BEFORE THE ADJUDICATING OFFICER

SECURITIES AND EXCHANGE BOARD OF INDIA

[ADJUDICATION ORDER NO.EAD-5/SVKM/RGA/AO/ 20 /2015-16]
________________________________________________
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 BY ADJUDICATING OFFICER) RULES, 1995
In respect of
Vishal Vijay Shah
SEBI Registration No. INB011277614
PAN No. BBJPS3622P
In the matter of M/s Maharashtra Polybutenes Limited

FACTS
1. Securities and Exchange Board of India (hereinafter referred to
as SEBI) conducted investigation into the alleged irregularities
in the trading in the shares of Maharashtra Polybutenes Ltd.
(hereinafter referred to as 'MPL') from February, 2009 to July,
2009 (hereinafter referred to as relevant period) and into the
possible violation of the provisions of the Securities and

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Exchange Board of India Act, 1992 (hereinafter referred to as

'SEBI Act, 1992') and Regulations made thereunder. It was
observed that during the relevant period, there was sudden spurt
in the volumes traded and price of the scrip without any
significant change in the economic fundamentals of the company.
A total of 53,51,932 shares were traded and the price increased
from ` 53.35 to ` 79.95 during the relevant period.
2. It was observed that Vishal Vijay Shah (hereinafter referred to as
'Noticee') traded for three clients, namely Vipul Bhagwandas
Shah, R. Raghavan and Kamlesh Lalitkumar Nagarsheth and
executed large scale manipulative transactions in the scrip that
created false or misleading appearance of trading. During the
course of investigation, Noticee was issued:
i.

summons dated January 17, 2011, January 28, 2011

under section 11C(2), (3),(6) of the SEBI Act, 1992
requiring the Noticee to personally appear and furnish the
following information/documents as mentioned in the
Annexure to the summons, before the Investigating
Authority (IA):
i. Trade details of MPL for the relevant period
ii. Copy of contract notes issued to the clients during
the relevant period
iii.

All De-mat transaction statement of Noticee for the

relevant period

iv. All bank statements of Vishal Vijay Shah for the

relevant period

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v.

Details with regard to the trades

vi.

Details

such

as

correspondence

address,

permanent address, PAN No., e-mail, Phone

Number., etc.
vii. Copy of Income tax return filed for Financial Year
2008-09& 2009-10.
ii.

summons dated June 13, 2011, July 14, 2011 under

section 11C(2), (3),(6) of the SEBI Act, 1992 requiring
Noticee to furnish the following information/documents as
mentioned in the Annexure to the summons, before the
Investigating Authority (IA) :
i.

Complete set of KYC documents of all the clients

who dealt in the scrip of MPL.

ii.

Client ledger of the clients who dealt in the scrip of

MPL.

iii.

Copy of contract notes issued to the clients who

dealt in the scrip.

iv.

Details of payments made/received by the Noticee

to clients namely Kamlesh Lalitkumar Nagarsheth,
Vipul Bhagwandas Shah and R Raghavan.

v.

Details of Compliant received during the period

from January 2008-March 2010.

vi.

Soft copy of quarterly statements of funds and

securities sent during January 2008-March 2010 for
the abovementioned clients.

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vii.

List of instances where the client code was modified

at back office after the market hours.

viii.

Client master with all client details such as name,

code, address, telephone number, e-mail, de-mat
statement, bank details, etc.

ix.

List and details of branches and sub-broker offices.

x.

List of employees since 2008.

xi.

Listofgroup/subsidiarycompanies/associates/proprie
torship, etc and their director details.

xii.
iii.

Details with regard to proprietary trades.

summons dated September 22, 2011

under section

11C(2), (3),(6) of the SEBI Act, 1992 as a reminder for all

earlier

summons

requiring

Noticee

to

furnish

the

unfurnished information/documents as mentioned in the

Annexure

to

the

previous

summons,

before

the

Investigating Authority (IA).

3. It was observed that Noticee did not furnish complete information

as required under the summons dated January 17, 2011, January
28, 2011, June 13, 2011, July 14, 2011 and September 22, 2011.
Therefore, it was alleged that the Noticee violated the provisions
of section 11C(2), 11C(3) and 11C(6) of the SEBI Act, 1992.
APPOINTMENT OF ADJUDICATING OFFICER
4. Vide order dated July 22, 2013, appointed Shri Piyoosh Gupta as
the Adjudicating Officer. Consequent to the transfer of Shri
Piyoosh Gupta, Shri A. Sunil Kumar was appointed as
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Adjudicating Officer vide order dated November 08, 2013.

Pursuant to the transfer of Shri A. Sunil Kumar, the undersigned
has been appointed as Adjudicating Officer vide order dated June
22, 2015 to inquire and adjudge under sections 15A(a) of the
SEBI Act, 1992 the violations specified in the SCN.
SHOW CAUSE NOTICE, REPLY AND PERSONAL HEARING
5. Show Cause Notice no. ASK/RGA/25497/2014 dated August 28,
2014 (hereinafter referred to as 'SCN') was issued to the noticee
in terms of Rule 4 of SEBI (Procedure for Holding Inquiry and
Imposing Penalties by Adjudicating Officer) Rules, 1995 read with
section 15I of SEBI Act, 1992 to show cause as to why an inquiry
should not be initiated and penalty be not imposed under section
15A(a) of SEBI Act, 1992 for the violations specified in the SCN.
The copies of the documents relied upon in the SCN were
provided to the Noticee along with the SCN. Noticee vide letter
dated October 01, 2014 requested for time for filing reply to the
SCN. Vide notice dated January 02, 2015, an opportunity of
personal hearing was granted to the Noticee on January 28,
2015. The hearing notice was received and acknowledged by the
Noticee. On January 20, 2015, Noticee requested for additional
time for filing reply to the SCN. Vide letter dated March 05, 2015
Noticee submitted reply to the SCN. The salient points of
submissions of the Noticee are as under:

All necessary documents were furnished and the nonsubmissions of documents has not at any point of time
hampered the investigation.

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Vide summons dated January 17, 2011, I was required to

appear personally on January 20, 2011 alongwith certain
information/documents. Since, I was out of town, it was not
possible for providing the required information and thus
non-appearance should not be treated as non-compliance.

Vide summons dated January 28, 2011, I was required to

appear personally on January 31, 2011 alongwith
documents/information as sought by the earlier summons
dated January 17, 2011. I had duly appeared before the
Investigating Authority, however, was not able to submit
the information/documents. Vide February 09, 2011,
submitted

certain

information/documents

before

the

Investigating Authority and stated that the pending

documents shall be submitted within 3-4 days.

Fresh summons dated June 13, 2011 was issued

to

submit a new set of documents/information before SEBI

on June 20, 2011. I was not able to respond to the said
summons

and

thus

no

documents/information

was

submitted before SEBI on June 20,2011.

Another summons was issued by SEBI on July 14, 2011

to

submit

the

documents/information

sought

vide

summons dated June 13, 2011.Vide letter dated July 18,

2011, I had requested for 15 days time to submit the
documents/information since it pertained to the year 2009.
Thereafter vide letter dated August 08, 2011, I had duly
submitted limited information/document which could be

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collated from the past records and retrieved from the

software.

Another summons was issued on September 22, 2011,

wherein it was observed that I had failed to submit
documents/information as sought by SEBI vide its earlier
summons and was required to submit the details by
October 03, 2011. I was also informed that annexures to
the letter submitted by me on August 08, 2011 were not
found. I had requested time till October 05, 2011 for
submission of documents.

Each time I had co-operated with the Investigation

Department and submitted all the documents/information
which were available with me and had made my utmost
attempt to submit the required documents.

None of the details which were not provided by me would

have hampered the investigation in the matter.

Most of the information sought from me was available with

other entities such as banks, DP and the client
themselves. Since I was unable to submit the requisite
information due to various extraneous reasons , I assume
that Investigating Authority would have obtained such
information from these entities and was under a genuine
impression that the investigation in the matter was over.

6. Thereafter, Noticee was given another opportunity of personal

hearing on March 25, 2015 vide notice dated March 09, 2015.
Noticee vide letter dated March 23, 2015 sought adjournment.

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Again vide notice dated June 22, 2015 another opportunity of

hearing was granted to the Noticee on June 29, 2015. Noticee
vide letter dated June 25, 2015 again sought adjournment.
7. In view of the aforesaid , ample opportunities have been given to
the Noticee to defend his case. As per Rule 4(7) of the Rules, if
any person fails, neglects or refuses to appear as required by
sub-rule (3) before the Adjudicating Officer, he may proceed with
the inquiry in the absence of such person after recording the
reasons therefor. Despite having been given ample opportunities,
the Noticee has failed to avail of the opportunity of personal
hearing. I am, therefore, proceeding with the matter based on
documents on record.
CONSIDERATION OF ISSUES AND FINDINGS

8. The issues that arise for consideration in the present case are :
a. Whether Noticee violated the provisions of section 11C(2), (3)
and(6) of SEBI Act, 1992?
b. Does the violation, if any, attract monetary penalty under
section 15A (a) of SEBI Act, 1992?
c. If so, what would be the monetary penalty that can be imposed
taking into consideration the factors mentioned in section 15J of
SEBI Act, 1992?

9. It would be appropriate here to refer to the aforesaid provisions of

the SEBI Act, 1992 which reads as under:

SEBI Act, 1992

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Section 11
Investigation
(1)..........................................................................
(2)Without prejudice to the provisions of sections 235 to 241 of the
Companies Act, 1956, it shall be the duty of every manager, managing
director, officer and other employee of the company and every
intermediary referred to in section 12 or every person associated with
the securities market to preserve and to produce to the Investigating
Authority or any person authorised by it in this behalf, all the books,
registers, other documents and record of, or relating to, the company
or, as the case may be, of or relating to, the intermediary or such
person, which are in their custody or power.
(3) The Investigating Authority may require any intermediary or any
person associated with securities market in any manner to furnish such
information to, or produce such books, or registers, or other
documents, or record before him or any person authorised by it in this
behalf as it may consider necessary if the furnishing of such
information or the production of such books, or registers, or other
documents, or record is relevant or necessary for the purposes of its
investigation.
(6) If any person fails without reasonable cause or refuses
(a) to produce to the Investigating Authority or any person authorised
by it in this behalf any book, register, other document and record which
is his duty under sub-section (2) or sub-section (3) to produce; or
(b) to furnish any information which is his duty under sub-section (3) to
furnish; or
(c) to appear before the Investigating Authority personally when
required to do so under sub-section (5) or to answer any question
which is put to him by the Investigating

Authority in pursuance of that

sub-section; or
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(d) to sign the notes of any examination referred to in sub-section (7),

he shall be punishable with imprisonment for a term which may extend
to one year, or with fine, which may extend to one crore rupees, or with
both, and also with a further fine which may extend to five lakh rupees
for every day after the first during which the failure or refusal continues.

10. The details of the summons issued, information sought, proof of

delivery, status thereof, etc., from the material available on record
are as under:
S.N

Delivered

Replied

1.

Summon
dated
17-Jan-2011

Yes

Jan 19, 2011 - sought for

fresh date.

2.

28-Jan-2011

Yes

Representative
appeared on Jan 31,
2011
Feb 09, 2011

3.

13-Jun-2011

Yes

No

4.

14-Jul-2011

Yes

Sought 15 days time

5.

22-Sep-2011

Yes

Submitted a letter dated

Aug 08, 2011 stating that
he has enclosed certain
documents.
However,
other than the letter no
other
details
were
enclosed.
Letter dated Sep 27,
2011 postponement of
hearing.

Details of data
submitted
Nil

Nil

Point 1 & 5 of
Annexure dated
Jan 17, 2011.
Nil

Nil

Pending details
As per Annexure to
the summon dated
Jan 17, 2011
As per Annexure to
the summon Jan 17,
2011
Pont 2,3,4,6 &

Annexure to the
reminder letter dated
Jan 28, 2011
Annexure to the
summon dated July
14, 2011
Annexure to the
summon dated July
14, 2011

Reminder
dated Jan
2011

Annexure to the
reminder letter dated
Sep 22, 2011

Reminder for all

the summons

11. From the above, it is clear that Noticee was issued summons
dated January 17, 2011 under section 11C(2), 11C(3) and 11C(6)
of the SEBI Act, 1992

to appear personally before the

Investigating Authority and to furnish documents/information as

mentioned in the Annexure to the summons. Noticee vide letter

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Remarks

28,

dated January 19, 2011, sought time for fresh date. No

documents/information were submitted. Noticee was issued
another summons dated January 28, 2011, under section 11C(2),
11C(3) and 11C(6) of the SEBI Act, 1992
before

the

Investigating

documents/information

Authority

to appear personally
and

to

furnish

as mentioned in the Annexure to the

summons. In response to the aforesaid summons, on January

31,

2011,

Noticee's

representative

appeared

before

the

Investigating Authority, however, no documents/information was

submitted by the Noticee. Vide letter dated February 09, 2011,
Noticee submitted only part details of the total information sought
vide summons dated January 17, 2011, like trade details of MPL
for the period of February 2009 to July 2009. The Noticee did not
submit the following information sought vide summons dated
January 17, 2011: copy of contract notes issued by the Noticee to
his clients for the relevant period, De-mat statements and Bank
statements of the Noticee for the relevant period. Noticee was
further issued summons dated June 13, 2011, under section
11C(2), 11C(3) and 11C(6) of the SEBI Act, 1992

to furnish

documents/information as mentioned in the Annexure to the

summons. Noticee did not respond to the summons dated June
13, 2011. Noticee was further issued summons dated July 14,
2011 under section 11C(2), 11C(3) and 11C(6) of the SEBI Act,
1992

to furnish documents/information

as mentioned in the

Annexure to the summons. In response to summons dated July

14, 2011, Noticee sought 15 days time for furnishing information.
Vide letter dated August 08, 2011 Noticee stated that it has
enclosed documents/information alongwith the letter, however,
other than the letter no other details were enclosed. The Noticee
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had failed to submit the information sought by the Noticee vide

summons dated June 13, 2011 and July 14, 2011 i.e. KYC of all
clients in the scrip of MPL, client ledger of the clients who dealt in
the scrip of MPL, contract notes issued to the clients, details of
payments made and received by the Noticee to the client, copy of
quarterly statements of funds and securities sent during the
period January 2008 to March 2010, etc. Another summons was
issued to the Noticee on September 22, 2011 under section
11C(2), 11C(3) and 11C(6) of the SEBI Act, 1992 as a reminder
for furnishing the information as mentioned in the Annexure to the
earlier summons. Vide letter dated September 27, 2011, Noticee
sought time for a fresh date. Noticee did not respond to the
aforesaid summons. I note that all the aforementioned summons
were delivered to the Noticee. However, only part information
was provided by the Noticee in response to the aforesaid five (5)
summons. I note that Noticee in his reply dated March 05, 2015
has admitted that full and complete information as sought by the
aforesaid five (5) summons was not provided to SEBI by the
Noticee during the course of investigation.

12. However, the Noticee has contended that it is not shown that as
to how the investigation was hampered or adversely affected or
delayed in the absence of these documents. It is pertinent to
mention here that any non compliance of the summons of the
Investigating Authority hampers the process of investigation.
Even when Investigating Authority asks a person to appear
before him, the sole purpose is to collect information and to seek
answers/clarifications. It is the statutory duty of

a person to

appear before the Investigating Authority and to answer the

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queries. It is well established that timely submission of

information is very important for the purpose of effective
investigation proceedings and non-cooperation by an entity can
delay or hinder the investigation.

13. The contention of the Noticee that most of the information sought
from him was available with other entities such as banks, DP and
the clients themselves cannot be accepted as Noticee was
summoned in the capacity of a broker and it was his duty to cooperate with the IA and submit full and complete information and
also personally appear before the Investigating Authority. That
the Investigating Authority could have collected the requisite
information from some other source cannot be a ground for nonsubmission of information by the Noticee. The Noticee cannot
adopt a stand :"Don't ask me but look elsewhere" towards the
Investigating Authority. It is not only the information, documents
and records that is required to be produced by the Noticee to the
Investigating Authority when demanded, his presence would be
required to answer the questions that the Investigating Authority
might have.
14. The Honble Securities Appellate Tribunal (SAT) has also
recognized the importance of compliance of summons and
personal appearance and in the matter of DKG Buildcon Pvt. Ltd.
v. SEBI (Appeal No. 106 of 2006, Date of Decision: 07.01.2009), it
has held:By not responding to the summons, the representative(s) of
the appellant did not appear before the investigating officer as a result
whereof their statements could not be recorded. This, obviously,
hampered the investigations. In the result, the inescapable conclusion is
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that the appellants were adamant in not furnishing the information

sought from them though vital to the investigations and that they
stonewalled the investigations as commented by the adjudicating
officer. It is of utmost importance that every person from whom
information is sought should fully co-operate with the investigating
officer and promptly produce all documents, records, information as
may be necessary for the investigations. If persons are allowed to flout
the summons issued to them during the course of the investigations,
the Board as the watchdog of the securities market will not be able to
perform its duties in protecting the interests of the investors and
safeguarding the integrity of the securities market.

15. In this context, I would like to also refer to the order of the Hon'ble
SAT in the matter of Mr. Jalaj Batra vs. SEBI (Appeal no. 184 of
2010, dated December 06, 2010) wherein it observed "......We
have observed time and again that it is of utmost importance that
market players like the appellant should fully cooperate with the
investigations that are carried out by the Board, the watchdog of the
securities market. If market players and intermediaries avoid appearing
before the investigating officer or furnish the necessary information
sought from them, the Board as a market regulator will not be able to
carry out its statutory functions and duties of protecting the integrity of
the securities market and the investigations would be grossly hampered.
Non co-operation with the market regulator has to be viewed seriously.
We do not know what else would have come to light if the appellant had
appeared before the investigating officer or if he had furnished the
requisite information that was sought from him."

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16. Reference to adjudication also cites section 11C(6) of the SEBI

Act, 1992 but that is a provision which makes certain defaults
punishable with imprisonment and fine which obviously can be
imposed by a court of competent jurisdiction and not by the
Adjudicating Officer. Further, the Adjudicating Officer has limited
jurisdiction to adjudicate violations which have been specifically
referred to in the terms of reference.

The real issue is

adjudication under section 11C(2) and (3) of SEBI Act, 1992,

wherein it has to be seen as to whether an intermediary/person
associated with securities market is under a statutory duty to
produce records and documents to the IA and whether there is
default in this regard. The answer is in the affirmative. Once the
default is established, it calls for levying of penalty.

17. Thus, I find that since the Noticee did not comply with the
summons dated January 17, 2011, January 28, 2011, June 13,
2011, July 14, 2011 and September 22, 2011, the Noticee has
violated provisions of sections 11C(2), 11C(3) and 11C(5) of
SEBI Act, 1992. Noticee withheld important information like
demat statement and bank account statement for the year 2009,
copy of contract notes issued to the clients, complete set of KYC
of clients, details of payments made/received by Noticee to its
clients, quarterly statement of funds and securities sent from
January 2008 to March 2010 for the clients, client master etc.
Funds flow and securities flow are important tools of investigation
to keep a trial and by not furnishing bank and demat statement,
Noticee failed to furnish vital information and he did not cooperate with the Investigating Authority and successfully stalled
the investigation.
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18. In this context, reliance is placed upon the order of the Honble
Supreme Court of India in the matter of Chairman, SEBI v.. Shriram
Mutual Fund {[2006] 5 SCC 361} wherein it was held that "In our
view, the penalty is attracted as soon as contravention of the statutory
obligations as contemplated by the Act is established and, therefore, the
intention of the parties committing such violation becomes immaterial.
. Hence, we are of the view that once the contravention is
established, then the penalty has to follow and only the quantum of
penalty is discretionary."

19. As regards the imposition of monetary penalty for noncompliance of summons, I note that the Hon'ble SAT had the
occasion to deal with this issue in the matter of DKG Buildcon Pvt.
Ltd.(supra), wherein it observed: " The power to require a person to
furnish any information or record or documents includes the power to
require such person to make a statement and give clarifications with
regard to the information and documents produced by him. In the
absence of such a power the purpose of the legislature in introducing
section 11C would be frustrated and the Board will not be able to
investigate properly the market irregularities and offences. In order to
advance the object of Parliament the language used in sub-section (3)
of section 11C has to be given a wider meaning. We are, therefore, of
the considered opinion that section 11C (3) gives the power to the
investigating authority to call upon any person to make a statement
while furnishing any information, document or record." Thus, it is
clear that if a person fails to comply with the summons of
Investigating Authority he is liable for penalty under Section
15A (a) of SEBI Act, 1992. As the violation of provisions of
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section 11C (2),(3) and 11C(5) of SEBI Act, 1992 by the Noticee
has been established, I find that Noticee is liable for monetary
penalty under section 15A(a) of SEBI Act, 1992.

20. The aforesaid provisions read as under:

"15A. Penalty for failure to furnish information, return, etc.- If
any person, who is required under this Act or any rules or
regulations made thereunder,(a) to furnish any document, return or report to the Board, fails to
furnish the same, he shall be liable to a penalty of one lakh
rupees for each day during which such failure continues or one
crore rupees, whichever is less;"
21. I note that the material made available on record has not
quantified the amount of disproportionate gain or unfair
advantage made by the Noticee and the loss suffered by the
investors as a result of the Noticee's default. Also there is no
material made available on record to assess the amount of loss
caused to investors or the amount of disproportionate gain or
unfair advantage made by the Noticee as a result of default.
However, it is pertinent to mention here that not submitting
information and documents to the summons

hampers the

investigation. Further, any delay or hurdle in investigation due to

non cooperation by any entity is detrimental to the interest of
investors in securities market and the same deserves to be
viewed seriously. Since the Noticee has failed to respond to the
summons issued on more than one occasion, the default is
repetitive in nature.

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ORDER
22. After taking into consideration all the facts and circumstances of
the case, nature and gravity of the charges and the factors
mentioned in section 15J of the SEBI Act, 1992, I, in exercise of
the powers conferred upon me under Section 15I of the SEBI
Act, 1992 read with Rule 5 of the Adjudication Rules, hereby
impose a monetary penalty of

` 15,00,000/- (Rupees Fifteen

Lakh Only) on the Noticee which will be commensurate with the

violation committed by him.

23. The Noticee shall pay the said amount of penalty by way of
demand draft in favour of SEBI - Penalties Remittable to
Government of India, payable at Mumbai, within 45 days of
receipt of this order. The said demand draft should be forwarded
to The Division Chief, Enforcement Department-EFD-DRA-III,
SEBI Bhavan, Plot No. C 4 A, G Block, Bandra Kurla
Complex, Bandra (E), Mumbai 400 051.

24. In terms of rule 6 of the Rules, copies of this order are sent to the
Noticee and also to the Securities and Exchange Board of India.

DATE: SEPTEMBER 14, 2015

PLACE: MUMBAI

S.V. KRISHNAMOHAN
CHIEF GENERAL MANAGER
&ADJUDICATING OFFICER

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