Noticee nor the Noticee

appeared for hearing. Accordingly, I am constrained to proceed to deal with the

matter ex-parte on the basis of material available on record in terms of Rule 4(7)

of the SEBI Adjudication Rules which reads as under: -

“

…

4(7) If any person fails, neglects or refuses to appear as required by sub-rule (3) before the Board or the

adjudicating officer, the Board or the adjudicating officer may proceed with the inquiry in the

absence of such person after recording the reasons for doing so.

…”.

12. Further, in this regard, reliance is placed on Hon’ble Securities Appellate Tribunal

(SAT) order dated December 08, 2006 in the matter of Classic Credit Ltd. vs. SEBI

wherein Hon’ble SAT had, inter alia, observed that, "......the appellants did not file

any reply to the second show-cause notice. This being so, it has to be presumed

that the charges alleged against them in the show cause notice were admitted by

them”. It is also pertinent to note that the Hon’ble SAT in the matter of Sanjay

Kumar Tayal (File Ref No.: EAD2/SS/VS/64/111/2019-20) & Others vs SEBI

(Appeal No. 68 of 2013 decided on February 11, 2014), had also, inter alia,

observed that: “........... appellants have neither filed reply to show cause notices

issued to them nor availed opportunity of personal hearing offered to them in the

adjudication proceedings and, therefore, appellants are presumed to have

admitted charges leveled against them in the show cause notices...” Further, the

same position is reiterated by the Hon’ble SAT in the matter of Dave Harihar

Kirtibhai Vs SEBI (Appeal No. 181 of 214 dated December 19, 2014), wherein the

Hon’ble SAT observed as under:“...further, it is being increasingly observed by the

Tribunal that many persons/entities do not appear before SEBI (Respondent) to

submit reply to SCN or, even worse, do not accept notices/letters of Respondent

and when orders are passed ex-parte by Respondent, appear before Tribunal in

appeal and claim non-receipt of notice and do not appear and/or submit reply to

SCN but claim violation of principles of natural justice due to not being provided

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opportunity to reply to SCN or not provided personal hearing. This leads to

unnecessary and avoidable loss of time and resources on part of all concerned

and should be eschewed, to say the least. Hence, this case is being decided on

basis of material before this Tribunal...”. Further, in the matter of Shri. B.Ramalinga

Raju vs. SEBI (Appeal no. 286 of 2014), Hon’ble SAT observed that “eventhough

the Noticees remained ex-parte, I find it relevant that I should be guided by

the documents available on record”.

13. In view thereof, I hereby proceed to deal with the matter on the basis of material

available on record and on the basis of presumption that the allegations /charges

have been admitted by Noticee.

CONSIDERATION OF ISSUES AND FINDINGS

14. The charges levelled against the Noticee and the documents / material available

on record have been carefully perused. The issues that arise for consideration in

the present case are:

4.1 Whether the Noticee has violated provisions of Regulations 3(a), (b), (c), (d),

4(1) and 4(2)(a) of PFUTP Regulations?

4.2 Does the violation, if any, attract monetary penalty u/s 15HA of the SEBI Act,

1992?

4.3 If so, what would be the quantum of monetary penalty that can be imposed on

the Noticee after taking into consideration the factors mentioned in section 15J

of the SEBI Act, 1992?

15. Before proceeding further, the relevant provisions of the PFUTP Regulations are

mentioned as below:

PFUTP Regulations, 2003

3. Prohibition of certain dealings in securities

No person shall directly or indirectly—

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(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;

Issue (a): Whether the Noticee has violated provisions of Regulations 3(a),

(b), (c), (d) and Regulation 4(1) & 4(2)(a) of PFUTP Regulations?

16. Before proceeding to the merits of the case, it is noted that pursuant to a

preliminary examination conducted in the Illiquid Stock Options matter, Interim

order was passed by SEBI on August 20, 2015 which was confirmed vide Orders

dated July 30, 2016 and August 22, 2016. Meanwhile, SEBI initiated a detailed

investigation relating to stock options segment of BSE which was completed in the

year 2018. The investigation revealed that 14,720 entities were involved in

executing non-genuine trades in BSE’s stock option segment during the

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investigation period. The proceedings initiated vide the aforementioned Interim

Order were disposed of vide Final Order dated April 05, 2018 also considering that

appropriate action was initiated against the said 14,720 entities in a phased

manner.

17. It is further noted that there are no timelines prescribed in the SEBI Act, for the

purpose of identifying trades as non-genuine. In this regard, it is pertinent to note

that, in the matter of SEBI Vs Bhavesh Pabari (2019) SCC Online SC 294, the

Hon’ble Supreme Court of India has, inter alia, held that:

“There are judgments which hold that when the period of limitation is not prescribed,

such power must be exercised within a reasonable time. What would be reasonable

time, would depend upon the facts and circumstances of the case, nature of the

default/statute, prejudice caused, whether the third-party rights had been created

etc.”

18. It is relevant at this juncture to deal with the transactions executed by the Noticee

in the alleged non-genuine trades.

19. It is noted that allegation against the Noticee is that, while dealing in the stock

option contract at BSE during the IP, it had executed reversal trades which were

allegedly non-genuine trades and the same had resulted in generation of artificial

volume in stock option contract at BSE. Reversal trades are considered to be

those trades in which an entity reverses it’s buy or sell positions in a contract with

subsequent sell or buy positions with the same counterparty during the same day.

The said reversal trades are alleged to be non-genuine trades as they are not

executed in the normal course of trading, lack basic trading rationale, lead to false

or misleading appearance of trading in terms of generation of artificial volumes

and hence, are deceptive and manipulative.

20. Further, it is noted from the trade log of the Noticee that it had allegedly executed

4 non-genuine trades in 2 contracts and the above mentioned trades of the

Noticee had resulted in the creation of artificial volume of 1,50,000 units in the said

contract. Summary of non-genuine trades of the Noticee is as follows:

Contract

Name

Avg.

Buy

Rate

(Rs)

Total Buy

Volume

(No. of

units)

Avg. Sell

Rate (Rs)

Total Sell

Volume

(No. of

units)

% of Non

Genuine

trades of

Noticee

in the

% of

Non-

Genuine

trades of

Noticee

% of

Artificial

Volume

generated

by

% of

Artificial

Volume

generated

by Noticee

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contract

to

Noticee's

Total

trades in

the

Contract

in the

contract

to Total

trades in

the

Contract

Noticee in

the

contract

to

Noticee's

Total

Volume in

the

Contract

in the

contract

to Total

Volume in

the

Contract

BPCL15MAR800.00CE

0.35 50000 5.35 50000 100 33.33 100 41.24

HDBK15APR1020.00CE 40 25000 50 25000 100 12.5 100 10.89

21. It is noted that the Noticee had allegedly executed non-genuine trades in said

contracts, wherein the alleged non-genuine trades of the Noticee in stock options

contracts were 100% of the total trades in the contract. Further, alleged artificial

volume generated by Noticee in the contract amounted to 100% volume of total

volume generated by it in the contracts. It is also noted that alleged artificial volume

generated by the Noticee was 100% of the total volume from the market in the

said contract. The details of squaring up done by the Noticee in the contract

‘BPCL15MAR800.00CE’ is as given below:

Trade

Date Client Name CP Client Name Trade

Time

Trade

Rate

(Rs.)

Traded

Quantity

Buy/Sell

by the

Noticee

19/03/2015

RAM ASAVA

HUF KAUSTAV

CONSTRUCTION

PRIVATE LIMITED

11:55:26 0.35 50000 Buy

19/03/2015

KAUSTAV

CONSTRUCTION

PRIVATE LIMITED

RAM ASAVA

HUF 11:55:33 5.35 50000 Sell

22. As can be seen from the table above, the trades executed by the Noticee in the

contract was squared up within short time, with the same counterparty. Noticee on

March 19, 2015 at 11:55:26 hrs (Order time of Noticee and the Counterparty was

same as the trade time) entered into a buy trade with counterparty viz. KAUSTAV

CONSTRUCTION PRIVATE LIMITED for 50000 units at the rate of Rs. 0.35 per

unit in the contract ‘BPCL15MAR800.00CE’. Thereafter, on the same day at

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11:55:33 hrs, (Order time of the Noticee and the Counterparty was same as the

trade time), Noticee entered into 1 sell trade for 50000 units with same

counterparty viz. RAM ASAVA HUF at the average rate of Rs 5.35 per unit.

23. I note that while dealing in the said contract during the IP, the Noticee executed

reversal trade with same counterparty viz. KAUSTAV CONSTRUCTION PRIVATE

LIMITED, on the same day, with significant price difference.

24. Thus, the Noticee, through its dealing in the contract viz. ‘BPCL15MAR800.00CE’

during the I.P., executed trade which was 100% of the total trades from the market

in the said contract during the I.P., and thereby, Noticee generated artificial volume

of 1,00,000 units which was 100% of the volume traded in the said contract from

the market during the I.P.

25. The non-genuineness of these transactions executed by the Noticee is evident

from the fact that there was no commercial basis as to why, within a short span of

time, the Noticee reversed the position with its counterparty. The fact that the

transactions in a particular contract were reversed with the same counterparty

indicates a prior meeting of minds with a view to execute the reversal trades at a

pre-determined price. Since these trades were done in illiquid option contracts,

there was no trading in the said contract and hence, there was no price discovery

in the strictest terms. The wide variation in prices of the said contract, within a

short span of time, is a clear indication that there was pre-determination in the

prices by the counterparties while executing the trades. The fact that the buy and

sell orders were placed by the Noticee and counterparty within a short span of

time, strongly indicates meeting of minds. Thus, it is observed that Noticee had

indulged in reversal trades with its counterparty in the stock options segment of

BSE and the same were non-genuine trades.

26. I note that it is not mere coincidence that the Noticee could match its trades with

the same counterparty with whom it had undertaken first leg of the respective

trades. The fact that the transactions in a particular contract were reversed with

the same counterparty for the same quantity of units, indicates a prior meeting of

minds with a view to execute the reversal trades at a pre-determined price. This is

the outcome of meeting of minds and it was a deliberate attempt to deal in such a

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manner. In this regard, it is noted that in matters dealing with violation of PFUTP

Regulations, the reason as with respect to execution of non-genuine trades might

not be immediately forthcoming. However, the correct test instead, is one of

preponderance of probabilities and therefore at this juncture, it is pertinent to rely

on the judgment of Hon’ble Supreme Court in SEBI v Kishore R Ajmera (AIR

2016 SC 1079) decided on February 23, 2016, wherein it was held that-

“...According to us, knowledge of who the 2nd party / client or the broker is, is not relevant

at all. While the screen based trading system keeps the identity of the parties anonymous it

will be too naïve to rest the final conclusions on the said basis which overlooks a meeting

of minds elsewhere. Direct proof of such meeting of minds elsewhere would rarely be

forthcoming...in the absence of direct proof of meeting of minds elsewhere in synchronized

transactions, the test should be one of preponderance of probabilities as far as adjudication

of civil liability arising out of the violation of the Act or provision of the Regulations is

concerned. The conclusion has to be gathered from various circumstances like that volume

of the trade effected; the period of persistence in trading in the particular scrip; the

particulars of the buy and sell orders, namely, the volume thereof; the proximity of time

between the two and such other relevant factors. The illustrations are not exhaustive...”

27. The Hon’ble Supreme Court further held in the same matter that – “It is a

fundamental principle of law that proof of an allegation levelled against a person may be

in the form of direct substantive evidence or, as in many cases, such proof may have to be

inferred by a logical process of reasoning from the totality of the attending facts and

circumstances surrounding the allegations/charges made and levelled. While direct

evidence is a more certain basis to come to a conclusion, yet, in the absence thereof, the

Courts cannot be helpless. It is the judicial duty to take note of the immediate and

proximate facts and circumstances surrounding the events on which the

charges/allegations are founded and to reach what would appear to the Court to be a

reasonable conclusion therefrom. The test would always be that what inferential process

that a reasonable/prudent man would adopt to arrive at a conclusion.”

28. The observations made in the aforesaid judgments of Hon’ble Supreme Court

apply to the facts and circumstances of the present case. It is visible that the

execution of trades by the Noticee in the illiquid options segment with such

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precision in terms of order placement, time, price, quantity etc. and also the fact

that the transactions were reversed with the same counterparty with the same

quantity clearly indicates a prior meeting of minds with a view to execute the

reversal trades at a pre-determined price. The only reason for the wide variation

in prices of the same contract, within short span of time was a clear indication that

there was pre-determination in the prices by both the counterparty when executing

the trades. Thus, the nature of trading, as brought out above, clearly indicates an

element of prior meeting of minds and therefore, a collusion of the Noticee with

his counterparty to carry out the trades at pre-determined prices.

29. Further, following is noted from the judgement of the Hon’ble SAT in the matter of

Ketan Parekh vs SEBI (supra):

In other words, if the factum of manipulation is established it will necessarily follow that

the investors in the market had been induced to buy or sell and that no further proof in this

regard is required. The market, as already observed, is so wide spread that it may not be

humanly possible for the Board to track the persons who were actually induced to buy or

sell securities as a result of manipulation and law can never impose on the Board a burden

which is impossible to be discharged. This, in our view, clearly flows from the plain

language of Regulation 4 (a) of the Regulations.

30. It would be instrumental to also place reliance on the judgment of Hon’ble

Supreme Court in the matter of SEBI v Rakhi Trading Private Limited (Civil

Appeal Nos. 1969, 3174-3177 and 3180 of 2011 decided on February 8, 2018),

in which the Hon’ble SC held that - “Considering the reversal transactions, quantity,

price and time and sale, parties being persistent in number of such trade transactions with

huge price variations, it will be too naive to hold that the transactions are through screen-

based trading and hence anonymous. Such conclusion would be over-looking the prior

meeting of minds involving synchronization of buy and sell order and not negotiated deals

as per the board's circular. The impugned transactions are manipulative/deceptive device

to create a desired loss and/or profit. Such synchronized trading is violative of transparent

norms of trading in securities…..”.

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31. Further, the Hon’ble SAT in its judgement dated September 14, 2020 in the matter

of Global Earth Properties and Developers Pvt Ltd relied upon the Hon’ble

Supreme Court judgement in the matter of SEBI v Rakhi Trading Private Limited

(Civil Appeal Nos. 1969, 3174-3177 and 3180 of 2011 decided on February 8,

2018), and held that, “It is not a mere coincidence that the Appellants could match the

trades with the counter party with whom he had undertaken the first leg of respective trade.

In our opinion, the trades were non-genuine trades and even though direct evidence is not

available in the instant case but in the peculiar facts and circumstances of the present case

there is an irresistible inference that can be drawn that there was meeting of minds

between the Appellants and the counter parties, and collusion with a view to trade at a

predetermined price.”

32. In view of the observations of Hon’ble Supreme Court and SAT in the above

judgments, it can be said that the Noticee had prior meeting of minds to execute

such non-genuine trades at a pre-determined price for the sole purpose to create

artificial volume in the market.

33. Therefore, the trading behaviour of the Noticee confirms that such trades were not

normal indicating that the trades executed by the Noticee were not genuine trades

and being non-genuine, created an appearance of artificial trading volumes in

respective contracts. In view of the above, the violation of Regulations 3(a), (b),

(c), (d), 4(1) and 4(2)(a) of PFUTP Regulations, against the Noticee stands

established.

Issue (b): Does the violation, if any, attract monetary penalty u/s 15HA of the

SEBI Act, 1992?

34. Considering the findings that the Noticee has executed non-genuine trades

resulting in the creation of artificial volume, thereby violating the provisions of

Regulation 3(a), (b), (c) & (d) & Regulation 4(1) and 4(2)(a) of the PFUTP

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Regulations, it is a fit case for imposition of monetary penalty on Noticee u/s

Section 15HA of SEBI Act which reads as under:

Penalty for fraudulent and unfair trade practices.

15HA. If any person indulges in fraudulent and unfair trade practices relating to securities,

he shall be liable to a penalty which shall not be less than five lakh rupees but which may

extend to twenty - five crore rupees or three times the amount of profits made out of such

practices, whichever is higher.

Issue (c): If so, what would be the quantum of monetary penalty that can be

imposed on the Noticee after taking into consideration the factors mentioned in

Section 15J of the SEBI Act?

35. While determining the quantum of penalty u/s 15HA of SEBI Act, it is important to

consider the factors as stipulated in Section 15J of the SEBI Act which reads as

under:

15J. While adjudging quantum of penalty under [15-I or section 11 or section 11B, the Board or

the adjudicating officer] shall have due regard to the following factors, namely:—

(a) the amount of disproportionate gain or unfair advantage, wherever quantifiable, made as a

result of the default;

(b) the amount of loss caused to an investor or group of investors as a result of the default;

(c) the repetitive nature of the default.

36. It is observed that the material available on record does not quantify any

disproportionate gains or unfair advantage, if any, made by the Noticee and the

losses, if any, suffered by the investors due to such violations on part of the said

Noticee. However, the Noticee has entered into 4 non-genuine trades which

demonstrates the violation of PFUTP Regulations.

ORDER

37. Having considered all the facts and circumstances of the case, the material

available on record, the factors mentioned in section 15J of the SEBI Act, and in

exercise of power conferred u/s 15-I of the SEBI Act, r/w Rule 5 of the SEBI

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Adjudication Rules, following penalty u/s 15HA of the SEBI Act is imposed on the

Noticee:

Name of the Noticee Violation provisions Penalty

Ram Asava HUF

(AARHR3709J)

Regulations 3(a), (b), (c), (d),

4(1) and 4(2)(a) of PFUTP

Regulations

Rs 5,00,000/-

(Rupees Five Lakhs

only)

38. I find the said penalty to be commensurate with the violation on the part of the

Noticee.

39. The Noticee shall remit / pay the said amount of penalty within 45 days of receipt

of this order either through online payment facility available on the website of

SEBI, i.e. www.sebi.gov.in on the following path, by clicking on the payment link:

ENFORCEMENT > Orders > Orders of AO > PAYNOW

40. In the event of failure to pay the said amount of penalty within 45 days of the receipt

of this Order, SEBI may initiate consequential actions including but not limited to

recovery proceedings u/s 28A of the SEBI Act for realization of the said amount of

penalty along with interest thereon, inter alia, by attachment and sale of movable and

immovable properties.

41. In terms of the provisions of Rule 6 of the SEBI Adjudication Rules, a copy of this

order is being sent to the Noticee viz. Ram Asava HUF and also to SEBI.

Date: August 13, 2026 MEDHA SONPAROTE

Place: Mumbai ADJUDICATING OFFICER