Primary sources · Order
Ex-Parte Interim Order in the matter of manipulative trades during CAS on SENSEX expiry at BSE- August 13, 2026
- SEBI adapter: text extracted by Firecrawl; the source PDF was not retrieved, so no original file is archived.
SECURITIES AND EXCHANGE BOARD OF INDIA EX-PARTE INTERIM ORDER
UNDER SECTIONS 11(1), 11(4) AND 11B(1) OF THE SECURITIES AND
EXCHANGE BOARD OF INDIA ACT, 1992
IN THE MATTER OF MANIPULATIVE TRADES DURING CAS ON SENSEX EXPIRY
AT BSE– AUGUST 13, 2026.
In respect of:
Sr. No.
Names ofNoticees
PAN
1.
Copthall Mauritius Investment Limited
AAACC4303M
2.
Mansi Share and Stock Broking Private Limited
AADCM6645D
(The entities mentioned above are individually referred to by their respective names or Noticee No. and
1
collectively referred to as “Noticees”, unless the context specifies otherwise)
TABLE OF CONTENTS
TABLE OF CONTENTS............................................................................................................................... 1
A. BACKGROUND................................................................................................................................ 2
B. BRIEF FINDINGS OF THE EXAMINATION BY SEBI........................................................................... 3
C. ANALYSIS OF TRADING PATTERN IN CAS ON BSE......................................................................... 5
C.1 Spike 1 (15:20:41 to 15:20:43)............................................................................................... 8
C.2 Spike 2 (15:24:08 to 15:24:20)............................................................................................. 12
C.3 Spike 3 (15:25:49 to 15:26:17)............................................................................................. 14
C.4 Drawdown by Mansi (15:21:03 to 15:26:00)....................................................................... 17
D. OBSERVATIONS ON UNUSUAL TRADING PATTERN OF THE NOTICEES....................................... 19
D.1.1 Activity of Copthall Mauritius Investment Limited..................................................... 22
D.1.2 Activity of Mansi Share and Stock Broking Private Limited........................................ 22
D.2 F&O position vis-a-vis cash trading pattern........................................................................ 23
D.3 Consideration of issues and prima facie findings................................................................ 26
D.4 Calculation of Wrongful gains.............................................................................................. 36
D.4.1 Calculation of Wrongful gains of Copthall Mauritius Investment Limited:................ 36
1
Some names who are not Noticees are anonymised and actual name would be supplied to Noticees during
inspection and to Hon’ble Securities Appellate Tribunal and Courts, during court proceedings.
Page 1 of 46
[Image: Image20]
D.4.2 Calculation of Wrongful gains of Mansi Share and Stock Broking Private Limited.... 38
E. Need for Interim Order................................................................................................................ 41
F. DIRECTIONS.................................................................................................................................. 43
A. BACKGROUND
1. Securities and Exchange Board of India (“SEBI”) vide Circular (“SEBI
Circular”) dated January 16, 2026 introduced Closing Auction Session
(“CAS”) on the platform of stock exchanges. The framework for CAS as
prescribed in the aforesaid SEBI Circular became effective from August 03,
2026. The CAS was made applicable in a phased manner and initially, the
closing price of the stocks in the cash segment on which derivative
contracts are available are to be determined based on the prescribed
framework of CAS.
2. As per provisions of the said SEBI Circular, the normal trading in the
covered scrips in cash segment halts at 15:15 and a reference price for
these scrips is calculated between 15:15 to 15:20. Thereafter, the CAS
begins at 15:20 and continues till 15:30 subject to random closure by stock
exchanges between 15:28 and15:30. The price band applicable during
CAS is +/-3% from the reference price of the stock. Thereafter, by 15:35, a
single equilibrium price is discovered where maximum quantity of the
shares is executable.
3. The methodology for computation of the closing price for index is
paraphrased here from para 4.9 from the SEBI Circular and the same is as
follows:
1.1.9. The settlement price shall be the closing price of the underlying index on
the day of expiry. The closing price of the underlying index shall be based on
the closing price of the constituents of the underlying index.
Page 2 of 46
4. Further as per para 4.12 of the SEBI Circular, the following information shall
be disseminated during CAS:
4.12.1. Indicative equilibrium price of the stock
4.12.2. Indicative cumulative buy and sell quantity of the stock
4.12.3. Indicative imbalance quantity of the stock at equilibrium price
4.12.4. Indicative imbalance quantity based on market orders of the stock
4.12.5. Indicative Index
5. After implementation of CAS, SEBI surveillance has been monitoring it on
every day. CAS is designed to improve price discovery and transparency.
It provides SEBI with greater ability to identify potential manipulation
compared to the earlier system based on volume weighted average price
(“VWAP”). SEBI surveillance noted abnormal spikes in the Indicative
Equilibrium Price (“IEP”) of Sensex on August 13, 2026, Thursday which
was also a BSE Sensex weekly expiry day for derivative contracts. The
broad concerns seen were in respect of the recovery of 113.61 points in
Sensex, sharp price movement in options etc. Accordingly, a detailed
examination of the trading activity in the CAS of BSE on August 13, 2026
was carried out by SEBI.
B. BRIEF FINDINGS OF THE EXAMINATION BY SEBI
6. During the CAS (15:20 to 15:30) on August 13, 2026 which was a Sensex
weekly expiry day on BSE, it was observed that the reference price of the
Sensex was 77829.6 at 15:15 . The CAS started at 15:20 and the closing
price of Sensex arrived through CAS was 78079.96 (rounded off to 78080
for calculations) based on the constituents of the Sensex. However, abrupt
Page 3 of 46 changes in the movement of IEP were noted during the CAS. The
movement of the IEP is depicted in the chart given below:
Figure 1 Indicative SENSEX Equilibrium Price
Indicative SENSEX Equilibrium price
78300.00
spike 1
spike 2
spike 3
78200.00
78100.00
78000.00
77900.00
77800.00
77700.00
77600.00
77500.00
77400.00
15:18:09
15:20:15
15:20:30
15:20:47
15:21:02
15:21:17
15:21:32
15:21:47
15:22:02
15:22:17
15:22:32
15:22:47
15:23:02
15:23:17
15:23:32
15:23:47
15:24:02
15:24:17
15:24:32
15:24:47
15:25:02
15:25:17
15:25:32
15:25:47
15:26:02
15:26:17
15:26:32
15:26:47
15:27:02
15:27:17
15:27:32
15:27:47
15:28:02
15:28:17
15:28:32
15:28:47
15:29:02
15:29:17
7. August 13, 2026 was the weekly expiry day of Sensex options and the
settlement price of the said options was to be based on the closing price of
the Sensex determined during the CAS.
8. As can be seen from the above chart that there were 3 substantial price
spikes along with one gradual drawdown during the CAS. The spikes are
summarized in the table below.
Table 1
Parameter
Spike 1 sec)
Spike 2
Spike 3
Time Window
15:20:41 to 15:20:43(2sec)
15:24:08 to 15:24:20(12sec)
15:25:49 to 15:26:17(28sec)
Sensex Movement
77,661.40 to 78,023.42
77,707.84 to 77,840.51
77,787.94 to 78,193.02
Sensex Point Spike
+362.02 points
+132.67 points
+405.08 points
Page 4 of 46
9. Thus, a significant price spike (“Spike 1”) was observed in the BSE
SENSEX, where the SENSEX IEP rose from 77,661.40 to 78,023.42
(+362.02 points) within a two-second interval (15:20:41 to 15:20:43),
indicating an abrupt surge. In addition to the first spike, a second significant
movement (“Spike 2”) occurred between 15:24:08 and 15:24:20, where the
BSE SENSEX appreciated by 132.67 points, moving from 77,707.84 to
77,840.51 in a span of 12 seconds.
**10.**Furthermore, a third instance of abnormal price movement (“Spike 3”) was
recorded shortly thereafter. Between 15:25:49 and 15:26:17, the BSE
SENSEX IEP witnessed a sharp rise from 77,787.94 to 78,193.02. This
movement, represented an increase of 405.08 points within a brief window
of 28 seconds.
**11.**Also, it is observed that during the interval from 15:21:03 to 15:26:00, the
BSE SENSEX exhibited a general downward trajectory, declining from
77,991.05 to 77,893.61. It is pertinent to note that this drawdown was
intermittently interrupted by one of the aforementioned price spikes, which
caused a temporary deviation from the prevailing downward trend in this
period.
**12.**The correlation between the aforesaid spikes and the trading activity of
Noticees are analysed in the subsequent sections of this order.
C. ANALYSIS OF TRADING PATTERN IN CAS ON BSE
**13.**The top 10 entities on Gross Buy Basis at PAN level as on August 13, 2026
in CAS in SENSEX constituents are as given in the table below:
Table 2
Client Name
Gross BuyValue (₹ inCrs.)
Gross value%
COPTHALL MAURITIUS INVESTMENT LIMITED
191.29
86.60
Other buyer #2
12.24
5.54
Page 5 of 46
Other buyer #3
6.63
3.00
Other buyer #4
2.17
0.98
Other buyer #5
0.84
0.38
Other buyer #6
0.25
0.11
Other buyer #7
0.22
0.10
Other buyer #8
0.22
0.10
Other buyer #9
0.20
0.09
Other buyer #10
0.20
0.09
**14.**From the table above, it may be noted that the 86.6% of the gross buy value
was traded by a single entity, i.e., Copthall Mauritius Investment Limited
(“Copthall”/“***Noticee No.***1”).
**15.**The top 10 entities on Gross Sell Basis at PAN level as on August 13, 2026
in CAS in SENSEX constituents are as given in the table below:
Table 3
Client Name
Gross Sellvalue (₹inCrs.)
Gross Sell %
seller #1
76.03
34.42
seller #2
25.87
11.71
seller #3
19.85
8.99
seller #4
10.09
4.57
seller #5
9.63
4.36
seller #6
8.39
3.80
seller #7
6.13
2.78
seller #8
5.43
2.46
seller #9
5.15
2.33
seller #10
4.53
2.05
**16.**The top 10 entities on Gross buy order quantity cancelled at PAN level as
on August 13, 2026 in CAS are as given in the table below:
Page 6 of 46
Table 4
Client Name
Gr. Buy Orderquantity Placed
Gr. BuyOrderquantitycancelled
COPTHALL MAURITIUS INVESTMENT LIMITED
31,66,651
10,38,201
Entity #2
2,71,125
1,97,796
Entity #3
1,49,901
1,06,900
Entity #4
1,00,000
1,00,000
Entity #5
26,02,268
72,368
Entity #6
8,94,708
67,465
Entity #7
60,000
60,000
Entity #8
1,77,993
50,100
Entity #9
50,000
50,000
Entity #10
45,000
45,000
**17.**From the table above, it can be observed that Copthall cancelled the
highest number of buy orders worth ₹98.11 Crore. The entity cancelled a
total of 10,38,201 out of the order quantity of 31,66,651, i.e., a cancellation
percentage of 32.79%.
**18.**The top 10 entities on Gross Sell order quantity cancelled at PAN level as
on August 13, 2026 in CAS are as given in the table below:
Table 5
Client Name
Gr. Sell OrderquantityPlaced
Gr. SellOrderquantitycancelled
MANSI SHARE AND STOCK BROKING PRIVATE LIMITED
12,77,000
12,65,000
Entity #2
5,15,180
5,15,000
Entity #3
34,80,702
3,08,589
Entity #4
3,00,000
3,00,000
Page 7 of 46
Client Name
Gr. Sell OrderquantityPlaced
Gr. SellOrderquantitycancelled
Entity #5
2,98,758
2,98,758
Entity #6
4,23,625
2,52,300
Entity #7
3,72,119
1,71,522
Entity #8
1,50,000
1,50,000
Entity #9
2,25,800
1,44,900
Entity #10
6,86,353
1,08,003
**19.**From the table above, it may be observed that Mansi Share and Stock
Broking Private Limited (“Mansi”/“Noticee No. 2”) cancelled the highest
number of sell orders. The entity cancelled a total of 12,65,000 out of the
sell order quantity of 12,77,000, i.e., a cancellation percentage of 99.06%.
**20.**The nature of buy concentration, order placement and order cancellation by
the entities mentioned above appeared to warrant a detailed examination
of the nature of the orders placed by these entities and the impact of the
said order placement and cancellation on the IEP on August 13, 2026.
Accordingly, a detailed examination has been conducted into the price
movement of the constituents of SENSEX for the spikes and drawdown
mentioned in the preceding paragraphs.
C.1 Spike 1 (15:20:41 to 15:20:43)
**21.**It was observed that between 15:20:41 and 15:20:43 in the CAS, there was a
spike of around 362.02 points in SENSEX IEP abruptly from 77661.4 to
78023.42. In order to ascertain the cause of such abrupt spike, the IEP change
in the underlying constituents during the period 15:20:41 to 15:20:43 was
examined. It was also examined as to which entity(s) had caused this price
spike. The movement in the IEP of constituents during the period (15:20:41 to
15:20:43) was examined. The details of the IEP movement of SENSEX
Page 8 of 46 constituent scrips, with significant change above reference price during the
aforesaid period is as given below:
Table 6
Scrip Code
Symbol
% Change in IEP
539448
INDIGO
2.62
532755
TECHM
2.44
500251
TRENT
1.91
532978
BAJAJFINSV
1.60
543320
ETERNAL
1.26
532921
ADANIPORTS
1.19
532215
AXISBANK
1.06
500247
KOTAKBANK
1.00
532555
NTPC
0.91
532898
POWERGRID
0.88
500520
M&M
0.86
500820
ASIANPAINT
0.84
532538
ULTRACEMCO
0.82
500470
TATASTEEL
0.82
500875
ITC
0.81
500049
BEL
0.71
524715
SUNPHARMA
0.50
500510
LT
0.50
532540
TCS
0.50
500696
HINDUNILVR
0.50
500034
BAJFINANCE
0.50
532281
HCLTECH
0.49
532500
MARUTI
0.47
500209
INFY
0.21
**22.**An analysis of the trade log and Order log of the period was conducted and
summarised as follows:
Table 7
Parameter
Value
Time Window
15:20:41 to 15:20:43 (2 seconds)
Total Sell Orders
14 orders
Total Buy Orders
88 orders (86 Limit, 2 Market)
Total Buy Order Value
₹66,63,96,390 (~₹66.64 Cr)
Total Sell Order Value
₹17,64,468.4(~₹17.64 Cr)
Page 9 of 46
**23.**From the table above, it is observed that during the period 15:20:41 to
15:20:43 (2 seconds) 88 buy orders were placed and out of that, 86 buy
orders were limit orders. These orders aggregate to a value of approx.
₹66.64 crores. Further, the Order log of the entity, Copthall, who appeared
at the top both in terms of gross buy value and gross buy order cancelled,
was examined and summarised as follows:
Table 8
Particulars
PAN: AAACC4303MCopthall Mauritius Investment Limited
Other Market Participants
Total / MarketImpact
Limit Buy Orders
32
54
86
Order Value
₹ 66,57,90,274
₹6,06,115
₹ 66,63,96,390
% Share of Value
99.91%
0.09%
100.00%
Price where limitorders placed
+3.0% above referenceprice
Below +2.0% (0 orders >+2%)
Extremedivergence
Scrip Coverage
Placed across all Sensexscrips
Distributed and varied
Concentratedmarket-wide impact
**24.**From the table above, it is observed that 32 of the 86 total limit buy orders
were placed by Copthall. Further, the gross order value of the orders placed
by Copthall was approx. ₹66.57 Crore in comparison to total market gross
order value of ₹66.64 Crore i.e., 99.91% of the total order value. The table
given below shows the summary of the orders placed by Copthall that prima
facie has caused this spike. The table clearly shows that the buy orders
were placed by Copthall at a range of 2.7% to 3% above reference price
and all the orders were entered at the same time.
Table 9
Symbol
Scrip Name
Ordertime
Avg. BuyOrderprice
Sum ofOrderQuantity
Sum of OrderValue
Max ofReferenceprice (RP)
Deviationfrom RP
532755
TECHM
15:20:42
1688.05
3898
65,80,019
1638.9
2.999%
524715
SUNPHARMA
15:20:42
1996.35
4591
91,65,243
1938.25
2.998%
500696
HINDUNILVR
15:20:42
2150.9
1738
37,38,264
2088.3
2.998%
500510
LT
15:20:42
4178.95
8120
3,39,33,074
4057.25
3.000%
532454
BHARTIARTL
15:20:42
1998.65
31493
6,29,43,484
1940.45
2.999%
532281
HCLTECH
15:20:42
1405.45
5628
79,09,873
1364.55
2.997%
500520
M&M
15:20:42
3503.05
3077
1,07,78,885
3401.05
2.999%
500049
BEL
15:20:42
421.55
20397
85,98,355
409.3
2.993%
Page 10 of 46
time
Avg. Buy Order price
Sum of Order Quantity
Sum of Order Value
Max of Reference price (RP)
Deviation from RP
500470
TATASTEEL
15:20:42
189.25
26536
50,21,938
183.75
2.993%
500251
TRENT
15:20:42
3083
1278
39,40,074
2993.25
2.998%
500875
ITC
15:20:42
285.6
17959
51,29,090
277.3
2.993%
532898
POWERGRID
15:20:42
275.55
10831
29,84,482
267.55
2.990%
532540
TCS
15:20:42
2438.8
5241
1,27,81,751
2367.8
2.999%
500180
HDFCBANK
15:20:42
748.6
157556
11,79,46,422
726.8
2.999%
500034
BAJFINANCE
15:20:42
1120.5
14394
1,61,28,477
1087.9
2.997%
543320
ETERNAL
15:20:42
327.6
38611
1,26,48,964
318.1
2.986%
532174
ICICIBANK
15:20:42
1452.65
74112
10,76,58,797
1410.35
2.999%
500112
SBIN
15:20:42
1108.5
42939
4,75,97,882
1076.25
2.997%
500114
TITAN
15:20:42
5188.75
4221
2,19,01,714
5037.65
2.999%
532555
NTPC
15:20:42
352.6
9948
35,07,665
342.35
2.994%
532500
MARUTI
15:20:42
14278.05
913
1,30,35,860
13862.2
3.000%
500325
RELIANCE
15:20:42
1352.5
69944
9,45,99,260
1313.15
2.997%
532978
BAJAJFINSV
15:20:42
2080.9
2759
57,41,203
2020.3
3.000%
500247
KOTAKBANK
15:20:42
402.95
20424
82,29,851
391.25
2.990%
532921
ADANIPORTS
15:20:42
1701
2387
40,60,287
1651.5
2.997%
539448
INDIGO
15:20:42
5498.95
1227
67,47,212
5338.8
3.000%
500209
INFY
15:20:42
1201.45
14464
1,73,77,773
1166.5
2.996%
532215
AXISBANK
15:20:42
1255.85
7472
93,83,711
1219.3
2.998%
500820
ASIANPAINT
15:20:42
2816.7
918
25,85,731
2734.7
2.999%
532538
ULTRACEMCO
15:20:42
12011.25
261
31,34,936
11661.45
3.000%
Total
6,03,337
66,57,90,275
**25.**Further, in comparison to other market participants, it is observed that the
orders placed by Copthall were limit orders with limit near the upper
permissible limit under the CAS regulation (3% above reference price),
whereas orders of other participants varied between 0% to 2%. Further,
Copthall placing buy orders across all the constituents of SENSEX at the
same time in a coordinated manner, especially at higher prices indicates a
prima facie intent to manipulate the closing price by increasing the IEP of
SENSEX in CAS.
**26.**Even though it was short lived, in the initial seconds of 15:20:03 to 15:20:06
there was a dip in the Sensex IEP by 451 points. The same drawdown is
also under further examination by SEBI.
Page 11 of 46
**27.**After the spike at 15:20:43 Sensex gradually fell down from 78023.42 to
77707.84 by 15:24:07 due to sell orders placed by the Noticee No. 2 (the
details of analysis of the sell orders is explained in subsequent sections of
this order).
**28.**Also prior to Spike 2, during the period 15:23:47 to 15:24:06 there was a
sudden dip in Sensex of 127.26 points, upon analysis it is observed that
during the period, the biggest fall was in the scrip of LT and it may be noted
that during the exact same period the Noticee No. 2 had placed sell orders
worth ₹39.5 crores at -2.52%. This apparently had caused the dip in
Sensex.
**29.**Moving to Spike 2, it is seen that between 15:24:08 to 15:24:20 there was
a rise in Sensex IEP of 132.67 points from 77707.84 to 77840.51. An
analysis of the trade log and order log of the period was conducted and is
summarised as follows:
Table 10
Parameter
Market Total
Time Window
15:24:08 to 15:24:20 (12 seconds)
Total Sell Orders
37 orders
Total Buy Orders
189 orders (165 Limit, 24 Market)
Total Buy Order Value
₹131,74,23,873 (~₹131.74 Cr)
Total Sell Order Value
₹2,97,11,083.8 (~₹ 2.97 Cr)
**30.**From the table above, it is observed that during the period 15:24:08 to
15:24:20 (12 seconds) 189 buy orders were placed and out of that 165 were
limit orders. These orders aggregate to a value of approx. ₹131.74 crores.
The nature of order placement of Copthall in this spike period is also
examined and is summarised as follows:
Page 12 of 46
Table 11
Particulars
PAN: AAACC4303M Copthall Mauritius Investment Limited
Other Market Participants
Total / Market Impact
Limit Buy Orders
108
57
165
Order Value
₹126,58,69,574.00(~₹126.59 Cr)
₹5,15,54,299.00(~₹5.16 Cr)
₹1,31,74,23,873
% Share of Value
96.09%
3.91%
100.00%
Price where limit orders placed
+3% above reference price
<+1.0%(All 57 orders below +1%)
Aggressive price markup
Scrip Coverage
Placed across all Sensex scripts
Distributed across market
Systematic index-wide impact
**31.**From the table above, it is observed that 108 of the 165 total limit buy orders
were placed by Copthall. Further, the gross order value of the orders placed
by Copthall is approx. ₹126.59 Crore in comparison to total market gross
order value of ₹131.74 Crore i.e., 96.09% of the total order value. The table
given below shows the summary of the orders placed by Copthall that
caused this spike. The table clearly shows that the buy orders were placed
at a range of 2.7% to 3% above the reference price.
Table 12
time start
Order time end
Buy Order Price
Sum of Order Quantity
Sum of Order Value
Max of Referen ce price (RP)
Deviati on from RP
500034
BAJFINANCE
15:24:08
15:24:12
1120.5
40954
4,58,88,957
1087.9
2.997%
500049
BEL
15:24:08
15:24:17
421.55
66835
2,81,74,294
409.3
2.993%
500112
SBIN
15:24:08
15:24:08
1108.5
42938
4,75,96,773
1076.25
2.997%
500114
TITAN
15:24:08
15:24:08
5188.75
4222
2,19,06,903
5037.65
2.999%
500180
HDFCBANK
15:24:08
15:24:08
748.6
157556
11,79,46,42 2
726.8
2.999%
500209
INFY
15:24:08
15:24:08
1201.45
36055
4,33,18,280
1166.5
2.996%
500247
KOTAKBANK
15:24:08
15:24:17
402.95
111631
4,49,81,711
391.25
2.990%
500251
TRENT
15:24:08
15:24:20
3083
6483
1,99,87,089
2993.25
2.998%
500325
RELIANCE
15:24:08
15:24:08
1352.5
69945
9,46,00,613
1313.15
2.997%
500470
TATASTEEL
15:24:08
15:24:17
189.25
152703
2,88,99,043
183.75
2.993%
500510
LT
15:24:08
15:24:08
4178.95
14319
5,98,38,385
4057.25
3.000%
500520
M&M
15:24:08
15:24:17
3503.05
17290
6,05,67,735
3401.05
2.999%
500696
HINDUNILVR
15:24:08
15:24:18
2150.9
16721
3,59,65,199
2088.3
2.998%
500820
ASIANPAINT
15:24:08
15:24:18
2816.7
8402
2,36,65,913
2734.7
2.999%
500875
ITC
15:24:08
15:24:13
285.6
139150
3,97,41,240
277.3
2.993%
524715
SUNPHARMA
15:24:08
15:24:12
1996.35
17730
3,53,95,286
1938.25
2.998%
532174
ICICIBANK
15:24:08
15:24:08
1452.65
74113
10,76,60,24 9
1410.35
2.999%
532215
AXISBANK
15:24:08
15:24:18
1255.85
51669
6,48,88,514
1219.3
2.998%
532281
HCLTECH
15:24:08
15:24:13
1405.45
18037
2,53,50,102
1364.55
2.997%
Page 13 of 46
Symbol
Scrip Name
Ordertime start
Ordertime end
Buy OrderPrice
Sum ofOrderQuantity
Sum ofOrder Value
Max ofReference price(RP)
DeviationfromRP
532454
BHARTIARTL
15:24:08
15:24:08
1998.65
31494
6,29,45,483
1940.45
2.999%
532500
MARUTI
15:24:08
15:24:18
14278.05
2248
3,20,97,056
13862.2
3.000%
532538
ULTRACEMCO
15:24:08
15:24:17
12011.25
2239
2,68,93,189
11661.45
3.000%
532540
TCS
15:24:08
15:24:17
2438.8
19486
4,75,22,457
2367.8
2.999%
532555
NTPC
15:24:08
15:24:20
352.6
79214
2,79,30,856
342.35
2.994%
532755
TECHM
15:24:08
15:24:12
1688.05
9271
1,56,49,912
1638.9
2.999%
532898
POWERGRID
15:24:08
15:24:18
275.55
83388
2,29,77,563
267.55
2.990%
532921
ADANIPORTS
15:24:08
15:24:13
1701
12855
2,18,66,355
1651.5
2.997%
532978
BAJAJFINSV
15:24:08
15:24:12
2080.9
8822
1,83,57,700
2020.3
3.000%
539448
INDIGO
15:24:08
15:24:12
5498.95
3409
1,87,45,921
5338.8
3.000%
543320
ETERNAL
15:24:08
15:24:08
327.6
74818
2,45,10,377
318.1
2.986%
Total
13,73,997
1,26,58,69,574
**32.**Further, in comparison to other market participants, it is noted that the
orders placed by Copthall were limit orders with limit near the upper
permissible limit under the CAS regulation (3% above reference price),
whereas, orders of other participants varied between 0% to 1%. Further,
Copthall placing buy orders across all the constituents of SENSEX around
the same time in a coordinated manner, especially at higher prices indicates
a prima facie intent to manipulate the closing price by increasing the IEP of
SENSEX in CAS.
C.3 Spike 3 (15:25:49 to 15:26:17)
**33.**During the period between 15:25:49 and 15:26:17 (28 seconds) another
significant spike of 405.8 points was observed, wherein SENSEX moved
from 77787.94 to 78193.02. The price movement in the constituents during
the period (15:25:49 to 15:26:17) was examined. The details of the IEP
movement of SENSEX constituent scrips, with significant change above
reference price during the aforesaid period is as given below:
Table 13
Scrip Code
Name
% Change in IEP
500510
LT
2.89
543320
ETERNAL
1.60
500875
ITC
1.01
Page 14 of 46
500251
TRENT
0.86
500114
TITAN
0.63
532174
ICICIBANK
0.50
500325
RELIANCE
0.50
500112
SBIN
0.50
500209
INFY
0.50
500180
HDFCBANK
0.50
539448
INDIGO
0.45
532281
HCLTECH
0.30
500520
M&M
0.18
532215
AXISBANK
0.10
500049
BEL
0.10
500247
KOTAKBANK
0.09
532454
BHARTIARTL
0.04
**34.**An analysis of the trade log and order log of the period was conducted and
the same is summarised as follows:
Table 14
Parameter
Market Total
Time Window
15:25:49 to 15:26:17 (28 seconds)
Total Sell Orders
118 orders
Total Buy Orders
176 orders (All 176 Limit)
Total Buy Order Value
₹115,14,87,476 (~₹115.15 Cr)
Total Sell Order Value
₹84,22,14,315.5(~₹84.22Cr)
$$
384.22.14.315.5(\approx3.84.22(1)
$$
**35.**From the table above, it is observed that during the period 15:25:49 to
15:26:17 (28 seconds) 176 buy orders were placed and out of that all 176
were limit orders. These orders aggregate to a value of approx. ₹115.15
crores. The nature of order placement of Copthall in this spike period was
also examined and the same is summarised as follows:
Table 15
Particulars
PAN: AAACC4303M Copthall Mauritius Investment Limited
Other Market Participants
Total / Market Impact
Limit Buy Orders
32
144
176
Order Value
₹98,11,70,665 (~98.12 Cr)
₹17,03,16,810 (~17.03 Cr)
₹115,14,87,476(~115.14Cr)
% Share of Value
85.21%
14.79%
100.00%
Price where limit orders placed
+3% above reference price
<+2.0%(143 of 144 Orders)
Aggressive price markup
Page 15 of 46
Scrip Coverage
Placed across all Sensex scrips
Only 1 Order in ICICI placed above 2% for a value of Rs. 4.23 Cr.
Systematic index- wide impact
**36.**From the table above, it is observed that 32 of the 176 total limit buy orders
were placed by Copthall. Further, the gross order value of the orders placed
by Copthall is approx. ₹98.12 Crore in comparison to total market gross
order value of ₹115.15 Crore i.e., 85.21% of the total order value.
**37.**Further, in comparison to other market participants, it is seen that the orders
placed by Copthall were limit orders with limit near the maximum
permissible limit under the CAS regulation (3% above reference price),
whereas, orders of other CAS participants (143 of the 144 orders) varied
between 0% to 2%. The only exception being one order in ICICI placed
above 2% for a value of ₹4.23 Crore.
**38.**The price rise in Spike 3 period is further accentuated by the bulk order
cancellations of pending sell orders across 8 scrips by the Noticee No. 2.
The cancellation of the said high value sell orders completely changed the
order matching and caused a sudden spike in SENSEX IEP due to the
presence of aggressive buy orders of Copthall. The details of the nature of
order placement by the Noticee No. 2 has been discussed in detail in the
subsequent sections of this order.
**39.**Sequence of events in Spike 3: The Noticee No. 2 cancelled its sell orders
by 15:26:05 and the SENSEX IEP rose sharply because of the sudden
order imbalance i.e., presence of aggressive buy orders of Copthall and the
lack of counteraction by a large sell order. At 15:26:14, Copthall again
placed buy orders across all 30 Sensex scrips at higher prices and caused
an additional jump in the SENSEX IEP. Subsequently, at 15:26:21, Copthall
cancelled all its latest buy orders (placed at 15:26:14) worth
₹98,11,70,665.40 across 30 Sensex scrips. It appears that the cancellation
was done because an upward move in Sensex closing price had already
taken place. Since the upward move was already caused and carried
Page 16 of 46 forward by Copthall’s initial aggressive buy orders and the subsequent sell
order cancellation by Mansi, Copthall appear to have cancelled the latest
buy orders to prevent additional investments.
**40.**Further, it may be noted that the last set of buy orders at 15:26:14 by
Copthall had increased the Sensex IEP by 66 points only. Since the
additional aggressive buy orders was only increasing the IEP by 66 points,
this could also be the reason for cancellation. This also shows that the buy
orders worth ₹98 Crore of Copthall were with an intent to artificially inflate
the IEP of Sensex.
**41.**Hence, it is prima facie established that such aggressive buy orders by
Copthall had caused a sustained upward move in IEP of SENSEX
constituents and ultimately resulted in SENSEX closing at 78080, whereas,
equivalent move based on Nifty movement would have resulted in SENSEX
closing at 77840. The close of Sensex was 77,966 on August 12, 2026.
Nifty closed on August 13 at -0.16% compared to August 12, 2026. Hence,
the equivalent Sensex value is ~ 77840.
C.4 Drawdown by Mansi (15:21:03 to 15:26:00)
**42.**During the period between 15:21:03 and15:26:00 (~5 minutes) Mansi
placed sell orders at lower prices with the sell order value being ₹145.65
crores and cancelled them between 15:26:02 to 15:26:05. This cancellation
created an immediate surge in SENSEX IEP by 232.96. By using inverse
logic, it can be inferred that the sell orders of Mansi were causing an artificial
suppression of IEP by at least 232.96 points in Sensex.
**43.**It is also observed that during the period, Mansi placed large sell orders at
prices lower than reference prices. Mansi had placed sell orders worth
₹105.04 Crores in scrips of RELIANCE, SBIN, ETERNAL, ICICIBANK, LT,
INFY at prices in the range of -1.5% to -3% of reference price. The details
of sell orders placed by Mansi in CAS are given in the table below.
Page 17 of 46
Table 16
Symbol
Scrip Name
Sum ofOrderQuantity
Ordertime
Sell OrderValue
AverageSellOrderprice
Referenceprice (RP)
Deviationfrom RP
500325
RELIANCE
100000
15:22:38
12,75,00,000
1,275.00
1313.15
-2.91%
500112
SBIN
100000
15:23:17
10,45,00,000
1,045.00
1076.25
-2.90%
543320
ETERNAL
255000
15:21:17
7,90,50,000
310.00
318.1
-2.55%
532174
ICICIBANK
152000
15:22:58
20,90,60,000
1,375.39
1410.35
-2.48%
500510
LT
105000
15:21:03
41,53,00,000
3,955.24
4057.25
-2.51%
500209
INFY
100000
15:23:09
11,50,00,000
1,150.00
1166.5
-1.41%
500114
TITAN
55000
15:24:56
27,59,85,000
5,017.91
5037.65
-0.39%
532454
BHARTIARTL
10000
15:26:51
1,93,40,000
1,934.00
1940.45
-0.33%
500875
ITC
400000
15:21:35
11,08,00,000
277.00
277.3
-0.11%
Total
1277000*
1,45,65,35,000
*Includes 10,000 Bharti Airtel and 2,000 ICICI shares ordered after cancellation.
**44.**Details of sell orders cancelled by Mansi during 15:26:02 to 15:26:05 are
given in the table below.
Table 17
PAN
Symbol
Scrip Name Se
ll Cancellation time
Cancellation Order price
Cancelled Quantity
Cancelled value
AADCM6645D
500112
SBIN
15:26:03
1045
100000
104500000
AADCM6645D
500114
TITAN
15:26:02
5017.75
55000
275985000
AADCM6645D
500209
INFY
15:26:03
1150
100000
115000000
AADCM6645D
500325
RELIANCE
15:26:04
1275
100000
127500000
AADCM6645D
500510
LT
15:26:03
3950
100000
395000000
AADCM6645D
500510
LT
15:26:05
4060
5000
20300000
AADCM6645D
500875
ITC
15:26:03
277
150000
41550000
AADCM6645D
500875
ITC
15:26:04
277
250000
69250000
AADCM6645D
532174
ICICIBANK
15:26:03
1375
50000
68750000
AADCM6645D
532174
ICICIBANK
15:26:04
1375
100000
137500000
AADCM6645D
543320
ETERNAL
15:26:04
310
250000
77500000
AADCM6645D
543320
ETERNAL
15:26:05
310
5000
1550000
Total
1265000
1434385000
**45.**It can be seen from the table above that Mansi cancelled 12,65,000 sell
orders worth ₹143,43,85,000 during the CAS. It has cancelled all the
12,65,000 sell orders placed prior to 15:26:00. This also shows that the sell
orders for 5 minutes were prima facie meant to suppress the IEP rather
than performing a legitimate sell transaction.
**46.**Scrips which showed the maximum upward movement during the time of
cancellation of orders by Mansi were the ones that contributed most to the
Page 18 of 46 suppression of SENSEX IEP. It can be seen in the table below clearly that
the price of the below given 7 scrips was suppressed because of sell orders
of Mansi and upon cancellation of sell orders, they showed a sudden rise
in price.
Table 18
Scrip Name
Sum of % Upward Changeafter sell order cancelledby Mansi
Whether MansiCancelled Order
LT
2.89%
Yes
ETERNAL
1.08%
Yes
ITC
0.90%
Yes
TITAN
0.63%
Yes
INFY
0.50%
Yes
RELIANCE
0.34%
Yes
SBIN
0.27%
Yes
**47.**Hence, it is clearly established that the sell orders by Mansi at lower limits
were causing the suppression of the SENSEX IEP and these sell orders
that were cancelled during 15:26:02 to 15:26:05 prima facie reveals the
intention of Mansi to never legitimately sell these shares but to knowingly
suppress the IEP.
D. OBSERVATIONS ON UNUSUAL TRADING PATTERN OF THE NOTICEES
**48.**As per the economic behavioural science, a participant seeking to purchase
securities would generally seek to purchase at the prevailing market price
or at a price lower than the prevailing market price. In the same way, a
participant seeking to sell securities would ordinarily seek to sell at the
prevailing market price or at a price higher than the prevailing market price.
Such conduct is broadly consistent with the standard economic theory
which states that businesses try to maximise their profits, leading market
forces to natural balance through supply and demand.
**49.**In this regard, the fact that a participant places a buy order at a high price
away from the prevailing reference price/IEP, by itself, would not
Page 19 of 46 necessarily be indicative of any misconduct. However, when participants
repeatedly place large buy orders at prices substantially above the
prevailing reference price/IEP, it warrants an examination of conduct of the
participants. In other case, if a participant places large sell orders at prices
substantially below the prevailing reference price/IEP, particularly when
such orders are subsequently cancelled or such orders have a significant
concentration the trading activity warrants examination as to its intent,
economic rationale and purpose.
**50.**The trading pattern of Copthall placing large buy orders at significantly
higher prices at three times and Mansi placing large sell orders at lower
prices and then subsequently cancelling them is prima facie highly unusual
and needs to be examined with their possible positions in F&O.
**51.**Observations on the trading pattern of Copthall:
a. As a buyer, there does not appear to be any economic rationale for
Copthall to place large buy orders across the Sensex constituents at
prices 3% above the reference price, particularly when the prevailing IEP
was much lower.
b. Buy orders were placed by Copthall across all Sensex constituents
within very short intervals and in 2 instances at the exact same time.
c. The pattern also indicated that Copthall did not intend to acquire the
securities under its last buy order because it cancelled that buy order
aggregating to an amount approx. ₹98.12 crore across 30 Sensex
constituents which was 32.79% of its outstanding buy orders.
d. The placement of buy orders at higher prices prima facie appear to have
been done with an intent to influence upward movement of the IEP of
the underlying securities and, consequently, the Sensex.
e. One economic rationale for such trading could prima facie be that the
F&O position of the entity provided an economic incentive for
engineering such movements in SENSEX IEP and consequently, the
closing price.
Page 20 of 46
**52.**Observations on the trading pattern of Mansi:
a. There does not appear to be any economic rationale for Mansi placing
sell orders aggregating 12.65 lakh shares across eight Sensex
constituents at prices substantially below the reference price. The
aforesaid sell orders of Mansi remained in the system until 15:26:01 and
then subsequently were cancelled across all 8 scrips within short interval
of 4-5 seconds.
b. The placement and cancellation of the sell orders prima facie appear to
have been done with the intent to influence the IEP of the underlying
securities downward and consequently, the Sensex.
c. One economic rationale for such trading could prima facie be that the
F&O position of the entity provided an economic incentive for
engineering such movements in SENSEX IEP until their sell orders
remained in the system.
**53.**The trading pattern of the entities was therefore, examined not merely on
the basis of the individual orders, but also having regard to their size, price,
timing, concentration across constituent securities, effect on the IEP and
subsequent cancellations, as well as the concurrent F&O positions of the
concerned participants.
**54.**On August 13, 2026, the Sensex was scheduled for weekly expiry at BSE.
The reference price of the Sensex at 15:15 was 77,829.60, following which
the CAS commenced at 15:20. During the CAS, three significant price
movements were observed. The following table depicts those price
movements:
Table 19
Price movement
Time
Sensex movement
Change
Spike 1
15:20:41-15:20:43
77,661.40 → 78,023.42
+362.02 points
Spike 2
15:24:08-15:24:20
77,707.84 → 77,840.51
+132.67 points
Page 21 of 46
Price movement
Time
Sensex movement
Change
Spike 3
15:25:49-15:26:17
77,787.94 → 78,193.02
+405.08 points
**55.**The magnitude and extremely short duration of these movements assume
significance when viewed along with the order activity of these entities in
the underlying Sensex constituents.
D.1.1 Activity of Copthall Mauritius Investment Limited
**56.**During the first spike, in a period of merely two seconds, there were 88 buy
orders having an aggregate value of approximately ₹66.64 crore. Copthall
alone accounted for approximately ₹66.58 crore, or 99.91% of the entire
buy order value. All 32 of Copthall's limit buy orders were placed at a price
3% above the reference price and were spread across all Sensex
constituents.
**57.**The pattern was not confined to the first spike. During the second spike
Copthall accounted for approx. ₹126.59 crores or 96.09% of total buy
orders. Similarly, during third spike Copthall accounted for
approximately ₹98.12 crore, or 85.21% of the total buy-order value, with all
32 of its limit buy orders again being placed at a price 3% above the
reference price across all Sensex scrips.
**58.**Further, at 15:26:21, Copthall simultaneously cancelled its latest buy orders
having an aggregate value of approximately ₹98.12 crore across 30
Sensex scrips.
D.1.2 Activity of Mansi Share and Stock Broking Private Limited
**59.**Following the initial upward movement, Mansi placed aggressive sell orders
between 15:21:03 and 15:24:59 across eight Sensex constituents
aggregating 12.65 lakh shares. Of these, approximately 7.05 lakh shares
were placed at a price 2.5% below the reference price, while only 4.6 lakh
shares were within 1% below the reference price.
Page 22 of 46
**60.**The entire quantity of 12.65 lakh shares across the eight scrips was
subsequently cancelled between 15:26:02 and 15:26:05.
**61.**Copthall pushed the IEP of SENSEX higher by placing aggressive buy
orders at +3%. They also contributed to 85% of the gross buy value.
**62.**Mansi pushed the IEP of SENSEX lower for certain time period of ~4 to 5
minutes by placing sell orders at prices much lower than reference price
and this downward pressure by Mansi was released when they cancelled
their sell orders.
**63.**It is pertinent to note that the examination or the evidence does not prima
facie indicate that the entities acted in concert. It is prima facie noted that
both have tried to push the market in directions favourable to them as
discussed in the later sections of this order.
**64.**The role of the two entities is distinguishable from the nature and direction
of their respective order placements.
Table 20
Entity
Principal observed activity
Price placement
Subsequent conduct
Apparent Effect
Copthall Mauritius Investment Limited
Large buy orders across Sensex constituents
+3% of reference price
Partial cancellation
Upward movement in IEP/Sensex
Mansi Share and Stock Broking Private Limited
Large sell orders across 8 Sensex constituents
-1% to -3% of reference price
Cancellation of entire sell block
Downward pressure on IEP/Sensex until cancellation of
**65.**It is observed that the two participants adopted opposite but highly
aggressive price-impacting strategies during the same CAS session.
D.2 F&O position vis-a-vis cash trading pattern
**66.**As discussed earlier, one economic rationale to such behaviour by Noticees
could be their positions in F&O segment, which is discussed as under:
Page 23 of 46
Copthall Mauritius Investment Limited
a. The trading activity of Copthall on major exchanges (NSE and BSE) was
as under:
Table 21
Exchange
Client Name
Gr Buy Value (in ₹)
Gr Sell Value (in ₹)
BSE
COPTHALL MAURITIUS INVESTMENT LIMITED
220,79,71,646
9,82,37,257
NSE
COPTHALL MAURITIUS INVESTMENT LIMITED
1,030,43,18,051
49,69,43,024
Total
12,51,22,89,697
59,51,80,281
b. The F&O position of Copthall for the relevant period shows that they had
certain outstanding expiry-day Sensex option positions that were open
as at 15:20 on August 13, 2026. The outstanding position is given in the
table below:
Table 22
Contract Name
Net BuyQty.
Net SellQty.
Remarks
SENSEX2681377500CE
26560
0
carried forward from previous days
SENSEX2681377500PE
0
26560
carried forward from previous days
SENSEX2681378000CE
84200
0
position built during the day
SENSEX2681378000PE
0
84200
position built during the day
SENSEX2681378500CE
12640
0
carried forward from previous days
SENSEX2681378500PE
0
12640
carried forward from previous days
c. The above table shows that Copthall had net buy call positions and net
sell put positions for each of 77500, 78000, 78500 strike prices of the
expiry day.
d. It may be seen that the payoff of the above strategy is known as the
Synthetic Long Asset Position or Synthetic Factor. Any upward
movement in the Sensex above the strike price would generate unlimited
profit or help avoid significant pay-out to the put buyers for Copthall.
e. Hence, it is seen that the aggressive buy orders of Copthall in SENSEX
constituents were entered with the prima facie intention to keep the index
value at higher level so as to generate prima facie wrongful gains from
the outstanding expiry day option positions.
Page 24 of 46 f. Thus, the cash-market/CAS activity of Copthall cannot be viewed in
isolation from its contemporaneous positions in expiry day Sensex
options. The timing and direction of the underlying trading activity and
the corresponding Sensex Options warrant consideration together.
**67.**Mansi Share and Stock Broking Private Limited
a. The trading activity of Mansi on major exchanges (NSE and BSE) was
as under:
Table 23
Exchange
Client Name
Gr Buy Value (in ₹)
Gr Sell Value (in ₹)
BSE
MANSI SHARE AND STOCK BROKINGPRIVATE LIMITED
274,91,76,408
292,71,29,490
NSE
MANSI SHARE AND STOCK BROKINGPRIVATE LIMITED
657,59,60,746
637,66,63,720
Total
932,51,37,154
930,37,93,209
b. The F&O position of Mansi for the relevant period shows that they had
certain outstanding expiry-day Sensex option positions that were open
as at 15:20 on August 13, 2026. The outstanding position is given in the
table below.
Table 24
Contract Name
Buy Net Qty
Sell Net Qty
Remarks
SENSEX2681377800CE
5000
0
Position built duringthe day
SENSEX2681377800PE
42020
0
Position built duringthe day
SENSEX2681377900PE
83320
0
Position built duringthe day
SENSEX2681378000PE
44000
0
Position built duringthe day
c. The above table shows that other than the 77800 CE, Mansi had open
position of net buy in Put options of 77800 PE, 77900 PE and 78000 PE
for the expiry day August 13, 2026.
d. Any downward movement in the SENSEX would generate wrongful
gains for Mansi.
Page 25 of 46 e. Hence, the aggressive sell orders should be seen as a prima facie
intentional activity by Mansi to suppress the SENSEX IEP and generate
wrongful gains.
f. It is pertinent to note that, during 15:21:03 to 15:26:00 Mansi placed
aggressive sell orders and suppressed the SENSEX IEP and in the
same 5 minutes exited all their outstanding put option positions at a profit
which otherwise would have expired worthless. The summary of the
transactions is given in detail in the subsequent sections of the order.
g. Thus, the cash-market/CAS activity of Mansi cannot be viewed in
isolation from its contemporaneous positions in expiry day Sensex
options. The timing and direction of the underlying trading activity and
the corresponding F&O positions warrant consideration together.
D.3 Consideration of issues and prima facie findings
**68.**At this stage, it is essential to examine if the acts of Noticees are prima facie
in violation of provisions of regulations 3(a), (b), (c), (d), 4(1), 4(2)(a), (b),
(d), (e) and (g) of the SEBI (Prohibition of Fraudulent and Unfair Trade
Practices Relating to Securities Markets) Regulations, 2003 (“PFUTP
Regulations”) and section 12A(a), (b) and (c) of the SEBI Act, 1992. In
case the answer to the above is in affirmative, it is required to be examined
whether facts of the matter warrant an urgent action in exercising powers
bestowed upon SEBI under provisions of sections11 and 11B of the SEBI
Act. The relevant provisions have been reproduced below for reference:
*“*SEBI Act, 1992
Functions of Board.
Section 11
(1) Subject to the provisions of this Act, it shall be the duty of the Board to
protect the interests of investors in securities and to promote the
development of, and to regulate the securities market, by such measures
as it thinks fit
Page 26 of 46
(4) Without prejudice to the provisions contained in sub-sections (1), (2),
(2A) and (3) and section 11B, the Board may, by an order, for reasons to
be recorded in writing, in the interests of investors or securities market, take
any of the following measures, either pending investigation or inquiry or on
completion of such investigation or inquiry, namely: —
(a) suspend the trading of any security in a recognised stock exchange;
(b) restrain persons from accessing the securities market and prohibit
any person associated with securities market to buy, sell or deal in
securities;
(c) suspend any office-bearer of any stock exchange or self-regulatory
organisation from holding such position;
(d) impound and retain the proceeds or securities in respect of any
transaction which is under investigation;
(e) attach, for a period not exceeding ninety days, bank accounts or
other property of any intermediary or any person associated with the
securities market in any manner involved in violation of any of the
provisions of this Act, or the rules or the regulations made thereunder:
Provided that the Board shall, within ninety days of the said attachment,
obtain confirmation of the said attachment from the Special Court,
established under section 26A, having jurisdiction and on such
confirmation, such attachment shall continue during the pendency of
the aforesaid proceedings and on conclusion of the said proceedings,
the provisions of section 28A shall apply:
Provided further that only property, bank account or accounts or any
transaction entered therein, so far as it relates to the proceeds actually
involved in violation of any of the provisions of this Act, or the rules or
the regulations made thereunder shall be allowed to be attached;
(f) direct any intermediary or any person associated with the securities
market in any manner not to dispose of or alienate an asset forming
part of any transaction which is under investigation:
Page 27 of 46
Provided that the Board may, without prejudice to the provisions
contained in sub-section (2) or sub-section (2A), take any of the
measures specified in clause (d) or clause (e) or clause (f), in respect
of any listed public company or a public company (not being
intermediaries referred to in section 12) which intends to get its
securities listed on any recognised stock exchange where the Board
has reasonable grounds to believe that such company has been
indulging in insider trading or fraudulent and unfair trade practices
relating to securities market:
Provided further that the Board shall, either before or after passing such
orders, give an opportunity of hearing to such intermediaries or persons
concerned.
Power to issue directions and levy penalty.
Section 11B
(1) Save as otherwise provided in section 11, if after making or causing to
be made an enquiry, the Board is satisfied that it is necessary, —
(i) in the interest of investors, or orderly development of securities market;
or
(ii) to prevent the affairs of any intermediary or other persons referred to in
section 12 being conducted in a manner detrimental to the interest of
investors or securities market; or
(iii) to secure the proper management of any such intermediary or person,
it may issue such directions, —
(a) to any person or class of persons referred to in section 12, or associated
with the securities market; or
(b) to any company in respect of matters specified in section 11A, as may
be appropriate in the interests of investors in securities and the securities
market.
Explanation. —For the removal of doubts, it is hereby declared that the
power to issue directions under this section shall include and always be
Page 28 of 46
deemed to have been included the power to direct any person, who made
profit or averted loss by indulging in any transaction or activity in
contravention of the provisions of this Act or regulations made thereunder,
to disgorge an amount equivalent to the wrongful gain made or loss averted
by such contravention.
Prohibition of manipulative and deceptive devices, insider trading and
substantial acquisition of securities or control.
Section 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;
Delegation.
Section 19.
The Board may, by general or special order in writing delegate to any
member, officer of the Board or any other person subject to such conditions,
if any, as may be specified in the order, such of its powers and functions
under this Act (except the powers under section 29) as it may deem
necessary.
Page 29 of 46
PFUTP Regulations, 2003
Definitions
Regulation 2
(1)....
(b) “dealing in securities” includes:
(i) an act of buying, selling or subscribing pursuant to any issue of any
security or agreeing to buy, sell or subscribe to any issue of any security
or otherwise transacting in any way in any security by any persons
including as principal, agent, or intermediary referred to in section 12 of
the Act, either by themselves or through mule accounts;
(ii) such acts which may be knowingly designed to influence the
decision of investors in securities; and
(iii) any act of providing assistance to carry out the aforementioned acts.
(c) “fraud” includes any act, expression, omission or concealment
committed whether in a deceitful manner or not by a person or by any
other person with his connivance or by his agent while dealing in
securities in order to induce another person or his agent to deal in
securities, whether or not there is any wrongful gain or avoidance of
any loss, and shall also include—
(1) a knowing misrepresentation of the truth or concealment of material
fact in order that another person may act to his detriment;
(2) a suggestion as to a fact which is not true by one who does not
believe it to be true;
(3) an active concealment of a fact by a person having knowledge or
belief of the fact;
(4) a promise made without any intention of performing it;
(5) a representation made in a reckless and careless manner whether
it be true or false;
(6) any such act or omission as any other law specifically declares to
be fraudulent,
Page 30 of 46
(7) deceptive behavior by a person depriving another of informed
consent or full participation,
(8) a false statement made without reasonable ground for believing it
to be true.
(9) the act of an issuer of securities giving out misinformation that
affects the market price of the security, resulting in investors being
effectively misled even though they did not rely on the statement itself
or anything derived from it other than the market price.
And “fraudulent” shall be construed accordingly;
Prohibition of certain dealings in securities
Regulation 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 d fraud 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.
Prohibition of manipulative, fraudulent and unfair trade practices
Regulation 4
Page 31 of 46
(1) Without prejudice to the provisions of regulation 3, no person shall
indulge in a manipulative, fraudulent or an unfair trade practice in
securities markets.
Explanation.– For the removal of doubts, it is clarified that-
(i)any act of diversion, misutilisation or siphoning off of assets or earnings
of a company whose securities are listed or any concealment of such act
or any device, scheme or artifice to manipulate the books of accounts or
financial statement of such a company that would directly or indirectly
manipulate the price of securities of that company, or
(ii)transactions through mule accounts for indulging in manipulative,
fraudulent and unfair trade practice shall be and shall always be deemed
to have been included in sub-regulation (1).
(2) Dealing in securities shall be deemed to be a manipulative fraudulent or
an unfair trade practice if it involves any of the following:—
(a) knowingly 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;
(d) inducing any person for dealing in any securities for artificially
inflating, depressing, maintaining or causing fluctuation in the price of
securities through any means including by paying, offering or agreeing
to pay or offer any money or money's worth, directly or indirectly, to any
person;
(e) any act or omission amounting to manipulation of the price of a
security including, influencing or manipulating the reference price or
bench mark price of any securities;
Page 32 of 46
(g) entering into a transaction in securities without intention of
performing it or without intention of change of ownership of such
security;
**69.**I note that section 12A(a), (b) and (c) of the SEBI Act, 1992 and
furthermore, regulation 3(a), (b), (c) and (d) of the PFUTP Regulations
inter alia prohibit, buying, selling or otherwise dealing in securities in a
fraudulent manner, employment of any manipulative/deceptive device,
scheme or artifice to defraud in connection with dealing in securities
including in connection with issue, purchase or sale of any securities listed
or proposed to be listed, engaging in any act, practice, course of business
which operates or would operate as fraud or deceit upon any person
in connection with dealing in securities, directly or indirectly.
**70.**Further, regulation 2(1)(c) of the PFUTP Regulations provides an inclusive
and broad definition of the term fraud, which also includes any act or
omission as any other law specifically declares to be fraudulent. I note that
section 12A(a), (b) and (c) of the SEBI Act, 1992 and regulations 3 and 4
of the PFUTP Regulations quoted above, inter alia, prohibit:
i. dealing in securities which is manipulative, fraudulent or an unfair
trade practice;
ii. use of or employment of any manipulative or deceptive device or
contrivance, in contravention of the provisions of the SEBI Act or rules
or regulations made thereunder;
iii. employment of any device scheme or artifice to defraud;
iv. engagement in any act, practice, course of business which
operate/would operate as fraud or deceit upon any person in
contravention of the provisions of the SEBI Act or rules or regulations
made thereunder;
Page 33 of 46 v. knowingly indulging in an act creating false or misleading appearance
of trading in the securities market;
vi. dealing in securities while not intending to effect transfer of beneficial
ownership of securities but to operate only as a device to inflate,
depress or cause fluctuations in price of such security;
vii. inducing any person for dealing in securities for artificially inflating
and/or causing fluctuation in price of security;
viii. any act to manipulate the price of a security which shall include
influencing or manipulating the reference price or bench mark price;
and
ix. entering into transactions in securities with no intention of performing
them.
**71.**In the facts of the present case, I note from the facts and circumstances
highlighted during the preliminary examination by SEBI that the modus
operandi adopted by Noticees was to prima facie involve/employ the use of
large and aggressive buy/sell orders in the underlying constituents of
Sensex during the CAS to influence the IEP/closing price of the Sensex to
enrich themselves with wrongful gains. To achieve an advantageous payoff factor from the positions held by Noticees in the Sensex options expiring
on the same day which is prima facie manipulative in nature.
**72.**In the case of Copthall, large buy orders were placed across the Sensex
constituents at prices materially above the reference price and within short
intervals, resulting in sharp upward movements in the IEP and ultimately
closing at a higher value. At the same time, Copthall had outstanding long
call and short put positions which derived benefits from the prima facie
artificial upward price movement in Sensex constituents engineered by
Copthall.
**73.**In the case of Mansi, it had open positions in expiry day put options at the
start of CAS. The payoff from these put options benefitted from the artificial
Page 34 of 46 suppression of IEP for 5 minutes which was prima facie engineered by
Mansi by placing aggressive sell orders in 8 constituent scrips of Sensex at
significantly lower prices than the reference price. Once the existing
positions in put options were squared off to its advantage, Mansi cancelled
sell orders, clearly showcasing prima facie that the intent of placing sell
orders was prima facie not bonafide but to artificially suppress the IEP and
benefit from their outstanding put options position.
**74.**The aforesaid sequence, when considered together with the F&O positions
of Noticees, prima facie indicates that the underlying cash-market activity
was not undertaken as an independent trading strategy but had a direct
economic relevance to the Noticees positions in Sensex options.
**75.**It is not prima facie being alleged that Noticees acted in concert. However,
the material available on record highlights that each of the Noticees tried to
create a favourable move for themselves in the Sensex constituents to
enrich themselves with wrongful gains in their expiry day Sensex Option
positions.
**76.**The preliminary findings show that the activity of Noticees in the underlying
securities during the CAS had a corresponding impact on their expiry-day
Sensex option positions. These large buy orders and large sell orders which
were placed and then cancelled, allowed Noticees to avoid losses or
wrongfully profit themselves from positions in derivatives trades that
otherwise would have expired worthless.
**77.**The economic linkage may therefore be represented as follows:
Figure 2 Modus Operandi of Noticee No.1
Large / aggressive orders in Sensex
constituent securities
Change in IEP of Sensex constituents
│
Page 35 of 46
▼
Consequent movement in IEP of Sensex
│
▼
Sensex closing at a higher value
│
▼
Change in expiry value of
Sensex option positions / Squaring off Sensex option positions
│
▼
Additional F&O profit /
avoidance of F&O loss
**78.**In case of the *Noticee No.*2, modus operandi was to benefit from temporary
dip by squaring off position in options.
D.4 Calculation of Wrongful gains
D.4.1 Calculation of Wrongful gains of Copthall Mauritius Investment Limited:
**79.**Upon perusal of the trade and order log at BSE, it is observed that on
August 13, 2026 at 15:20 the number of outstanding contracts in Sensex
Options expiring on August 13, 2026 for Copthall were as follows:
Table 25
Contract Name
Net BuyQty.
Net SellQty.
Remarks
SENSEX2681377500CE
26560
0
carried forward from previous days
SENSEX2681377500PE
0
26560
carried forward from previous days
SENSEX2681378000CE
84200
0
position built during the day
SENSEX2681378000PE
0
84200
position built during the day
SENSEX2681378500CE
12640
0
carried forward from previous days
SENSEX2681378500PE
0
12640
carried forward from previous days
**80.**The calculation of wrongful gains for the entity Copthall entails the
consideration of additional profit generated from affecting the closing price
of Sensex and the additional payments avoided, which would otherwise
have been payable to buyers of the put options because of the Sensex
ending higher and put options expiring worthless. For the purpose of
calculation of the wrongful gains it is reasonable to consider the fair
Page 36 of 46 settlement price of Sensex based on Nifty 50 closing value as 77840. The
close of Sensex was 77,966 on August 12, 2026 which is achieved through
prima facie manipulation as discussed earlier. Nifty closed on August 13 at
-0.16% compared to August 12, 2026. Hence, the equivalent Sensex value
is ~ 77840.
Table 26
Wrongful gains to Copthall - August 13, 2026 - Expiry day
Contract Name
NetBuyQty.
NetSellQty.
Strike
SensexEndingas perNiftylevels
Payofffor
Sensexactual
Payofffor
Unlawfulgain Pay
WrongfulPay-outAvoidanceper Qty. byCopthall
TotalWrongfulgains orlossavoided (in₹)
Contract Name
NetBuyQty.
NetSellQty.
Strike
SensexEndingas perNiftylevels
optionbuyerSensexat 77840
Ending
optionbuyerSensexat 78080
Off perQty. forCopthall
WrongfulPay-outAvoidanceper Qty. byCopthall
TotalWrongfulgains orlossavoided (in₹)
SENSEX2681377500CE
26560
0
77500
77840
340
78080
580
240
0
63,74,400
SENSEX2681377500PE
0
26560
77500
77840
0
78080
0
0
0
-
SENSEX2681378000CE
84200
0
78000
77840
0
78080
80
80
0
67,36,000
SENSEX2681378000PE
0
84200
78000
77840
160
78080
0
0
160
1,34,72,000
SENSEX2681378500CE
12640
0
78500
77840
0
78080
0
0
0
-
SENSEX2681378500PE
0
12640
78500
77840
660
78080
420
0
240
30,33,600
Total
2,96,16,000
**81.**The detailed calculation of wrongful gains for each outstanding expiry day
contract of Copthall, is as follows:
a. SENSEX2681377500CE: If the Sensex had a closing value of 77840 the
pay-off for Copthall would have been 340*26560= ₹90,30,400. But the
Sensex closed at 78080 because of buying pressure by Copthall and the
actual pay-off is ₹1,54,04,800. The wrongful gains are ₹63,74,400.
b. SENSEX2681377500PE: This option was deep out of the money and it
doesn’t make a difference whether Sensex Expires at 77840 or 78080.
Hence, no wrongful gain is attributed here.
c. SENSEX2681378000CE: If the Sensex had a closing value of 77840 the
pay-off for Copthall would have been 0 because the call option would
Page 37 of 46 have expired worthless. But the Sensex closed at 78080 because of
buying pressure by Copthall and the actual pay-off is 80*84200=
₹67,36,000. The wrongful gains are ₹67,36,000.
d. SENSEX2681378000PE: If the Sensex had a closing value of 77840 the
buyer of the put option would have a pay-off of 160*84200=
₹1,34,72,000 and Copthall would have had to pay the same to the buyer
of the option. But the Sensex closed at 78080 because of buying
pressure by Copthall and the put option expired worthless and because
of which Copthall did not have to make any pay out. Hence, they avoided
loss (avoiding paying the option buyer) of ₹1,34,72,000.
e. SENSEX2681378500CE: This option was deep out of the money and it
doesn’t make a difference whether Sensex Expires at 77840 or 78080.
Hence, no wrongful gains are attributed here.
f. SENSEX2681378500PE: If the Sensex had a closing value of 77840
then Copthall would have had to make a pay-out of 66012640=
₹83,42,400. But the Sensex closed at 78080 because of buying pressure
by Copthall and the actual pay-out they made is 42012640=
₹53,08,800. The wrongful gains are ₹30,33,600.
**82.**The Sensex closed at 78080 and the unlawful gain made by Copthall is
₹2.9616 Crores. While Copthall incurred a nominal price variance of ₹57
Lakhs in the cash segment, this represented a deliberate expenditure to
manufacture a terminal index level benefit that generated an asymmetric,
irreversible wrongful gain of ₹2.9616 Crores in the derivatives segment,
which prima facie could not have been feasible without these prima facie
manipulative transactions as detailed above in the order.
D.4.2 Calculation of Wrongful gains of Mansi Share and Stock Broking Private Limited
**83.**Upon perusal of the trade and order logs it is observed that on August 13,
2026 at 15:20 the number of outstanding contracts in Sensex Options
expiring on August 13, 2026 for Mansi is as follows:
Page 38 of 46
Table 27
Contract Name
Buy Netquantity
Sell Netquantity
Remarks
SENSEX2681377800CE
5000
0
Position built during theday
SENSEX2681377800PE
32000
0
Position built during theday
SENSEX2681377900PE
75460
0
Position built during theday
SENSEX2681378000PE
32000
0
Position built during theday
**84.**Unlike in the case of Copthall which had made wrongful gains through
settlement prices, Mansi was observed to have placed aggressive sell
orders in certain constituents of Sensex at prices lower than the reference
price for suppressing the IEP. During this period of artificial suppression of
IEP, Mansi exited the put options of 77800, 77900 and 78000 strikes at
certain values before they expired worthless when Sensex closed at 78080.
However, even during the period from 15:21 to 15:26 Mansi was observed
to have purchased more put options and squared them off along with the
outstanding contracts as on 15:20. Accordingly, the wrongful gains of Mansi
is given in the tables below.
**85.**Wrongful gains from squaring off of the outstanding contracts are shown in
the table below:
Table 28
Contract Name
Quantity ofoutstandingsold
Averagevalue ofsell
Value ofSell
Actualendingvalue ofoption
WrongfulGain
SENSEX2681377800CE
5000
-
-
-
-
SENSEX2681377800PE
32000
16.39
5,24,480
0
5,24,480
Page 39 of 46
SENSEX2681377900PE
75460
42.05
31,73,093
0
31,73,093
SENSEX2681378000PE
32000
108.35
34,67,200
0
34,67,200
Total
71,64,773
Total
71,64,773
Table 29
**86.**It may be noted that after the cancellation of sell orders by Mansi, the above
put options would have expired worthless. Had the sell orders of Mansi at
lower than reference price in Sensex constituents not been there to
artificially suppress the IEP, Mansi would not have been able to sell the put
options at prices as mentioned above. Hence, the entire sale value may
prima facie be considered as wrongful gains.
**87.**As discussed above, Mansi also purchased put options during 15:21 to
15:26. Squared-off difference made from additional purchase and sale of
expiry day puts during 15:21 to 15:26 by Mansi is as under:
Table 30
ContractName
ExtraBuy NetQty.
ExtraSell NetQty.
Averagebuy price(in ₹)
Averagesell price(in ₹)
Square-offdifference(in ₹)
SENSEX2681377800PE
25980
25980
32.48
16.39
-4,18,018
SENSEX2681377900PE
9360
9360
73.81
42.05
-2,97,274
**88.**Other than the outstanding positions as at 15:20, during 15:21 to 15:26
Mansi further purchased and sold put options as shown in table above and
had a negative square-off difference of ₹7,15,292. However, considering
Page 40 of 46 that Mansi dealt in these contracts while prima facie manipulating the
underlying, the wrongful gains made by Mansi in Sensex options is prima
facie considered to be ₹71,64,773 without adding the negative square-off
difference.
**89.**As of August 17, 2026, Mansi had net outstanding position in index options
and futures.
**90.**Accordingly, the total wrongful gains made by both Noticees can be
summarised as follows:
Table 31
Entity Name
Entity PAN
Wrongful gains (in ₹)
Copthall Mauritius Investment Limited
AAACC4303M
2,96,16,000
Mansi Share and Stock Broking Private Limited
AADCM6645D
71,64,773
E. Need for Interim Order
**91.**It is to be seen that the CAS is a mechanism for determining the closing
price of securities through the interaction of orders submitted by the market
participants. The integrity of such price discovery is fundamental to the fair
and orderly functioning of the securities market and for maintaining the ideal
price equilibrium in the securities. The price so discovered in CAS is used
for settlement of option contracts, Mutual Fund Net Asset Value (“NAV”)
determination, etc.
**92.**In the present matter, three sharp movements in the Sensex during the CAS
on August 13, 2026, including movements of 362.02 points, 132.67 points
and 405.08 points within periods ranging from two seconds to 28 seconds
were recorded. The order log further shows substantial concentration of the
relevant orders two participants, including Copthall accounting for 99.91%
and 96.09% of the buy-order value during the first two-second spike and
85.21% during another relevant period.
Page 41 of 46
**93.**Any manipulation or unfair practices employed to disturb the fair discovery
of prices in CAS has to be dealt with sternly by the regulator. Such conduct,
if permitted to continue or replicated by other participants in the securities
markets, has the potential to undermine the integrity of the CAS
mechanism, affect the fair discovery of price through such mechanism and
moreover, completely disrupt the orderly functioning of the securities
markets. It is imperative to note that such manipulative practices have huge
ramifications on participants who trade in F&O segments including retail
investors.
**94.**With the introduction of CAS, volatility and manipulation is expected to
reduce, as the system is more efficient and transparent. The design of CAS
is such that it provides SEBI with greater ability to identify manipulation as
compared to earlier VWAP system.
**95.**Such conduct, particularly when undertaken prima facie with a malafide
intention to manipulate the payoff from the outstanding Sensex options of
expiry-day, presents a serious concern from the perspective of market
integrity and fair price discovery and undermines the functioning of the
securities markets. It is also unfair to other investors who invest in mutual
funds and take positions in options based on trust.
**96.**The need for immediate and urgent directions is further strengthened by the
fact that Noticees are found to have created outstanding positions in the
coming weekly Sensex options on August 20, 2026. In such circumstances,
allowing Noticees to continue participating in the CAS, pending completion
of further examination by SEBI in the matter, may expose the securities
markets to the risk of recurrence of blatant misconduct observed in the
present case.
**97.**Immediate interim directions are necessitated in the interest of maintaining
the integrity of the securities market, fair price discovery and preventing
Page 42 of 46 further possible misuse of the CAS mechanism in the securities markets by
entities adopting manipulative practices.
F. DIRECTIONS
98. In view the aforesaid discussions surrounding the misconduct of Noticees
and after analysing prima facie evidence available on record about the
violations committed by Noticees, I hold that this is a fit case to exercise
powers of passing an interim order, pending further examination, so as to
insulate the securities market and to protect the wrongful gains made by
Noticees from being siphoned off, which may go beyond the regulatory
reach. Accordingly, I, in exercise of powers conferred upon me under
sections 11(1), 11(4) and 11B(1) read with section 19 of the SEBI Act,
hereby, by way of the present ex-parte interim order, issue the following
directions, which shall remain in force until further orders:
i. The bank accounts of *Noticee Nos.*1 and 2 are impounded to the
extent of amount as mentioned below, and they are directed to
open fixed deposit account(s) in their names so as to credit or
deposit the aforesaid impounding amount as per the following
table with a lien marked in favour of SEBI and the amount kept
therein shall not be released without permission from SEBI;
Table 32
Entity
Amount (in ₹)
Copthall Mauritius Investment Limited
2,96,16,000
Mansi Share and Stock Broking Private Limited
71,64,773
Total
3,67,80,773
ii. Noticee Nos. 1 and 2 shall be restrained from accessing the
securities markets (In case of the Noticee No. 2, this direction
applies to its proprietary trading account only);
iii. Noticee Nos. 1 and 2 are further prohibited from participating in
the Call Auction Session (CAS) in the equity segment, whether
Page 43 of 46 directly or indirectly, including by placing, modifying or cancelling
orders during the CAS, until further orders (In case of the Noticee
No. 2, this direction applies to its proprietary trading account only);
iv. Banks, where Noticees are holding bank accounts, are directed
that no debits shall be made, without permission of SEBI, in
respect of the bank accounts held by Noticees, except for the
purposes of transfer of funds to the fixed deposit account(s) as
stipulated above. Further, this direction shall not apply to those
bank accounts of Noticee No. 2 which deal with clients’ funds,
since Noticee No. 2 is a stock broker registered with SEBI and
deals with funds of clients;
v. Depositories shall also be directed that no debit shall be made,
without permission of SEBI, in respect of the demat accounts held
by Noticees (In case of the Noticee No. 2 this direction applies to
its proprietary account). However, credits, if any, into the
accounts may be allowed;
vi. Banks and the Depositories are directed to ensure that all the
aforesaid directions are strictly enforced. Further, debits in the
bank accounts may also be allowed for amounts available in the
account in excess of the amount to be impounded. Banks are
allowed to debit the accounts for the purpose of complying with
this Order;
vii. The Registrar and Transfer Agents shall ensure that, they neither
permit any transfer nor redemption of securities, including Mutual
Funds units, held by Noticees;
viii. Noticees shall not dispose of or alienate any of their
assets/properties, except with the prior permission of SEBI;
ix. Noticees are further directed to provide a full inventory of all their
assets whether movable or immovable, or any interest or
investment or charge in any of such assets, including property,
details of all their bank accounts, demat accounts, holdings of
Page 44 of 46 shares/securities if held in physical form and mutual fund
investments and details of companies in which they hold
substantial or controlling interest immediately but not later than
15 days of this Order;
x. The directions stipulated in clauses (ii), (iv), (v), (vi), (vii) and (viii)
shall cease to apply upon crediting of the impounding amount as
per clause (i);
xi. If Noticees have any open position in any exchange traded
derivative contracts, as on the date of the order, they can close
out/square off such open positions within 3 months from the date
of order or at the expiry of such contracts, whichever is earlier.
The Noticees are permitted to settle the pay-in and pay-out
obligations in respect of transactions, if any, which have taken
place before the close of trading hours on the date of this order.
Banks are allowed to debit the accounts for the purpose of
complying with this direction.
xii. Noticees are directed to co-operate with SEBI during the
examination/investigation in the instant matter.
99. A detailed investigation/examination by SEBI is required to be done in the
instant matter, with respect to violations committed by Noticees and other
suspects. The same may be completed expeditiously without being
influenced by the prima facie findings in this order.
**100.**The foregoing prima facie observations contained in this Ex-Parte Interim
Order are made on the basis of the material available on record. The
Noticees may, within 21 days from the date of receipt of this Order, file
their reply/objections, if any, to this Order and may also indicate whether
they desire to avail an opportunity of personal hearing on a date and time
to be fixed in that regard.
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**101.**This order is without prejudice to the rights of SEBI to take any other action
that may be initiated against Noticees in accordance with law, including
but not limited to levy of penalty and issuance of directions. This order is
further without prejudice to the rights of SEBI to take any action against
other persons/entities, not made Noticees in this order.
**102.**A copy of this order shall be served upon the Noticees, Exchanges,
Depositories, RTAs and Banks for necessary action and compliance with
the above directions.
**103.**The concerned stock exchange(s) and market intermediaries shall take
necessary steps to give effect to the aforesaid directions.
**104.**The aforesaid restriction shall apply to any trading account or arrangement
through which either of the aforesaid entities may seek to circumvent the
direction contained herein.
PLACE: MUMBAI
KAMLESH CHANDRA VARSHNEY
DATE: AUGUST 19, 2026
Digitally signed by KAMLESH
CHANDRA VARSHNEY
Date: 2026.08.19 19:18:27 +05'30'
KAMLESH CHANDRA VARSHNEY
WHOLE TIME MEMBER
SECURITIES AND EXCHANGE BOARD OF INDIA
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