WTM/KV/ISD/ISD-SEC-7/31103/2024-25

SECURITIES AND EXCHANGE BOARD OF INDIA

EX-PARTE INTERIM ORDER CUM SHOW CAUSE NOTICE

UNDER SUB-SECTION (1) OF SECTION 11, SUB-SECTION (4) OF SECTION 11,

SUB-SECTION (4A) OF SECTION 11 AND SECTION 11B OF THE SECURITIES
AND EXCHANGE BOARD OF INDIA ACT, 1992 READ WITH REGULATION 11 OF
THE SECURITIES AND EXCHANGE BOARD OF INDIA (PROHIBITION OF
FRAUDULENT AND UNFAIR TRADE PRACTICES RELATING TO SECURITIES
MARKET) REGULATIONS, 2003

IN THE MATTER OF EXTENDED FRONT RUNNING BY ROHIT SALGAOCAR,

KETAN PAREKH AND OTHERS

In respect of:
Sr. No. NOTICEES PAN
Information Carriers
1. Rohit Salgaocar Not Available
(Singapore Citizen) Passport No. - XXX51057B
2. Ketan Vinaychandra Parekh AADPP1505A
Front Runners (FRs)
3. GRD Securities Limited AABCG7534M
4. Salasar Stock Broking Limited AADCS8020Q
5. Anirudh Damani AFMPD0253P
6. Ashok Kumar Damani ACXPD6089R
7. Basukinath Properties Private Limited AABCB4123D
8. APR Properties Private Limited AAJCA9378H
Facilitators
9. Sanjay Taparia ABLPT6566E
10. Ashok Kumar Poddar AFTPP2389D
11. Sumit Sonthalia ALAPS2324Q
Directors
12. Pramod Kumar Drolia ADGPD7175A
13. Bimal Kumar Drolia ACQPD3084M
14. Priya Saraf (also Facilitator) AFDPD9286M
15. Anita Drolia BZYPD8214M
16. Kiran Kumar Sonthalia ALHPS3335E
17. Shyam Saraogi (also Facilitator) AQZPS7213E
18. Pradeep Saraogi (also Facilitator) AIXPS9818F
19. Rachit Poddar (also Facilitator) BDIPP6530J
20. Manoj Kumar Agarwal ACLPA9844P
21. Mahendra Kumar Agarwal ACMPA5091M
22. Renu Agarwal ADAPA2672D

(The entities mentioned above are individually known by their respective names or
Noticee no. and collectively referred to as “Noticees”)

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
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 TABLE OF CONTENTS

A. BACKGROUND .............................................................................................................................. 3
B. SUSPECTED MODUS OPERANDI .............................................................................................. 10
C. VARIOUS MOBILE NUMBERS USED BY KETAN PAREKH ..................................................... 11
D. CONNECTION AMONGST NOTICEES AND SHARING OF NPI AND NPI-BASED TRADING
INSTRUCTIONS ................................................................................................................................... 26
D.1 CONNECTION BETWEEN ROHIT SALGAOCAR AND KETAN PAREKH AND FLOW OF NPI ................... 26
D.2 FLOW OF NPI-BASED TRADING INSTRUCTIONS FROM KETAN PAREKH TO FRS............................. 29
D.3 FLOW OF NPI-BASED TRADING INSTRUCTIONS FROM KETAN PAREKH TO GRD SECURITIES LIMITED
AND DAMANIS ...................................................................................................................................... 30
D.4 FLOW OF NPI-BASED TRADING INSTRUCTIONS FROM KETAN PAREKH TO SALASAR STOCK BROKING
LIMITED39
D.5 FLOW OF NPI-BASED TRADING INSTRUCTIONS FROM KETAN PAREKH TO APR PROPERTIES PRIVATE
LIMITED AND BASUKINATH PROPERTIES PRIVATE LIMITED...................................................................... 42
E. COMPARISON OF TRADING VOLUME AND PROFITS OF FRS.............................................. 44
F. ROLE OF ROHIT SALGAOCAR IN OBTAINING AND SHARING NPI ...................................... 53
F.1 ARRANGEMENT BETWEEN SCPL/ROHIT SALGAOCAR AND THE BIG CLIENT ................................. 54
F.2 AGREEMENTS BETWEEN SCPL/ROHIT SALGAOCAR AND TRADING MEMBERS ............................. 59
F.3 MISLEADING AND FALSE INFORMATION PROVIDED BY ROHIT SALGAOCAR TO TRADERS OF THE BIG
CLIENT 67
G. ILLUSTRATIONS OF NPI-BASED TRADING ACTIVITIES IN THE ACCOUNTS OF FRS ....... 71
G.1 ILLUSTRATION OF NPI-BASED TRADES BY FR1 AND FR2 IN THE SCRIP OF TITAN COMPANY LIMITED
(TITAN/500114) ON APRIL 05, 2023 ................................................................................................... 73
G.2 ILLUSTRATION OF NPI-BASED TRADES BY FR2 IN THE SCRIP OF HDFC LIMITED (HDFC/500010) ON
SEPTEMBER 19, 2022 ......................................................................................................................... 82
G.3 ILLUSTRATION OF NPI-BASED TRADE BY FR1, FR2 AND FR3 IN THE SCRIP OF POLICY BAZAR LIMITED
(PB FINTECH/ 543390) ON NOVEMBER 11, 2022 .................................................................................. 89
G.4 ILLUSTRATION OF NPI-BASED TRADES BY FR 2 AND FR5 IN THE SCRIP OF CHOLAMANDALAM
INVESTMENT AND FINANCE COMPANY LIMITED (CHOLAFIN / 511243) ON JANUARY 09, 2023 ............. 105
G.5 ILLUSTRATION OF NPI-BASED TRADES BY FR 2 AND FR6 IN THE SCRIP OF TUBE INVESTMENTS OF
INDIA LIMITED (TIINDIA/540762) ON MAY 18, 2022 ........................................................................... 114
H. CALCULATION OF TOTAL UNLAWFUL GAINS MADE BY NOTICEES FROM TRADING
BASED ON NPI AND COMMISSION INCOME OF ROHIT SALGAOCAR....................................... 124
I. ILLUSTRATION OF PROFIT SHARING FROM FR TRADES .................................................. 125
J. FACT FINDING TO SUPPORT ALLEGATION OF MODUS OPERANDI ................................. 140
K. EXAMINATION OF LEGAL ISSUES TO DETERMINE IF THERE IS A VIOLATION ............... 141
L. LIABILITY OF DIRECTORS OF FR1, FR2, FR5 AND FR6....................................................... 158
M. NEED FOR INTERIM EX-PARTE ORDER ................................................................................ 174
N. BASIS OF DISGORGEMENT AND JOINT AND SEVERAL LIABILITY ................................... 177
O. INTERIM ORDER ....................................................................................................................... 180
LIST OF FIGURES MENTIONED IN THE ORDER ............................................................................ 185
LIST OF TABLES MENTIONED IN THE ORDER ............................................................................. 186

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
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A. BACKGROUND

1. The present proceedings are emanating from an investigation conducted for

the period of January 01, 2021 to June 20, 2023 (hereinafter “Investigation
Period”) by the Securities and Exchange Board of India (hereinafter “SEBI”)
involving abovementioned Noticees.

2. Considering the prima facie pattern of trades in common scrips by some of

Noticees with various funds of an overseas entity which are engaged in the
business of Foreign Portfolio Investment (hereinafter collectively referred to as
“Big Client”)1, further examination was conducted in order to ascertain whether
acts of the above Noticees were in violation of provisions of the Securities and
Exchange Board of India Act, 1992 (hereinafter “SEBI Act”), and the
Rules/Regulations framed thereunder.

3. SEBI appointed Joint Investigating Authorities under section 11C of the SEBI
Act to carry out investigation in the matter. Subsequently, after obtaining due
permission of the Competent Court, a search and seizure operation was carried
out over a period of three days starting on June 22, 2023 at the premises of 17
entities wherein various documentary and electronic evidences were gathered
and statements of various Noticees were recorded on oath. Out of the 17
entities, no case has been made out against 4 entities and these 4 entities have
not been named as Noticees in this order. The details of the entities whose
premises were searched are as follows:

Table no. 1
Details of entities whose premises were searched by SEBI
Sr.
Name/Description Address
No.
Entities who are Noticees in this order pursuant to search and seizure operation

1
Note: Name of the Big Client has not been used and would be supplied to Noticees during inspection of
documents and to Hon’ble SAT and Courts during court proceedings. It is further clarified that in the
statements/chats used in this order, the term ‘Big Client’ is used in place of the actual name appearing in such
statements/chats.

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 Sr.
Name/Description Address
No.
1. Salasar Stock Broking Limited Clive Row, Kolkata, West Bengal – 700001
2. Kiran Kumar Sonthalia New Alipore, Kolkata - 700053
Old Chaurangi Road, Kolkata, West Bengal –
3. Shyam Rajkumar Saraogi
700071
4. Pradeep Kumar Saraogi Alipore Road, Kolkata, West Bengal - 700027
5. Rachit Poddar Alipore H O, Kolkata, West Bengal - 700027
6. Manoj Kumar Agarwal Simla Road, Kolkata, West Bengal – 700006
7. Sanjay Taparia Alipore H O, Kolkata, West Bengal – 700027
Bhowanipore, Kolkata, West Bengal, India –
8. Anirudh Damani
700020
9. Ashok Kumar Damani Bhowanipore, Kolkata, West Bengal - 700021
A.J.C. Bose Road, Kolkata West Bengal -
10.
GRD Securities Limited 700020
11. Bimal Kumar Drolia Ballygunj, Kolkata West Bengal – 700019
12. Pramod Kumar Drolia Ballygunj, Kolkata West Bengal -700019
13. Priya Saraf Hazra Road, Kolkata, West Bengal - 700019
Entities who are not Noticees in this order pursuant to search and seizure
operation

14. Director of an FR company Alipore, Kolkata West Bengal - 700027

15. Proprietary trader Walkeshwar, Mumbai, Maharashtra - 400006

Vidyavihar West, Mumbai, Maharashtra -

16. Trader of Motilal
400086
17. Trader of Nuvama Borivali East, Mumbai, Maharashtra-400066

4. Based on the evidence collected during the search and seizure operation, it
was prima facie suspected that, in addition to traditional front-running, the
Frontrunners (hereinafter ‘FRs’) used complex trading strategies to take
advantage of the prior knowledge of the impending trades of the Big Client as
explained in detail in paragraph 182.

5. A brief description of Noticees and their alleged role is mentioned herein below:

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 i Rohit Salgaocar/Noticee no. 1: A person, residing in Singapore who is
the director and authorized signatory of a company called Strait
Crossing Pte Limited (hereinafter “SCPL”), who entered into a
Memorandum of Understanding (MoU)/referral agreement with Motilal
Oswal Financial Services Limited (hereinafter “Motilal”) and Nuvama
Wealth Management Limited (hereinafter “Nuvama”) (erstwhile
Edelweiss Securities Limited) to refer trades of the Big Client to them.
The traders of the Big Client used to consult Rohit Salgaocar prior to
placing orders in Indian markets and thus Rohit Salgaocar allegedly had
access to the non-public information (hereinafter “NPI”) with respect to
substantial impending transaction in various scrips;

ii Ketan Vinaychandra Parekh/ Ketan Parekh/ Noticee no. 2: A person

who allegedly obtained NPI from Rohit Salgaocar and orchestrated the
whole scheme to communicate trading instructions based on NPI to
other Noticees. In the past, Ketan Parekh and his group entities were
prohibited from dealing in the securities and debarred from associating
with the securities market for a period of 14 years vide SEBI order dated
December 12, 2003;

iii GRD Securities Limited/Noticee no. 3/FR1: A registered stock broker

who lent access to its proprietary trading account to Sanjay Taparia who
used the account for executing trades allegedly based on NPI. The
directors of GRD Securities Limited, who were in charge of and
responsible to the company for the conduct of its business during the
Investigation Period, namely, Pramod Kumar Drolia, Bimal Kumar
Drolia, Priya Saraf and Anita Drolia, are also alleged to have
contravened the provisions of securities laws;

iv Salasar Stock Broking Limited/Noticee no. 4/FR2: A registered stock

broker whose proprietary trading account was used for executing trades
allegedly based on NPI. The directors of Salasar Stock Broking Limited

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 who were in charge of and responsible to the company for the conduct
of its business during the Investigation Period, namely, Kiran Kumar
Sonthalia, Shyam Saraogi and Pradeep Kumar Saraogi, are also
alleged to have contravened the provisions of securities laws;

v Anirudh Damani/Noticee no. 5/FR3: A person who executed trades

allegedly based on NPI through his trading account. He is also a nephew
of Ashok Kumar Damani;

vi Ashok Kumar Damani/Noticee no. 6/FR4: A person who executed

trades allegedly based on NPI through his trading account. He is the
uncle of Anirudh Damani;

vii Basukinath Properties Private Limited/Noticee no. 7/FR5: A

company whose trading account was used by its director, Rachit
Poddar, through the computer system placed at his residence for
executing trades allegedly based on NPI. The directors of Basukinath
Properties Private Limited who were in charge of and responsible to the
company for the conduct of its business during the Investigation Period,
namely, Rachit Poddar, Manoj Kumar Agarwal and Mahendra Kumar
Agarwal, are also alleged to have contravened the provisions of
securities laws;

viii APR Properties Private Limited/Noticee no. 8/FR6: A company

whose trading account was used by its director Rachit Poddar, through
the computer system placed at his residence for executing trades
allegedly based on NPI. The directors of Basukinath Properties Private
Limited who were in charge of and responsible to the company for the
conduct of its business during the Investigation Period, namely, Rachit
Poddar, Manoj Kumar Agarwal, Mahendra Kumar Agarwal and Renu
Agarwal, are also alleged to have contravened the provisions of
securities laws;

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 ix Sanjay Taparia/Noticee no. 9: A person who received trade related
instructions allegedly based on NPI from Ketan Parekh and arranged
trading accounts for executing such trades;

x Ashok Kumar Poddar/Noticee no. 10: A person who allegedly

received trade related instructions based on NPI from Ketan Parekh and
passed such information to his son, Rachit Poddar, for executing trades
through trading accounts of APR Properties Private Limited and
Basukinath Properties Private Limited. Rachit Poddar is a director of
both these companies;

xi Sumit Sonthalia/Noticee no. 11: A person who is a trader of Salasar

Stock Broking Limited and facilitated execution of trades allegedly
based on NPI in the proprietary trading account of Salasar Stock
Broking Limited as per the instructions of Ketan Parekh;

xii Pramod Kumar Drolia/Noticee no. 12: A person who is the managing
director and promoter of GRD Securities Limited and was in such
capacity in charge of, and responsible to, the company for the conduct
of its business at the time the alleged contravention was committed by
the company;

xiii Bimal Kumar Drolia/Noticee no. 13: A person who is the whole-time
director and promoter of GRD Securities Limited and was in such
capacity in charge of, and responsible to, the company for the conduct
of its business at the time the alleged contravention was committed by
the company;

xiv Priya Saraf/Noticee no. 14: A person who is an independent director

and promoter of GRD Securities Limited and facilitated trading in the

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
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 proprietary trading account of GRD Securities Limited through her CTCL
ID and was in such capacity in charge of, and responsible to, the
company for the conduct of its business at the time the alleged
contravention was committed by the company;

xv Anita Drolia/Noticee no. 15: A person who is the director and promoter
of GRD Securities Limited and was in such capacity in charge of, and
responsible to, the company for the conduct of its business at the time
the alleged contravention was committed by the company;

xvi Kiran Kumar Sonthalia/Noticee no. 16: A person who is director of

Salasar Stock Broking Limited and was in such capacity in charge of,
and responsible to, the company for the conduct of its business at the
time the alleged contravention was committed by the company;

xvii Shyam Rajkumar Saraogi/Noticee no. 17: A person who is director of

Salasar Stock Broking Limited and who facilitated execution of trades in
the proprietary trading account of Salasar Stock Broking Limited upon
receipt of trade related instructions allegedly based on NPI from Ketan
Parekh;

xviii Pradeep Kumar Saraogi/Noticee no. 18: A person who is an

independent director of Salasar Stock Broking Limited and facilitated
execution of trades in the proprietary trading account of Salasar Stock
Broking Limited upon receipt of trade related instructions allegedly
based on NPI from Ketan Parekh;

xix Rachit Poddar/Noticee no. 19: A person who is director of APR

Properties Private Limited and Basukinath Properties Private Limited
who allegedly executed trades in the trading accounts of APR Properties
Private Limited and Basukinath Properties Private Limited upon receipt
of trade related instructions allegedly based on NPI from Ketan Parekh;

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 xx Manoj Kumar Agarwal/Noticee no. 20: A person who is director and
promoter of APR Properties Private Limited and Basukinath Properties
Private Limited and was in such capacity in charge of, and responsible
to, the company for the conduct of its business at the time the alleged
contravention was committed by the company;

xxi Mahendra Kumar Agarwal/Noticee no. 21: A person who is director

of APR Properties Private Limited and Basukinath Properties Private
Limited and was in such capacity in charge of, and responsible to, the
company for the conduct of its business at the time the alleged
contravention was committed by the company;

xxii Renu Agarwal/Noticee no. 22: A person who is director of APR

Properties Private Limited and was in such capacity in charge of, and
responsible to, the company for the conduct of its business at the time
the alleged contravention was committed by the company.

6. The aforesaid FRs, namely FR1 to FR6, have allegedly traded on the basis of
instructions received, directly or indirectly, from Ketan Parekh which were
allegedly based on NPI with respect to substantial impending transaction of the
Big Client in various scrips. The Big Client is a US based fund house which has
various funds registered as Foreign Portfolio Investors with SEBI. These FPIs
invest in the Indian securities markets through various registered Trading
Members (hereinafter “TMs”).

7. It was observed that trades of the Big Client in India were spread across a large
number of TMs during the Investigation Period. However, it was also observed
that trades of the Big Client undertaken through Nuvama and Motilal matched
with trades of FRs.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
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 8. In the course of the investigation, following information and evidence have been
gathered:
i Trading data;
ii Data/ information gathered from electronic devices;
iii Bank account statements;
iv Details of IP addresses which were used for the trades executed
through the account of some Noticees;
v Statement of Noticees recorded on oath;
vi KYC, Call Data Records (hereinafter “CDR”), etc.

B. SUSPECTED MODUS OPERANDI

9. After analysis of statements recorded, facts unearthed during the search and
seizure operations, it is seen that Noticees have, prima facie, adopted the
following modus operandi. Prior to execution of suspicious trades, FRs were
receiving trade instructions through WhatsApp chats or calls from a person
whose contact number(s) was saved in the devices as Jack/Jack New/Jack
Latest New/Boss, etc. Upon analysis of these contact numbers, it was found
that these numbers belonged to Ketan Parekh who was receiving NPI from one,
Rohit Salgaocar. After receiving specific and timely instructions, directly or
indirectly, from Ketan Parekh, the FRs used to execute orders and made unjust
profits.

10. The investigation further revealed that the Big Client used to place orders
containing the scrip name, buy/sell quantity and buy/sell price through their
order messaging system called FIX. For orders routed through Motilal and
Nuvama, traders of Nuvama and Motilal used to execute such orders. However,
the instructions regarding execution of these orders such as details of the scrip,
time quantity and price of the order, were dictated by Rohit Salgaocar. It was
found that SCPL, the company owned by Rohit Salgaocar, had entered into a
referral agreement with Nuvama and Motilal for revenue sharing of the
brokerage earned on trades of the Big Client referred by SCPL.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
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 11. It was further found that traders of the Big Client used to discuss the amount
and/or price of the scrip with Rohit Salgaocar prior to placing their orders and
Rohit Salgaocar used to request these traders to place the order either through
Nuvama or Motilal. Simultaneously, Rohit Salgaocar also used to interact with
traders of Nuvama and Motilal through Bloomberg chat and used to provide
trading instructions and seek updates on status of order execution through the
same chat function.

12. A detailed analysis of orders placed by the Big Client and FRs revealed the
recurrent matching of the scrip, price, quantity and timing of trades between the
Big Client and FRs which would not have been possible unless FRs were in
possession of NPI or NPI-based trading instructions relating to impending
orders of the Big Client in various scrips. Hence, the matter was further
investigated and it was observed that the NPI relating to impending orders of
the Big Client was being passed from Rohit Salgaocar to Ketan Parekh who in
turn used to communicate trading instructions based on such NPI, directly or
indirectly, to the six FRs for execution in order to gain undue profits. The facts
and evidences which prima facie establish the suspected modus operandi are
discussed in the subsequent paragraphs.

C. VARIOUS MOBILE NUMBERS USED BY KETAN PAREKH

13. From the back-up of the mobile devices found and seized during the
aforementioned search and seizure operations and the subsequent statement
recordings of various entities, certain contact details of Ketan Parekh were
gathered. It is noted that in none of the mobile phones, the contact numbers
were saved in the name of Ketan Parekh and instead, various pseudo names
such as, “Jack”, “John”, “Boss”, “Bhai”, “Wellwisher”, etc. were used to save
these numbers. The details of these contact numbers along with the
documentary proof are as follows:

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
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 Table no. 2
Details of contact numbers as obtained from various devices
Proof that Name of Ketan Parekh saved as pseudo name in mobile devices of various entities
the mobile
Ashok Ashok Rohit
S. Mobile number Sanjay Sanjay Rachit
Sumit Rakesh Kumar Kumar Salgaocar
No. Numbers belongs to Taparia - Taparia - Rahul Saraf Poddar -
Sonthalia Kathotia Poddar Poddar - (as per
Ketan Android iPhone Iphone
IPhone12 IPhone13 statement)
Parekh2
 Aadhaar
Card of Ketan
Parekh

 Night
Mamta
1 XXX0308243 location at - - - - - - - -
Bhabhi
Residence of
Ketan Parekh

 Hotel
Location

2
Hotel Location means the proof of the fact that location of phone number allegedly possessed by Ketan Parekh matched with the location of Hotel where Ketan Parekh is
had stayed.

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
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 Proof that Name of Ketan Parekh saved as pseudo name in mobile devices of various entities
the mobile
Ashok Ashok Rohit
S. Mobile number Sanjay Sanjay Rachit
Sumit Rakesh Kumar Kumar Salgaocar
No. Numbers belongs to Taparia - Taparia - Rahul Saraf Poddar -
Sonthalia Kathotia Poddar Poddar - (as per
Ketan Android iPhone Iphone
IPhone12 IPhone13 statement)
Parekh2
 Night
location at
2 XXX7623119 - - Jack Old - - Boss1 - - -
Residence of
Ketan Parekh
 Same IMEI
as mobile at
WhatsApp
Sr. No. 1
chats but
 Night
3 XXX7049917 - number not - - - - - - -
location at
saved in
Residence of
mobile
Ketan Parekh

 Night WhatsApp
location at chats but
Ketan
4 XXX6010390 Residence of - number not - - - - - -
Bhai 1
Ketan Parekh saved in
mobile

Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
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 Proof that Name of Ketan Parekh saved as pseudo name in mobile devices of various entities
the mobile
Ashok Ashok Rohit
S. Mobile number Sanjay Sanjay Rachit
Sumit Rakesh Kumar Kumar Salgaocar
No. Numbers belongs to Taparia - Taparia - Rahul Saraf Poddar -
Sonthalia Kathotia Poddar Poddar - (as per
Ketan Android iPhone Iphone
IPhone12 IPhone13 statement)
Parekh2
 Same IMEI
WhatsApp
as mobile at WhatsApp
chats but
Sr. No. 6 chats but
number not
 Night number not 900
saved in Jack.
5 XXX7571068 location at Jack New - saved in New.Boss - - -
mobile - Personal
Residence of mobile - 5
(Display
Ketan Parekh (Display
name3 -
 Hotel name - Jola)
Jola)
Location
 Statement
recording of
6 XXX6562996 Ketan Parekh - - - - - - - - Rohit
& Visitor Slip
at SEBI

3
Though the said number is not saved in the contact list of the mobile phone, the display name shown in the table is the one which is saved by the owner of the number with
WhatsApp.

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 Proof that Name of Ketan Parekh saved as pseudo name in mobile devices of various entities
the mobile
Ashok Ashok Rohit
S. Mobile number Sanjay Sanjay Rachit
Sumit Rakesh Kumar Kumar Salgaocar
No. Numbers belongs to Taparia - Taparia - Rahul Saraf Poddar -
Sonthalia Kathotia Poddar Poddar - (as per
Ketan Android iPhone Iphone
IPhone12 IPhone13 statement)
Parekh2
 Night
location at
Residence of
Ketan Parekh
 Hotel
Location
WhatsApp
chats but
 Night Ketan number not
location at Parekh saved in
7 XXX2522726 Jack New Jack. New Jack New Boss 3 - - -
Residence of John mobile -
Ketan Parekh Mobile (Display
name -
Boss)
WhatsApp
 Night JACK Jack
8 XXX5555484 955A Jack New chats but Boss 4 - - -
location at Latest Ketan
number not

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 Proof that Name of Ketan Parekh saved as pseudo name in mobile devices of various entities
the mobile
Ashok Ashok Rohit
S. Mobile number Sanjay Sanjay Rachit
Sumit Rakesh Kumar Kumar Salgaocar
No. Numbers belongs to Taparia - Taparia - Rahul Saraf Poddar -
Sonthalia Kathotia Poddar Poddar - (as per
Ketan Android iPhone Iphone
IPhone12 IPhone13 statement)
Parekh2
Residence of Bhai saved in
Ketan Parekh Mobile mobile -
 Hotel (Display
Location name -
 Birthday 955A)
wish on
WhatsApp
(explained
later)
WhatsApp WhatsApp
 Same IMEI
chats but chats but
as mobile at
number not number not
Sr. No. 5 Jack
saved in Jack New Jack- saved in
9 XXX8527607  Night Latest. Boss New - Wellwisher. -
mobile - M Mobile mobile -
location at New
(Display (Display
Residence of
name - name -
Ketan Parekh
JACK) JACK)

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 Proof that Name of Ketan Parekh saved as pseudo name in mobile devices of various entities
the mobile
Ashok Ashok Rohit
S. Mobile number Sanjay Sanjay Rachit
Sumit Rakesh Kumar Kumar Salgaocar
No. Numbers belongs to Taparia - Taparia - Rahul Saraf Poddar -
Sonthalia Kathotia Poddar Poddar - (as per
Ketan Android iPhone Iphone
IPhone12 IPhone13 statement)
Parekh2
 Same IMEI
as mobile at WhatsApp WhatsApp
Sr. No. 5 chats but chats but
Jack
10 XXX2928015  Night Jack number not number not - Boss 2 - - -
Ketan
location at saved in saved in
Residence of mobile mobile
Ketan Parekh

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 Aadhaar details of Ketan Parekh
14. Ketan Parekh had visited SEBI Office on March 15, 2023, representing another
entity (NH Securities Limited) in a different matter. As proof of identity, he had
submitted copy of his Aadhaar Card having number “XXXXXXX32573” which
also contained the mobile number “XXX0308243”. Further, in the visitor slip
generated with respect to the aforesaid visit of Ketan Parekh to SEBI, the
mobile number “XXX6562996” is hand-written along with the aforesaid mobile
number.

15. The subscriber details of the aforesaid contact number as obtained from the
Telecom Service Provider – Vodafone Idea are noted below:
i Name of Subscriber: Ms. Mamta Parekh
ii Address of Subscriber: Zaver Mahal, 19/b, Marine Drive, Marine Lines,
Mumbai, Maharashtra - 400020
iii Number active since: May 28, 2001

16. In his statement dated December 12, 2023, Ketan Parekh, confirmed that the
mobile number “XXX0308243” belongs to his wife, Ms. Mamta Parekh. Further,
the address of Ms. Mamta Parekh is the same as mentioned in the Aadhaar
card of Ketan Parekh. Thus, it is prima facie established that Ketan Parekh uses
the phone number “XXX0308243” which belongs to his wife.

IMEI analysis of various phone numbers of Ketan Parekh

17. The IMEI (International Mobile Equipment Identity) number is a unique 15-digit
serial number for identifying a particular mobile phone. On analysis of IMEI
numbers associated with the contact numbers gathered above, it was found
that various contact numbers were used in same mobile devices. The details of
IMEI numbers of mobile devices and the corresponding contact number(s)
which were used through such mobile devices are tabulated below:

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 Table no. 3
IMEI analysis of various phone numbers of Ketan Parekh
Mobile Nos/ IMEI XXX169320198069 XXX310700440194 XXX955052100791
XXX0308243 
XXX7049917 
XXX7571068  
XXX6562996 
XXX8527607 
XXX2928015 

18. From the table above, it can be observed that the IMEI which was used for
mobile number “XXX0308243” (number used by Ketan Parekh as explained
above), was also used for mobile number “XXX7049917”, confirming that this
number was also used by Ketan Parekh.

19. The contact number “XXX6562996” was confirmed by Ketan Parekh as his own
number in his statement dated December 12, 2023. Further, Rohit Salgaocar
also confirmed that the contact number “XXX6562996” belongs to Ketan
Parekh. The IMEI number for the contact numbers “XXX6562996” and
“XXX7571068” is the same i.e. “XXX6310700440194” which confirms that the
contact number “XXX7571068” was also used by Ketan Parekh.

20. Further, the contact number “XXX7571068”, was also used through mobile
device having IMEI number “XXX955052100791”. The same mobile device was
also found to be used for the mobile numbers “XXX8527607” and
“XXX2928015” which confirms that these mobile numbers were also used by
Ketan Parekh.

21. From the aforesaid analysis, it can be inferred that contact numbers
“XXX0308243”, “XXX7049917”, “XXX6562996”, “XXX7571068”,
“XXX8527607” and “XXX2928015” were being used by Ketan Parekh.

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 Location analysis of various phone numbers of Ketan Parekh
22. The CDRs of various contact numbers associated with Ketan Parekh were
analysed to identify the location of the said numbers at the night time (i.e. from
9:00 pm to 6:00 am) during the investigation period. It is revealed that all the
mobile numbers were located at the home address of Ketan Parekh on most
occasions i.e. Zaver Mahal, 19/b, Marine Drive, Marine Lines, Mumbai,
Maharashtra – 400020. The details of the same are as follows:
Table no. 4
Location analysis of various phone numbers of Ketan Parekh
Registered name & address as
S. Mobile Period
Latitude Longitude per Customer Acquisition
No. Number in use
Form
Mamta Parekh
19-Jul-21
1 XXX0308243 18.93715 72.82472 to 30- Zaver Mahal, 19/B, Marine Drive
Jun-23 N. S. Marg, Marine Lines, Mumbai
400020
20-Sep-
2 XXX7623119 18.93729 72.82475 21 to 16- CAF not shared by TSP
Dec-21
Dhruv Jamnadas Shah

27-Sep-
K-1 704 Neelyog Residency Gauri
3 XXX7049917 18.93714 72.82475 21 to 09-
Shankar Wadi N0-1, Near Kanta
Dec-21
Apartment Ghatkopar East, Pant
Nagar, Maharashtra - 400075
27-Sep-
4 XXX6010390 18.93729 72.82475 21 to 07- CAF not shared by TSP
Oct-21
20-Oct-
5 XXX7571068 18.9371 72.8249 21 to 30- Virendra Pareghi
Jun-23

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 Registered name & address as
S. Mobile Period
Latitude Longitude per Customer Acquisition
No. Number in use
Form
168 2015, Pratiksha Appartment,
Opp Krk Varma School,
Ahmedabad-380063, Gujarat
Virendra Pareghi
20-Oct-
6 XXX2928015 18.93729 72.82475 21 to 11- 168 2015, Pratiksha Appartment,
May-22 Opp Krk Varma School,
Ahmedabad-380063
23-Dec-
7 XXX6562996 18.93729 72.82475 21 to 30- CAF not shared by TSP
Jun-23
Manish Agrawal

10-Mar- B /502, Aster Tower, Vasant

8 XXX2522726 18.93715 72.82472 22 to 10- Valley Complex
Oct-22 2,Gen. A. K. Vaidya Marg,
Opposite Oberoi Mall, Malad East,
Mumbai-400097
Ronak Dinesh Bhai Solanki
20-Sep-
9 XXX5555484 18.92721 72.82118 22 to 08-
6/ 372 C Colony Naroda Road,
Jun-23
Ahmedabad - 382330
Kadiya Chhaganbhai
23-Nov-
10 XXX8527607 18.9371 72.8249 22 to 24- 11/248, Gujrat Hou Board,
Jun-23 Meghaninagar,
Ahmedabad -380016

23. It can be observed from the aforesaid table that Ketan Parekh had been using
multiple contact numbers /SIM cards issued in the name of different persons in
order to disguise his identity. This is also corroborated by Ketan Parekh in his
statement made before SEBI wherein he admitted that he used to change his
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 contact number frequently and that such contact numbers were not obtained in
his name.

Third party confirmation from Hotels and Airline

24. The CDRs of the aforesaid mobile numbers were analysed on sample basis to
identify the location of the said numbers when the same were observed to be
outside Mumbai. The analysis of the mobile numbers “XXX0308243”,
“XXX7571068”, “XXX6562996” and “XXX5555484” revealed that the said
numbers were found to be located together at different hotels during different
periods, which is detailed below –
Table no. 5
Details confirmed by Hotels
S. No. Period Location Confirmation from Hotels
1. March 17, Hotel Grand Hotel authorities, vide email dated November 03, 2023
2023 to Hyatt Kochi confirmed the stay of Mr. & Mrs. Ketan Parekh in
March 20, Bolgatty, Room No. 340, for attending a wedding. Mr. & Mrs.
2023 Kochi, Kerala Parekh has also shared their Aadhaar as identity
proofs to the Hotel.
2. November Hotel Hotel authorities, vide email dated October 18, 2023
27, 2022 to Rambagh confirmed the stay of Mr. & Mrs. Ketan Parekh in
November Palace, Room No. 340, for attending a wedding of the
29, 2022 Jaipur daughter of a family friend. Mr. & Mrs. Ketan Parekh
have also shared their Aadhaar as identity proofs to
the Hotel.

The same was also confirmed by Ketan Parekh and

his family friend in their statements given to SEBI.
3. January 29, Hotel ITC Hotel officials, vide, email dated August 04, 2023
2023 to Sonar confirmed the stay of Mr. & Mrs. Ketan Parekh in their
February 01, Bangla, hotels, in Room No.3007. Further, Hotel authorities,
2023 Kolkata vide email dated August 30, 2023 submitted that Mr.
& Mrs. Ketan Parekh were part of a group booking

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 S. No. Period Location Confirmation from Hotels
made for the purpose of a wedding. Mr. & Mrs. Ketan
Parekh have also shared their Aadhaar as identity
proofs to the Hotel.

The same was also confirmed by Ketan Parekh, his

family friend (who attended the said wedding) and
Sanjay Taparia (who also attended the said wedding)
in their statements given to SEBI. They had also stated
they attended the wedding of theirs friend’s son.
4. September Welcomhotel Hotel officials, vide, email dated October 20, 2023
30, 2022 till by ITC confirmed the stay of Mr. & Mrs. Ketan Parekh in
October 02, Hotels, Room No.314. The address mentioned in the stay
2022 Alkapuri, invoice, as shared by the Hotel is “Ketan Parekh, NH
Vadodara Securities Private Limited, 121, Radha Bhavan, N.M.
Marg” which is the office address of Ketan Parekh and
his cousin Kartik Parekh, the director of M/s. NH
Securities Private Limited. The email address and
mobile number mentioned at the time of checking in
were [email protected] and “XXX0308243”
respectively. Mr. & Mrs. Ketan Parekh have also
shared their Aadhaar as identity proofs to the Hotel.

25. Further, with respect to Ketan Parekh’s visit to Hotel Rambagh Palace, Jaipur, it was
observed that Ketan Parekh took a flight from Mumbai to Jaipur on November 27,
2022 and then moved through Jaipur, Agra, Morena and Gwalior by road. He took a
flight from Gwalior to Mumbai on December 01, 2022.

26. The details obtained from the airlines in this regard is as follows –

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 Table no. 6
Flight Details of Ketan Parekh
Email Flight Travel From
Airline PNR Passenger Details
date No. Date and To
Air India October November Mumbai Ketan Parekh and Mrs.
611 QQJWP4
Limited 25, 2023 27, 2022 to Jaipur Mamta Parekh
Ketan Parekh, Mrs.
Gwalior
October December Mamta Parekh, Ashita
IndiGo 265 IJ71ML to
16, 2023 01, 2022 Parekh and Bhavin
Mumbai
Parekh

Whatsapp message containing birthday greeting for Ketan Parekh

27. From the WhatsApp chat available in the mobile device of Sanjay Taparia, it is
seen that he wished birthday to “Jack Latest” (mobile number of Jack Latest
being XXX5555484) on February 15, 2023 who responded by thanking him. It
is noted that the birth date of Ketan Parekh as mentioned on his PAN Card is
also February 15, 1962. This further proves that “Jack Latest” is none other than
Ketan Parekh and mobile number XXX5555484 is used by Ketan Parekh. The
screenshot of the aforesaid chat as retrieved from the device of Sanjay Taparia
is placed below:

Figure no. 1
Screenshot of WhatsApp chat between Sanjay Taparia and Ketan Parekh

28. Considering the analysis of aforesaid evidences, it can be inferred that contact
numbers mentioned in the preceding paragraphs were being used by Ketan
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 Parekh and he used these contact numbers to, inter alia, communicate his
instructions for execution of NPI-based trades to FRs. A diagrammatic
representation of the analysis carried out in respect of various contact numbers
of Ketan Parekh is as under:
Figure no. 2
Establishing identity of Ketan Parekh

29. Having prima facie established that Ketan Parekh was using the contact
numbers mentioned above, the trading activities in the accounts of FRs have
been examined in subsequent paragraphs to ascertain how Ketan Parekh was
communicating trading instructions based on NPI to various FRs for execution
of NPI-based trades.

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D. CONNECTION AMONGST NOTICEES AND SHARING OF NPI AND NPI-BASED
TRADING INSTRUCTIONS

30. Any information with respect to substantial impending transaction in securities

of an entity which is not generally available to public is categorised as non-
public information or NPI. An entity, who is in possession of such NPI and trades
based on such NPI, can use this information to build a position in the market
prior to the execution of the substantial impending transaction to benefit from
the price movements caused in the market by such large orders.

31. The NPI pertaining to impending orders of the Big Client in various scrips was
communicated by Rohit Salgaocar to Ketan Parekh. Thereafter, Ketan Parekh
used to instruct other Noticees to execute orders through the trading accounts
of FRs so as to take positions in the market to benefit from the impending orders
in various scrips. The flow of information and evidence gathered relating to the
same is elucidated in the ensuing paragraphs.

D.1 Connection between Rohit Salgaocar and Ketan Parekh and flow of NPI

32. In his statement dated March 7, 2024 and July 22, 2024, Rohit Salgaocar stated
that for executing trades of the Big Client, he used to find counterparties through
different market participants including foreign funds, Indian funds, other holders
of the shares and Ketan Parekh. However, as per the statement of Rohit
Salgaocar, around 90% of the Big Client trades were being fulfilled by Ketan
Parekh alone. Rohit Salgaocar has also stated that his extent of due diligence,
before engaging with Ketan Parekh for Big Client trades, was just to check that
Ketan Parekh was not banned from dealing in Indian Securities Market. The
relevant extracts from the statement of Rohit Salgaocar dated March 7, 2024
and July 22, 2024 is reproduced below:
“Q 23. Explain how the trades for Big Client were executed by you?

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 Reply-Dealer of the Big Client provides me with the name of the stock they are
interested in. I will check the availability with different market participants including
foreign funds, Indian funds, other holders of the shares etc. and lastly with Ketan
Parekh. After confirming the availability from the counterparty, I get back to the dealer
of the Big Client with the quantity and price on offer. Upon confirmation from the dealer
of the Big Client, the deal goes through. The Big Client dealer sends the deal ticket to
the broker in India. After execution of the trades, Indian broker used to confirm me on
Bloomberg chat. Sometimes, I used to get confirmation from Big Client dealers as well.

Q 27. In the reply to Q. No. 23, you have mentioned that you used to source
counterparties through Mr. Ketan Parekh. What percentage of Big Client trades
were being fulfilled by Ketan Parekh?
Reply- Around 90%

Q 28. How do you know Ketan Parekh and for how long?
Reply- My ex-father-in-law Mr Dev Ahuja introduced me to Mr. Ketan Parekh sometime
in the late 1990s. I re-contacted Ketan around 2 1/2 -3 years ago for trade in some
illiquid stock of Big Client. That’s how I started contacting him for blocks.

Q 29. Is the Ketan Parekh, as you mentioned in your replies, the same Ketan
Parekh whom SEBI had banned in 2001 and is infamously known as KP or K10?
Reply- Yes

Q 30. What kind of due diligence did you undertake before engaging with Ketan
Parekh for Big Client Trades?
Reply-My extent of due-diligence was to check whether he was banned from dealing
in Indian Securities Market.

Q 31. How did you interact with Ketan Parekh?

Reply-Phone call over WhatsApp.

Q 32. Whether Ketan Parekh had only one mobile number or did he keep on
changing numbers?
Reply-He kept on changing his mobile numbers but his WhatsApp’s display picture
remained the same. To my knowledge, he changed his mobile numbers half a dozen
times.

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 Q 33. When Ketan Parekh used to change his numbers, how did you get to know
about that?
Reply- Most of the times, he would simply text me telling his new number. I used to
save the new numbers and delete the old ones.

Q 34. Do you have any numbers of Ketan Parekh saved in your phone?
Reply-I only have one number of Ketan Parekh i.e. +91 XXX65 62996.

Q 35. Do you have any idea how Ketan Parekh brings counterparties?
Reply- We only talk about size and price. No other conversations.

Q 36. Was Ketan Parekh aware that you were bringing trades of Big Client?
Reply- It was known in the market that I used to deal predominantly for Big Client. I
have never explicitly revealed name of any of my clients. However, I believe that Ketan
Parekh would have assumed that the trades were of Big Client.”

33. Further, the Internet Protocol Detail Records (hereinafter “IPDRs”) of the
various mobile numbers of Ketan Parekh were also analysed and it was
observed that two IP addresses based in Singapore were appearing
consistently in these IPDRs which meant that Ketan Parekh was connecting
with these IP addresses on a regular basis.

34. In order to ascertain the details of the aforementioned Singapore based IP

address, a request was made to Monetary Authority of Singapore (hereinafter
“MAS”). MAS, vide its letter dated January 09, 2024 informed that the IP
address 218.212.174.201 is provided by Starhub Limited and the same was
allocated to Rohit Salgaocar and the billing address of this IP is “57, Cairnhill
Road #04-08 Elizabeth Height Singapore 229668”, which matches with the
residential address of Rohit Salgaocar, as provided by him in his email dated
August 21, 2024.

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35. Further, the IPDR of two mobile numbers of Ketan Parekh (XXX6562996 and
XXX8527607), during the period between February 2023 and May 2023 shows
151 instances of interaction with the IP address 218.212.174.201, which
belonged to Rohit Salgaocar. This prima facie establishes that Ketan Parekh
and Rohit Salgaocar used to interact with each other through internet/whatsapp
frequently. Further, both Ketan Parekh and Rohit Salgaocar, in their statements
have also admitted that they used to interact with each other over WhatsApp.

36. Thus, there are clear evidences of connection between Rohit Salgaocar and
Ketan Parekh through matching of IPDR as well as their independent
deposition. In view of the same, considering that Ketan Parekh was able to pre-
empt the trade orders of the Big Client and take timely position in market
through the trading accounts of FRs, there is a prima facie conclusion that the
NPI pertaining to impending orders of the Big Client in various scrips were being
communicated by Rohit Salgaocar to Ketan Parekh who was communicating
trading instructions based on such NPI to other Noticees for execution of trades
from the trading accounts of FRs.

D.2 Flow of NPI-based trading instructions from Ketan Parekh to FRs

37. From the backup of the mobile devices obtained during search and seizure
operation from various Noticees, it was observed that the contact details of an
individual, (which was saved under various names such as Jack/Jack
New/955A/Boss, etc.) was providing the trade related instructions including
scrip name, buy/sell, quantity, price, etc. to various Noticees. The aforesaid
information was being provided over various WhatsApp groups viz. Jack-ST,
Jack-Saro or through individual chat, in these mobile phones. From the analysis
of aforesaid mobile devices, it was found that the individual who was providing
these contact details was Ketan Parekh, as prima facie established in
paragraph 28. Further, the manner in which different entities were receiving the
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 trade related instructions from Ketan Parekh is explained in the ensuing
paragraphs.

D.3 Flow of NPI-based trading instructions from Ketan Parekh to GRD Securities
Limited and Damanis
38. From the analysis of the computer systems found during the search and seizure
operations at premises of Sanjay Taparia as provided in Table no. 9, it was
seen that Sanjay Taparia and his employee Rahul Saraf had login access to
the proprietary trading account of GRD Securities Limited and had
arrangements for placing orders with Ashok Kumar Damani and Anirudh
Damani (hereinafter collectively referred to as “Damanis”) in their trading
accounts.

39. Sanjay Taparia and his employee Rahul Saraf, were part of a WhatsApp group
called “Jack-ST” where they used to receive trade related instructions from
Ketan Parekh (WhatsApp name - Jack/ Jack Latest New). A sample snapshot
of the WhatsApp chat showing the instructions given by Ketan Parekh in the
group Jack-ST is placed below:
Figure no. 3
WhatsApp chat showing instructions given by Ketan Parekh in the group Jack-
ST

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40. The details of the WhatsApp group “Jack-ST”, as found from the backup of the
mobile device of Rahul Saraf as obtained by SEBI during search and seizure
operation, is given in the table below:
Table no. 7
Details of the WhatsApp group “Jack-ST”
Names found Names as Details as per the
from devices provided by Customer Acquisition
S. No. Mobile No. backed up Sanjay Taparia Form (CAF) of
during Search during search Telecom Service
and Seizure and seizure Providers (TSPs)
Kartik Parekh, Surendra
1. XXX0657217 Maverick/680K brother of Ketan Subhashchandra
Parekh Pandey
Kartik Parekh, Surendra
Maverick/Kartik
2. XXX9978591 brother of Ketan Subhashchandra
ji
Parekh Pandey
Subhash
3. XXX1040895 - Subhas Joshi
Latest/Subhashji
Surendra
680A/ Akash. Staff of Ketan
4. XXX6308049 Subhashchandra
New Parekh
Pandey
Surendra
Sagar/ 680Ko/ Relative of
5. XXX6123307 Subhashchandra
Kau.New Ketan Parekh
Pandey
Ketan
6. XXX8527607 Parekh/Jack/ Ketan Parekh Kadiya Chhaganbhai
Jack Latest New
Airtel Rahul/ Rahul Saraf,
7. XXX1040894 Rahul/Rahul employee of Rahul Saraf
Latest Sanjay Taparia
Harit Parekh, Surendra
8. XXX6436048 680H/ Harit Son of Kartik Subhashchandra
Parekh Pandey

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 Names found Names as Details as per the
from devices provided by Customer Acquisition
S. No. Mobile No. backed up Sanjay Taparia Form (CAF) of
during Search during search Telecom Service
and Seizure and seizure Providers (TSPs)
Sanjay
Taparia/719/ ST
9. XXX3006262 Sanjay Taparia Sanjay Taparia
Bhaiya/ ST
Latest

41. Further, the analysis of CDR of Sanjay Taparia and Damanis indicates that
Damanis had frequent interactions with Sanjay Taparia. During the Investigation
Period, Sanjay Taparia had 21 calls with Anirudh Damani and 1363 calls with
Ashok Kumar Damani from two of his mobile numbers. The table below shows
the details:
Table no. 8
Details from CDR of Sanjay Taparia and Damanis
Calls Between No of Calls
Anirudh Damani
Sanjay Taparia
(XXX0291884) 21
(XXX0013991,
Ashok Kumar Damani
XXX8175000)
(XXX9793390) 1363
Total No of Calls 1384

42. It is observed that Sanjay Taparia, either himself or through his employee Rahul
Saraf, was executing the NPI-based trades, on the instructions of Ketan Parekh,
in the trading accounts of GRD Securities Limited and Damanis as explained
below.

43. Trading in the proprietary trading account of GRD Securities Limited -

GRD Securities Limited had installed its trading terminal on the computer
system of Sanjay Taparia at his office premises. The login credentials of the

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 proprietary trading account of GRD Securities Limited was available with Sanjay
Taparia and Rahul Saraf (his employee) and they used to place various trades
through this account, as per the instructions received from Ketan Parekh on the
WhatsApp group “Jack-ST”.

44. The aforesaid details have been confirmed with the help of the IP address and
Machine IDs gathered from connection logs of the trades and from the systems
of Sanjay Taparia. An analysis with respect to the mode of placement of the
NPI-based trades in trading accounts of GRD Securities Limited revealed the
following:
i Some of the NPI-based trades were executed in the proprietary trading
account of the GRD Securities. To identify the locations/people who were
executing these trades, connection logs4 from the GRD Securities Limited
were sought and analysed.
ii The aforesaid data was examined against the data so obtained from the
analysis of computer systems found during the search and seizure
operations at premises of Sanjay Taparia. Upon analysis following is
observed:

Table no. 9
Placement of orders in the trading account of GRD Securities Limited
CTCL Id Trader Name Period MAC Id Details matched with
(of GRD physical inspection at the
Securities) time of search and seizure
700020002078 Shreya June 16, 30-9C-23- Physical computer system
Mehrotra 2021 - 0E-5A-57 found in the office of Sanjay
June 21, Taparia
2023

4
Connection logs contains data pertaining to Terminal Id, MAC Ids and IP Addresses. A Media Access Control
Id (MAC Id) is a hardware identifier that uniquely identifies each device on a network.

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 CTCL Id Trader Name Period MAC Id Details matched with
(of GRD physical inspection at the
Securities) time of search and seizure
January 6- A4-AE-12-
7, 2022 7B-77-EF
700020002063 Priya Saraf June 1, 02-55-00- Physical computer system not
2021 - 30-31-39 found in the offices of GRD
June 16, Securities Limited or Sanjay
2021 Taparia
June 17, A4-AE-12- Physical computer system
2021 - 7B-77-EF found in the office of Sanjay
July 27, Taparia
2022
August 30, 30-9C-23- Physical computer system not
2022 - 82-F7-AD found in the offices of GRD
November Securities Limited or Sanjay
30, 2022 Taparia
December 00-0C-29- Virtual Machine5 (VM)
06, 2022 - 3F-7D-B1 installed in the server of GRD
June 21, Securities Limited and access
2023 found in the computer system
placed in the office of Sanjay
Taparia

5
Virtual Machine (VM) is a software computer which like a physical computer runs an operating system and
applications. However, unlike a physical system, a VM is created within a software environment called a
hypervisor. The hypervisor manages the physical resources of the host computer and allocates them to the VMs.
This allows multiple VMs to run on a single physical computer and each VM can run a different operating
system.
A Virtual Machine can be used to run a Virtual Private Server (VPS). A VPS is a remote server which is
dedicated to a particular use, which in the current case can be for trading. This can be useful if there is a need
to have a reliable and high performance trading platform or if there is a requirement to be able to trade from
anywhere in the world.
Some of the benefits of using VMs for trading are:
 Reduced latency: VMs can be located close to the exchanges, which can reduce the latency of order
execution.
 Increased reliability: VMs are less likely to experience downtime than physical servers.
 Scalability: VMs can be easily scaled up or down to meet the needs of trading operation.
 Security: VMs can be isolated from each other and from the host computer, which can improve security.
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 CTCL Id Trader Name Period MAC Id Details matched with
(of GRD physical inspection at the
Securities) time of search and seizure
November 30-9C-23- Physical computer system
Ram Kumar 11, 2022- 9B-89-52 found in the office of Sanjay
700020002752
Dargar December Taparia
08, 2022

iii In addition to the above, in his statement dated June 23, 2023, Sanjay Taparia
has accepted the fact that GRD Securities Limited had lent him three CTCL
IDs through which he used to execute trades for Ketan Parekh in the
proprietary trading account of GRD Securities Limited.

iv Hence, from above, it can be inferred that Sanjay Taparia used 3 CTCL Ids
viz. ‘700020002078’, ‘700020002752’ and ‘700020002063’ of GRD Securities,
registered in the names of Shreya Mehrotra, Ram Kumar Dargar and Priya
Saraf, respectively.

v It is important to note that GRD Securities had lent its CTCL IDs to Sanjay
Taparia, however, he is not an Authorised Person of GRD Securities. Further,
these trading terminals were used from the office premises of Sanjay Taparia
i.e. outside of the office premises of GRD Securities.

45. Trading in the personal accounts of the Damanis – Anirudh Damani and
Ashok Kumar Damani used to receive trade related instructions from Sanjay
Taparia or from Rahul Saraf (under instructions from Sanjay Taparia), over calls
and these NPI-based trades were executed by Damanis themselves through
internet based trading from their residential premises. This has been confirmed
by both Sanjay Taparia and the Damanis in the statements made by them to
SEBI under oath as reproduced below:

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 Excerpts from statement of Sanjay Taparia recorded on June
22 and June 23, 2023
“Q19 Whether you have passed on the information received by you from
Ketan Parekh to anyone else?
A19 Yes, when instructions were given to me by Ketan Parekh to execute trades
and if I was not able to trade the same in account of GRD because of shortage of
margin/ money, I used to tell Anirudh Damani or Ashok Damani to execute the
said trades.

Q20 Whether Anirudh Damani or Ashok Damani were aware that the trades
were placed on the instructions of Ketan Parekh?
A20 No, they didn't know that the trades I told them to execute were on behalf of
Ketan Parekh. I did not tell them and nor they asked for the same.

Q22 What is the arrangement with Ashok and Anirudh Damani, with respect
to the trades executed by them in their accounts on your instructions?
A22 My arrangement with Ashok and Anirudh Damani is for placing intra-
day and delivery-based trades, on my behalf or on behalf of my friends/clients, in
their individual accounts. Damanis charge me brokerage of around 0.03% for
intra-day trades and 0.3% for delivery-based trades.”

Excerpts from statement of Anirudh Damani recorded on June

22, 2023

“Q1. We have observed some very specifically timed suspicious intra-day

trades in your account which generated significant profits. Do you get
specific information/instruction from someone for executing such trades?
E.g. 27-0ct-2022 trades in scrip of VBL, 22-Jan-2022 in Jamna Auto etc. Even
recently, such suspicious trades in scrip of Deepak Fertilizers Ltd were
executed by you on June 07, 2023.
I get instructions from Sanjay Taparia to execute such suspicious trades and
above mentioned trades were also based upon the instructions from him.

Q2. Were you regularly executing such suspicious trades on instruction of

Sanjay Taparia?

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 I was getting instructions to execute similar suspicious trades on regular basis
from Sanjay Taparia. I used to sometimes execute less / more / equal quantity of
shares as instructed by Sanjay Taparia.

Q3. How were the profits earned in such trades shared with Sanjay Taparia?
The profits earned were shared from time to time with Sanjay Taparia in cash as
per his instructions. But pursuant to today’s interaction, I shall not be sharing any
profits with Sanjay Taparia in future and the entire profits from the aforementioned
trade and similar such suspicious trades where profits haven't yet been shared
by me, shall be retained by me. Also, I shall not follow any such instructions to
execute suspicious trades in future.

Q4. Do you know from where Sanjay Taparia gets such prior information for
executing suspicious trades which he passes on to you?
No, I don't know.

Q5. Do you happen to know Ketan Parekh? (whom SEBI has debarred from
the Stock Markets in regards to various violations related to Securities
Markets. Photo of the Ketan Parekh, as available on Internet is placed
below, confirm).
I have heard about him in the news but I do not personally know Ketan Parekh.”

46. Further, the NPI-based trading can also be established with the help of following
illustration:
i On November 11, 2022, 2 funds of the Big Client sold 52.5 lakh shares in the
scrip PB Fintech (Policy Bazaar). It was seen that GRD Securities Limited
(FR1), Salasar Stock Broking Limited (FR2) and Anirudh Damani (FR3) have
matched their trades with the Big Client for 20.61 lakh shares.

ii The screenshot of a message in the WhatsApp group Jack-ST, where Ketan

Parekh, at around 11:15 am, is seen to be giving instructions about covering
the short quantity on BSE at INR 384.50. At 11:16 am, Sanjay Taparia
confirms that 5.58 lakh shares have been bought. The said screenshot is
reproduced below:
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 Figure no. 4
Screenshot of a message in the WhatsApp group “Jack-ST”

iii From analysis of trade log (illustrated below) following pattern of buying by
FR1 and 3 is observed:
Table no. 10
Pattern of buying by FR1 and FR3 on November 11, 2022
Average
Count Trade Trade
Buy/ Sum of Trade Price Match
Particulars of Start End
Sell Trade Qty Range (in Vol.
Orders Time Time
INR)
FR3 Buy 7 09:20:50 10:01:53 20,000 380.76 -
FR1 Buy 5 11:15:54 11:16:20 4,08,531 384.50 4,08,529
FR3 Buy 2 11:15:51 11:16:42 1,30,000 384.50 1,29,998
BC Sell 11 11:14:32 11:16:27 25,00,000 384.50 5,38,527

iv From the table, it can be seen that between 11:15-11:16 am, FR1 bought 4.08
lakhs shares and FR3 bought 1.3 lakh shares, and around 100% of their buy
order matched with the sell order of the Big Client. Further, FR3 had already
bought a quantity of 20,000 shares in the morning. Thus, the total buy by FR1
and FR3, as confirmed by Sanjay Taparia, in the group Jack- ST, was of
around 5.58 lakhs.

v This illustrates that the trading instructions were passed on by Sanjay Taparia
to Damanis and the same has also been confessed by both of them in their
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 statements. Further, based on these instructions, trades were carried out by
Damanis.

D.4 Flow of NPI-based trading instructions from Ketan Parekh to Salasar Stock
Broking Limited

47. The NPI-based trades, which were executed in the proprietary trading account
of Salasar Stock Broking Limited were undertaken on the instructions of Ketan
Parekh. These instructions were given on the WhatsApp group named “Jack-
Saro”, in which Shyam Rajkumar Saraogi, Director of Salasar Stock Broking
Limited and Sumit Sonthalia, son of Kiran Sonthalia the Director of Salasar
Stock Broking Limited, were members.

48. Sumit Sonthalia was also working for Salasar Stock Broking Limited as a trader.
Further, an office phone named “Sam”, phone number “XXX7733697” was also
part of the aforesaid WhatsApp group. A sample snapshot of the WhatsApp
chat showing the instructions given by Ketan Parekh in the group “Jack-Saro”
is placed below:
Figure no. 5
Screenshot of a message in the WhatsApp group “Jack-Saro”

49. The details of the members of the WhatsApp group “Jack-Saro”, as found from
the WhatsApp back-up of Sumit Sonthalia, retrieved from his Google drive, is
given in the table below:

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 Table no. 11
Details of the members of the WhatsApp group “Jack-Saro”
Names as
Details as per the
provided by
Customer
Names from devices Sumit
Sr. Acquisition Form
Mobile No. found during Search Sonthalia
No. (CAF) of Telecom
and Seizure during
Service Providers
search and
(TSPs)
seizure
Jack New M/JACK/Jack Kadiya
1. XXX8527607 Ketan Parekh
Latest. New/K Chhaganbhai
Surendra
2. XXX6308049 680A/Akash New Doesn’t know Subhashchandra
Pandey
Surendra
3. XXX6436048 680H/ Harit Doesn’t know Subhashchandra
Pandey
Surendra
4. XXX9978591 Maverick/Kartik Ji/Kar Doesn’t know Subhashchandra
Pandey
Mobile kept in
office for
5. XXX7733697 Sam Sekh Sukuir
trading
purpose
Surendra
Sagar/680Ko/Kau.New/Sa
6. XXX6123307 Sagar Subhashchandra
hil
Pandey
Sumit Sonthalia/Sumeet Sumit
7. XXX0266666 Sumit Sonthalia
Sonthalia/Sumit Sonthalia
Shyam
8. XXX0460230 Shyam/Shyam Saraogi Priya Saraogi
Saraogi

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50. The instructions with respect to the NPI-based trades were received from Ketan
Parekh (Jack) in the aforesaid WhatsApp group and thereafter a trader of
Salasar Stock Broking Limited, including Sumit Sonthalia (one of the traders)
and Shyam Rajkumar Saraogi (Director of Salasar Stock Broking Limited and
one of its trader), who had access to the office phone named “Sam”, used to
execute the NPI-based trades in the proprietary trading account of Salasar
Stock Broking Limited.

51. The details of the CTCL Id and MAC Id, through which the NPI-based trades
were executed in the proprietary trading account of Salasar Stock Broking
Limited, are provided in the table below:

Table no. 12
Placement of orders in the prop account of Salasar Stock Broking Limited
CTCL Id Trader Name (of Period MAC Id Details Matched with
Salasar Stock
Broking
Limited)
700001002002 Pradeep Kumar Jan 01, 18-C0- Physical computer
Saraogi 2021 - 4D-B0- system found in the
June 21, E9-78 office of Salasar Stock
2023 Broking Limited

52. The aforesaid evidence prima facie establishes that the NPI-based trades were
placed from the trading terminals present in the office of Salasar Stock Broking
Limited.

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D.5 Flow of NPI-based trading instructions from Ketan Parekh to APR Properties
Private Limited and Basukinath Properties Private Limited

53. Ashok Kumar Poddar was a close associate of Ketan Parekh and has known
him since 1990s. He was a Kolkata based broker and used to provide broking
services to Ketan Parekh for which he was also debarred from the securities
market along with Ketan Parekh in the infamous stock market scam of 2001.

54. In the statement made by Ashok Kumar Poddar, it is stated that Ketan Parekh
used to provide trade related instructions to Ashok Kumar Poddar over
WhatsApp call and messages. Thereafter, Ashok Kumar Poddar used to
communicate the same to his son, Rachit Poddar. As per the instructions
received, Rachit Poddar used to execute the trades in the trading accounts of
APR Properties Private Limited and Basukinath Properties Private Limited
respectively, through the systems placed at their residence.

55. The analysis of CDR indicates that Ashok Kumar Poddar had frequent
interactions with Ketan Parekh and his brother Kartik Parekh. During the period
between November 2021 – June 2023, Ashok Kumar Poddar had 48 calls with
Ketan Parekh on 6 of his numbers and 14 calls with Kartik Parekh (brother of
Ketan Parekh). The table below shows the details:
Table no. 13
Details from CDR of Ashok Kumar Poddar
Calls of Ashok Kumar Poddar with Mobile number No. of calls
XXX2522726 10
XXX2928015 15
XXX5555484 12
Ketan Parekh
XXX8527607 4
XXX0308243 6
XXX7623119 1
Kartik Parekh XXX0657217 14

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 Calls of Ashok Kumar Poddar with Mobile number No. of calls
Total No. of calls 62

56. Thus, NPI-based trades were executed in the trading accounts of APR
Properties Private Limited and Basukinath Properties Private Limited from the
computer devices found at the residential premises of Ashok Kumar Poddar
and Rachit Poddar.

57. Based on the aforesaid facts, it is found that Ketan Parekh was executing NPI-
based trades through accounts of the six FRs and a diagrammatic
representation showing the flow of communication from Ketan Parekh to FRs
for execution through their trading accounts is depicted below:

Figure no. 6
Flow of NPI-based trading instructions from Ketan Parekh to FRs

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 E. COMPARISON OF TRADING VOLUME AND PROFITS OF FRS

58. The outcome of the investigation in the present matter indicates that the trading
volumes and profits made in the accounts of the FRs, namely, Salasar Stock
Broking Limited, GRD Securities Limited, APR Properties Private Limited,
Basukinath Properties Private Limited, Anirudh Damani and Ashok Kumar
Damani rose significantly during the Investigation Period as compared to the
pre-investigation period, except in the case of GRD Securities Limited due to
the fact that GRD Securities Limited had lent only three out of its two hundred
twenty-six proprietary trading terminals to Sanjay Taparia who was executing
trades through the said terminals.

59. The details of trades executed by FRs, demonstrating substantial increase in

the trading volumes and profits during the Investigation Period (30 months) as
compared to the pre-investigation period (30 months), are provided in the
following table:
Table no. 14
Details of trades executed by FRs before and during the Investigation Period

Pre - Investigation Period (from 01-Jul-18 to 31- Investigation Period (from 01-Jan-21 to 20-Jun-23)
Dec-20)
Derivativ Derivativ
Equity Equity Derivatives Equity Equity Derivatives
es es

Gross Gross Intra Intra Intra Intrada Gross Gross Intra Intrada Intra Intrada
Noticee
Trade Trade Day day Day y Trade Trade Day y Day y
Value Value scrip profit contra profit Value Value scrip profit contract profit
(in (in days (in ct (in (in (in days (in days (in
lakh) lakh) lak days lakh lakh) lakh) lakh lakh
h) ) ) )
GRD Securities
25,58,270 1,23,69,000 1,82,394 802 91,839 3,287 32,56,882 1,95,25,940 82,334 730 1,10,684 3,254
Ltd

Salasar Stock
2,26,890 25,44,920 702 208 5,333 342 15,18,987 25,072 2,736 1,353 5,948 -188
Broking Limited

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 Pre - Investigation Period (from 01-Jul-18 to 31- Investigation Period (from 01-Jan-21 to 20-Jun-23)
Dec-20)
Derivativ Derivativ
Equity Equity Derivatives Equity Equity Derivatives
es es
Gross Gross Intra Intra Intra Intrada Gross Gross Intra Intrada Intra Intrada
Noticee
Trade Trade Day day Day y Trade Trade Day y Day y
Value Value scrip profit contra profit Value Value scrip profit contract profit
(in (in days (in ct (in (in (in days (in days (in
lakh) lakh) lak days lakh lakh) lakh) lakh lakh
h) ) ) )
Ashok Kumar
3,679 3,584 13 0 2 0 1,33,829 1,12,948 130 57 106 169
Damani

Anirudh Damani 2,88,151 3,07,763 587 90 721 -183 9,75,738 1,61,344 502 598 306 69

APR Properties
6 103 1 0 1 -1 5,17,273 10,04,759 97 233 158 1,383
Private Limited

Basukinath
Properties Private 932 22,774 11 -1 137 3 11,74,759 9,67,642 214 544 544 -216
Ltd

60. From the aforesaid table, it is noted that more than 98% of the trades
undertaken by FRs, in terms of trade value, were done in cash markets. Further,
around 97% of the total profit earned through FR trades was made through cash
market trades alone.

61. Further, the trading profiles of each FR has been juxtaposed with the trading
profile of the Big Client during the Investigation Period to understand the
correlation between their trades. The trading profile of each FR has been
provided in the tabular format below:

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 i Trading profile of Salasar Stock Broking Limited (FR2)

Table no. 15
Trading profile of Salasar Stock Broking Limited (FR 2)
Equity Segment Equity Derivative Segment
Avera
ge
Squa
Gros
re off Average
Gross s Square
earne Gross Gross
No of Traded Trade No of off
Calend d Calend Traded Traded
instan Value d instance earned
ar days (INR ar days Value (INR Value
ces (INR In Value s (INR In
In In lakhs) (INR In
lakhs) (INR lakhs)
lakhs lakhs)
In
)
lakhs
)
No of Scrip days/Contract
616 15,18,987 124 1,400 616 19,508 22,04,394 113 -3,385
days traded 12,219
Common Scrip days/Contract
259 364 11,94,196 3,281 1,048 264 443 1,17,511 265 105
days with the Big Clients
No of Other Non-Common
Scrip days/Contract days with 616 3,24,792 27 352 616 19,065 20,86,883 109 -3,490
11,855
the Big Clients
No of Scrip days/Contract
days wherein day trading
586 2,735 13,36,507 489 1,350 609 5,948 8,78,755 148 -188
(80% squared off) has been
carried out
No of Scrip days/Contract
days wherein day traded
(80% squared off) and 245 340 11,92,684 3,508 1,047 115 138 51,371 372 63
commonly traded with the Big
Clients
Instances where client
earned a positive square off
difference of INR 1 or more
when day traded (80%
squared off) and commonly 175 218 9,65,520 4,429 1,241 4 4 5,265 1,316 4
traded with the Big Clients
and there is matched quantity
between big client and any of
the FRs

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62. From the table above, it is seen that:
i in the cash market, Salasar Stock Broking Limited earned a square off profit
of INR 13.50 crores from the trades wherein day trading (80% squared off)
was carried out. Among such trades, Salasar Stock Broking Limited earned
a square off profit of INR 12.41 crores from such trades where Salasar
Stock Broking Limited earned a square off difference of INR 1 or more and
where matching in that scrip, on that day, was seen between the Big Client
and any of the FRs. This shows that significant profits of Salasar Stock
Broking Limited have come from trades based on NPI.
ii Further, the number of instances of trades based on NPI is around 8% i.e.
218 instances out of 2,735 instances of day trading instances. However,
the Gross traded value (GTV) of such instances of NPI based trades (INR
9,655 crores) is around 72% of the GTV of day trading instances (INR
13,365 crores).
iii Additionally, the average GTV of the instances of NPI based trades was
observed to be around INR 44 crores, which is almost 9 times of the
average GTV of day trading instances (INR 4.9 crores).

63. The aforesaid trading profile illustrates that the NPI based trades had
substantially high trading size/concentration and have yielded substantial
unlawful profits for the Salasar Stock Broking Limited. Similarly, the tabular
representation of trading profile for other FRs is provided below:

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 ii Trading profile of GRD Securities Limited (FR1)

Table no. 16
Trading profile of GRD Securities Limited (FR1)
Equity Segment Equity Derivative Segment
Avera
Squa
ge
re off Average
Gross Gross Square
earn Gross Gross
Calen No of Traded Trade off
ed Calend No of Traded Traded
dar instanc Value d earned
(INR ar days instances Value (INR Value
days es (INR In Value (INR In
In In lakhs) (INR In
lakhs) (INR lakhs)
lakhs lakhs)
In
)
lakhs)
No of Scrip days/Contract
618 32,56,882 28 930 618 3,43,816 1,91,07,410 56 8,279
days traded 1,16,602
Common Scrip
days/Contract days with the 440 950 9,23,692 972 142 498 5,980 6,26,045 105 133
Big Clients
No of Other Non-Common
Scrip days/Contract days 618 23,33,189 20 788 618 3,37,836 1,84,81,364 55 8,146
1,15,652
with the Big Clients
No of Scrip days/Contract
days wherein day trading
618 82,482 27,24,178 33 711 618 1,09,028 76,44,501 70 2,368
(80% squared off) has
been carried out
No of Scrip days/Contract
days wherein day traded
(80% squared off) and 388 714 9,03,555 1,265 149 358 1,318 2,33,103 177 169
commonly traded with the
Big Clients
Instances where client
earned a positive square
off difference of INR 1 or
more when day traded
(80% squared off) and 85 97 4,79,944 4,948 560 26 26 16,955 652 41
commonly traded with the
Big Clients and there is
matched quantity between
big client and any of the FRs

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 iii Trading profile of Anirudh Damani (FR 3)

Table no. 17
Trading profile of Anirudh Damani (FR 3)
Equity Segment Equity Derivative Segment
Avera
ge
Averag
Gross Gross Squar Squar
Gross e Gross
No of Traded Trade e off No of e off
Calenda Calenda Traded Traded
instance Value d earned insta earned
r days r days Value (INR Value
s (INR In Value (INR In nces (INR In
In lakhs) (INR In
lakhs) (INR lakhs) lakhs)
lakhs)
In
lakhs)
No of Scrip days/Contract days
616 5,974 9,75,738 163 668 561 3,894 1,61,344 41 -33
traded
Common Scrip days/Contract
85 103 4,94,154 4,798 382 37 44 10,191 232 0
days with the Big Clients
No of Other Non-Common Scrip
days/Contract days with the Big 616 5,871 4,81,584 82 286 561 3,850 1,51,153 39 -33
Clients
No of Scrip days/Contract days
wherein day trading (80%
317 492 5,49,185 1,116 598 196 306 15,135 49 69
squared off) has been carried
out
No of Scrip days/Contract days
wherein day traded (80%
58 68 4,64,735 6,834 400 3 3 56 19 0
squared off) and commonly
traded with the Big Clients
Instances where client earned a
positive square off difference of
INR 1 or more when day traded
(80% squared off) and
43 46 3,73,960 8,130 486 - - - - -
commonly traded with the Big
Clients and there is matched
quantity between big client and
any of the FRs

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 iv Trading profile of Ashok Kumar Damani (FR4)

Table no. 18
Trading profile of Ashok Kumar Damani (FR4)
Equity Segment Equity Derivative Segment
Avera
ge
Averag
Gross Gross Squar Gross Squar
e Gross
No of Traded Trade e off No of Traded e off
Calenda Calenda Traded
instance Value d earned instanc Value earned
r days r days Value
s (INR In Value (INR In es (INR In (INR In
(INR In
lakhs) (INR lakhs) lakhs) lakhs)
lakhs)
In
lakhs)
No of Scrip days/Contract days
565 2,566 1,33,829 52 112 378 1,308 1,12,948 86 174
traded
Common Scrip days/Contract days
13 13 32,689 2,515 0 14 17 10,498 618 4
with the Big Clients
No of Other Non-Common Scrip
days/Contract days with the Big 565 2,553 1,01,140 40 112 378 1,291 1,02,450 79 171
Clients
No of Scrip days/Contract days
wherein day trading (80% squared 109 126 37,333 296 57 79 106 31,960 302 169
off) has been carried out
No of Scrip days/Contract days
wherein day traded (80% squared
5 5 23,630 4,726 5 1 1 4,675 4,675 4
off) and commonly traded with the
Big Clients
Instances where client earned a
positive square off difference of
INR 1 or more when day traded
(80% squared off) and commonly 3 3 20,332 6,777 17 - - - - -
traded with the Big Clients and
there is matched quantity between
big client and any of the FRs

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 v Trading profile of Basukinath Properties Pvt Limited (FR5)

Table no. 19
Trading profile of Basukinath Properties Private Limited (FR5)
Equity Segment Equity Derivative Segment
Avera
ge
Squar Average
Gross Square
Gross e off Cale Gross Gross
No of Trade off
Calend Traded earne ndar No of Traded Traded
instanc d earned
ar days Value (INR d (INR day instances Value (INR Value
es Value (INR In
In lakhs) In s In lakhs) (INR In
(INR lakhs)
lakhs) lakhs)
In
lakhs)
No of Scrip days/Contract
433 865 11,74,759 1,358 551 461 1,915 9,67,642 505 16
days traded
Common Scrip
days/Contract days with 86 121 11,02,310 9,110 508 74 90 62,048 689 34
the Big Clients
No of Other Non-
Common Scrip
404 744 72,449 97 44 453 1,825 9,05,595 496 -18
days/Contract days with
the Big Clients
No of Scrip days/Contract
days wherein day trading
146 214 11,39,006 5,322 544 176 260 2,34,748 903 -216
(80% squared off) has
been carried out
No of Scrip days/Contract
days wherein day traded
(80% squared off) and 85 120 11,02,310 9,186 508 21 23 26,694 1,161 -9
commonly traded with the
Big Clients
Instances where client
earned a positive square
off difference of INR 1 or
more when day traded
(80% squared off) and
64 81 9,21,049 1,030 9 10 10,384 1,038 38
commonly traded with the 11,371
Big Clients and there is
matched quantity between
big client and any of the
FRs

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 vi Trading profile of APR Properties Pvt Limited (FR6)

Table no. 20
Trading profile of APR Properties Private Limited (FR6)
Equity Segment Equity Derivative Segment
Avera Squar
ge e off Average
No Gross Square
Gross earne Gross Gross
of Traded off
Calend Trade d Calend No of Traded Traded
inst Value earned
ar days d (INR ar days instances Value (INR Value
anc (INR In (INR In
Value In In lakhs) (INR In
es lakhs) lakhs)
(INR In lakhs lakhs)
lakhs) )
No of Scrip days/Contract
239 428 5,17,273 1,209 242 398 1,539 10,04,759 653 729
days traded
Common Scrip
days/Contract days with the 41 55 4,50,576 8,192 168 89 110 69,087 628 70
Big Clients
No of Other Non-Common
Scrip days/Contract days 225 373 66,697 179 74 385 1,429 9,35,672 655 659
with the Big Clients
No of Scrip days/Contract
days wherein day trading
69 97 4,97,978 5,134 233 122 158 1,64,600 1,042 1,383
(80% squared off) has been
carried out
No of Scrip days/Contract
days wherein day traded
(80% squared off) and 40 54 4,50,575 8,344 168 19 20 17,138 857 62
commonly traded with the
Big Clients
Instances where client
earned a positive square off
difference of INR 1 or more
when day traded (80%
squared off) and commonly 28 35 2,77,932 7,941 407 7 7 8,591 1,227 46
traded with the Big Clients
and there is matched
quantity between big client
and any of the FRs

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 64. From the tables above, it can be observed that FRs have earned significant
profits through day trading majorly on common scrip day instances matching
with the Big Client.

F. ROLE OF ROHIT SALGAOCAR IN OBTAINING AND SHARING NPI

65. The investigation revealed that although trades of the Big Client in India were
spread across a large number of TMs, the trades executed through Motilal and
Nuvama resulted in the maximum instances of NPI based trades. As per the
data obtained from the Big Client, it was seen that the Big Client had traded
through 29 Trading Members during the Investigation Period and around 5.2%
and 9.1% of trades of the Big Client in the Indian equity markets was made
through Motilal and Nuvama, respectively. During the search and seizure
operation at the premises of traders of the aforesaid TMs, it was found that they
used to execute trades for Big Client based on the instructions of Rohit
Salgaocar even though he was not the authorised representative of the Big
Client.

66. Further, Rohit Salgaocar used to operate through a corporate entity called Strait
Crossing Pte Limited (SCPL) which was incorporated on March 15, 2016 and
registered with Accounting and Corporate Regulatory Authority (ACRA) of
Singapore. The Unique Entity Number (UEN) of SCPL is “201606768H” and its
registered office address, as stated by Rohit Salgaocar, is “1 Harbourfront Place
#03-11 Harbourfront Tower One Singapore (098633)”. The primary activity of
SCPL is “Other Activities Auxiliary to Financial Service Activities N.E.C. (e.g.
Mortgage Advisory Firms).

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F.1 Arrangement between SCPL/Rohit Salgaocar and the Big Client

67. In its submission dated October 26, 2023, the Big Client stated that it did not
have any agreement with SCPL or Rohit Salgaocar. However, traders of the
Big Client, who knew Rohit Salgaocar, engaged with him while trading with
respect to securities listed in India. The trade related conversation between
Rohit Salgaocar and traders of the Big Client used to happen over Bloomberg
chats and calls. In their statements, the traders have stated that Big Client was
aware of the dealings with Rohit Salgaocar.

68. Upon analysis of the Bloomberg chats between traders of the Big Client and
Rohit Salgaocar, it was found that traders of the Big Client and Rohit Salgaocar
had frequent discussions with respect to trades in various scrips. There were
occasions where the Big Client trader would provide Rohit Salgaocar with the
quantum of trade and/or price at which they wanted to do certain trades in a
scrip. The illustrations pertaining to the same are provided in Part G of this
order.

69. Subsequently, the trader of the Big Client would provide the confirmation of
going ahead with the trade and on a majority of instances, Rohit Salgaocar
would ask trader of the Big Client to send the deal ticket to Motilal or Nuvama.
The illustrations pertaining to the same are provided in Part G of this order.

70. Two traders of the Big Client namely, BCTrader1 and BCTrader26, were
primarily responsible for trading securities listed in Indian markets on behalf of
the Big Client and they handled 90% of the total value of the trades of Big Client
referred to Motilal or Nuvama during the Investigation Period. In their statement
made to SEBI, BCTrader1 and BCTrader2, stated that they would interact with

6
Note: Name of the traders of the Big Client have not been used and would be supplied to Noticees during
inspection of documents and to Hon’ble SAT and Courts during court proceedings. Apart from these traders two
other traders of Big Client, namely BCTrader3 and BCTrader4 have also been mentioned in this order.
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 various entities including Rohit Salgaocar for facilitating trades in Indian
markets and that as per their understanding while the Big Client did not
compensate Rohit Salgaocar, the Indian brokers compensated Rohit Salgaocar
for his services. The relevant extracts from the statements of BCTrader2
recorded on May 28-30, 2024 at the office of the Big Client (Singapore) are
reproduced below:
“Q 18. How do you identify the broker for your trade?
Reply — There are multiple factors I take into account for a broker selection. These
may include maintaining continuity with a broker, who had earlier executed trade for
us in that equity security of the company, brokers who were involved in the company's
IPO, brokers who would have shown us their flows in certain companies which we are
interested in. One of the reasons for limiting the number of brokers that receive our
indications is to mitigate information leakage.

Q 19. Do you interact with anyone other than Trading Members (Brokers)
registered with SEBI for the execution of your trades/facilitating execution of
your trades?
Reply — Yes, in addition to Indian brokers, I also used to interact with Mr. Rohit
Salgaocar as someone who can source liquidity and help find the other side of the
trade in the Indian market.

Q 27. Do you have any formal arrangement/contract with Rohit Salgaocar?

Reply — No, I do not have any arrangement or contract with Rohit Salgaocar.

Q 28. Does Big Client have any formal arrangement/contract with Rohit
Salgaocar, for availing his services?
Reply — As per my knowledge, there is no formal arrangement/contract between Big
Client and Rohit Salgaocar.

Q 29. Does Big Client pay any remuneration/fees/commission to Rohit

Salgaocar for facilitating the trades?
Reply — No, Big Client does not pay any remuneration/fees/commission to Rohit
Salgaocar.

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 Q 30. Why was Rohit Salgaocar providing you with his services for helping you
in executing Big Client trades?
Reply —As per my knowledge, Rohit Salgaocar has agreements with various brokers
that have been approved by Big Client for trade execution. I am not sure about the
terms of the agreements but these brokers might have had a commission sharing
arrangement with him or his firm Strait Crossing Pte Ltd.

Q 31. Is Big Client aware about your dealing with Rohit Salgaocar?
Reply — Yes, Big Client is aware about my dealing with Rohit Salgaocar. The former
regional manager of trading and former global head of trading knew about this.
However, I do not know when they were first informed about this.

Q 32. Do you have arrangement with any other entity/person, like what you have
with Rohit Salgaocar? Is there any other arrangement like Rohit in or outside
India?
Reply — For India, no. For markets outside India, I do not recall.”

71. From the Bloomberg chats between traders of the Big Client and Rohit
Salgaocar, it is seen that the positions to be taken by the Big Client in various
scrips during the Investigation Period were discussed. Various illustrations of
the same are provided in Part G of this order. Further, the Bloomberg chats
reveal that Rohit Salgaocar and traders of the Big Client also used to discuss
trade related information with each other over calls.

Table no. 21
Extract of Bloomberg chat between Rohit Salgaocar and Trader of Big
Client
Time From Message
Bloomberg chat on January 05, 2022
11:38:54 BCTrader1- Big Client I need some shares
11:38:56 Rohit Salgaocar - Strait Crossing Till 1:30pm delivery 259k
11:39:07 Rohit Salgaocar - Strait Crossing calling

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 Time From Message
Bloomberg chat on January 06, 2022
sure or if something comes
BCTrader2 – Big Client
09:00:22 up then call BCTrader4
Will do, you have the algo set
Rohit Salgaocar - Strait Crossing
09:01:03 in BHARTI right?
Bloomberg chat on January 18, 2022
10:13:04 BCTrader2 – Big Client yo call me
10:13:13 Rohit Salgaocar - Strait Crossing calling
Bloomberg chat on October 07, 2022
Hi BCTrader1 please let me
Rohit Salgaocar - Strait Crossing
08:36:00 know when free
12:17:44 BCTrader1- Big Client Free house yo
12:18:08 Rohit Salgaocar - Strait Crossing Calling
14:02:22 BCTrader1- Big Client 1mn 876 if ever ICICI Bank
14:02:23 BCTrader1- Big Client can do
14:56:58 BCTrader1- Big Client closing up

72. Thus, Rohit Salgaocar used to obtain NPI through Bloomberg chats as well as
through phone calls from the trader of the Big Client and had clear visibility of
the quantum of buying/selling that the Big Client was about to undertake.

73. Rohit Salgaocar, in his statement dated March 7, 2024 and July 22, 2024,
stated that he used to help the Big Client find counterparties for their trades in
the Indian securities market, functioning as an Inter-Trader Broker. Further,
most of his revenues, almost 90%, were from the Big Client trades in Indian
Securities Market. He had no agreement with the Big Client for his services and
had commission sharing agreements with the Indian TMs viz. Motilal, Nuvama
etc. As per the agreements, the brokers would give him 75% of the net
brokerage income after excluding costs from the trades of the Big Client. He
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 further stated that since 2021, he had routed 90% of the Big Client trades
through Nuvama and Motilal. The relevant extracts from the statement of Rohit
Salgaocar is reproduced below:
“Q 21. From 2021 onwards, what is the percentage of Big Client’s trades that
were routed by you through Motilal and Nuvama?
Reply- Around 90%

Q 23. Explain how the trades for Big Client were executed by you?
Reply-Dealer of the Big Client provides me with the name of the stock they are
interested in. I will check the availability with different market participants including
foreign funds, Indian funds, other holders of the shares etc and lastly with Ketan
Parekh. After confirming the availability from the counterparty, I get back to the dealer
of the Big Client with the quantity and price on offer. Upon confirmation from the dealer
of the Big Client, the deal goes through. The Big Client dealer sends the deal ticket to
the broker in India. After execution of the trades, Indian broker used to confirm me on
Bloomberg chat. Sometimes, I used to get confirmation from Big Client dealers as well.

Q 27. In the reply to Q. No. 23, you have mentioned that you used to source
counterparties through Mr. Ketan Parekh. What percentage of Big Client trades
were being fulfilled by Ketan Parekh?
Reply- Around 90%”

74. In view of the aforesaid discussion, the following facts are noted:
i Traders of the Big Client and Rohit Salgaocar used to have frequent
discussions with respect to trades in various scrips through Bloomberg chat
as well as through phone calls;
ii Various illustrations of Bloomberg chats, as provided in Part G of this order,
will show that Rohit Salgaocar had clear visibility of the name of the scrip,
quantum of buying/selling and the timing of execution of the trade that the
Big Client was about to undertake in such scrips;
iii Even in cases where the Bloomberg chats do not specify quantum/price of
the impending order, Rohit Salgaocar had a fair idea about the price and
quantity given his vast experience of dealing with the Big Client, owing to

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 his long standing relationship with them. He also used to speak to the
traders of Big Client over calls which enabled him to have a fair insight
about the impact of the Big Client orders on the existing demand and supply
in the market;
iv Rohit Salgaocar used to tell traders of the Big Client the name of the
particular Indian Trading Member (mostly Motilal or Nuvama), to whom the
deal ticket was to be sent for execution of trades. About 90% of trades of
Big Client traded executed by Motilal and Nuvama were referred by Rohit
Salgaocar.
v Rohit Salgaocar was discussing impending trades of the Big Client with
Ketan Parekh.

F.2 Agreements between SCPL/Rohit Salgaocar and Trading Members

75. Motilal and Nuvama had entered into a Memorandum of Understanding

(MoU)/referral agreement (hereinafter “agreement”) with a Singapore based
entity named SCPL.

76. Rohit Salgaocar, who was the only Director and the authorized signatory of
SCPL, had signed the aforesaid agreements on behalf of SCPL. The said
agreement outlined the scope of the services that SCPL would offer and the
manner of its compensation which included, inter-alia, referral of clients by
SCPL to the Motilal and Nuvama in return for a share in brokerage. The details
of the said agreements are briefly discussed in the ensuing paragraphs.

77. Details of Agreement between SCPL and Motilal: The agreement between
Motilal and SCPL, titled as “Memorandum of Understanding” (MoU) was made
on January 21, 2021, which came into effect from January 25, 2021. Para 1 of
the aforesaid MoU, provides for the scope of the arrangement between Motilal
and SCPL, which states that the role of SCPL is only limited to the extent of
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 referring individuals/entities to Motilal for transacting in all traded securities and
also initiate transactions on such securities from existing clients of Motilal.

78. Further, as per Schedule I of the said MoU, in consideration of carrying out the
referral activity, Motilal was required to pay SCPL a referral fees of 75% of the
net commission received, from the clients referred under the agreement. While
the Big Client was an existing client of Motilal, the order flow of the Big Client to
Motilal increased significantly after Motilal entered into the said agreement with
SCPL. The same is illustrated in the table below:

Table no. 22
Change in Gross Traded Value (GTV) in the order flow of the Big Client to
Motilal
%age jump in GTV
GTV GTV
Total during the
without through
GTV investigation period
Period Rohit Rohit
(in INR vis-à-vis comparable
Salgaocar Salgaocar#
cr) period just before
(in INR cr) (in INR cr)
investigation period
Jan 21- Jun
23
4,478 11,857 16,334 383.31
(Investigation
period)
Jul 18 - Dec
20
(Comparable
4,261 - 4,261
period prior to
Investigation
Period)
# - Rohit Salgaocar entered into agreement with Motilal in January 2021.

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79. Although Motilal had no written communication from the Big Client, authorising
SCPL/ Rohit Salgaocar to act on their behalf or to handle their trades, the
traders of Motilal were taking instructions from Rohit Salgaocar to execute
trades of the Big Client. During the Investigation, Motilal contended that even
though there was no written formal communication, the Big Client was aware
that Rohit Salgaocar was facilitating/managing their trades and to substantiate
the said contention, Motilal submitted a Bloomberg conversation, dated
February 1, 2021, between trader of the Big Client (BCTrader1) and trader of
Motilal, wherein BCTrader1 instructed Motilal to “order via Rohit”.

80. In view of the aforesaid discussions, following facts are noted:

i Motilal entered into an agreement with SCPL for referral of clients;
ii The Big Client was an existing client of Motilal. However, the order flow
from the Big Client to Motilal increased by 383% after entering into the
referral agreement with SCPL/Rohit Salgaocar and no client other than the
Big Client was referred by SCPL to Motilal under the aforesaid agreement.
iii SCPL was entitled for 75% referral commission on the trades of the Big
Client;
iv As the deal ticket from the Big Client was sent through the FIX system of
Bloomberg, the execution status of the trades would only reflect in the
system of the traders of the brokers and traders of the Big Client. However,
Rohit Salgaocar was able to get the updates in respect of the trade
execution through Bloomberg chats from traders of Motilal and Nuvama;
v The trades of the Big Client were being executed by traders of Motilal as
per the instructions of SCPL/ Rohit Salgaocar without there being any
written mandate from the Big Client;
vi Hence, the role of traders of Motilal and Nuvama was to punch the trades
for the Big Client and the entire control with respect to the aforesaid trades
was with Rohit Salgaocar.

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81. During the Investigation period, Motilal paid a total of INR 8,06,29,054 (around
INR 8.06 crore) as referral fee/commission to Rohit Salgaocar.

82. Details of agreement between SCPL and Nuvama: The agreement between
Nuvama and SCPL, titled as ‘Referral Agreement” was made on August 03,
2016. As per para 1.1 and 12.2 of the aforesaid referral agreement, the role of
SCPL was limited to make the referrals only and the decision to execute trade
was solely made by the Big Client and as per the agreement, SCPL was not to
be involved in the making of such decision or in the execution of a trade by such
client.

83. Further, as per Schedule 1 of the aforesaid referral agreement, in consideration

of carrying out the referral activity, Nuvama was to pay SCPL a referral fees of
75% of the net brokerage earned. During the investigation period, except for
Big Client, there was only one more client referred to Nuvama by SCPL under
the said agreement. However, the trades from Big Client constitute more than
99% of such referred trades. The table below illustrates the aforesaid
statement:

Table no. 23
Clients referred to Nuvama by SCPL during the Investigation Period

INR in Crores
GTV of trades GTV of
Clients of Nuvama involving trades
Total GTV
Rohit without Rohit
Salgaocar Salgaocar
Big Client 28,743.44 27,627.06 1,116.38
Other client 445.57 163.10 282.47
Total 29,189.01 27,790.16 1,398.85
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84. While the Big Client was an existing client of Nuvama, the order flow of the Big
Client to Nuvama increased significantly during the Investigation Period vis-à-
vis comparable period prior to the Investigation period. The same is illustrated
in the table below:

Table no. 24
Change in Gross Traded Value (GTV) in the order flow of the Big Client to
Nuvama
%age jump in
GTV during the
GTV GTV investigation
without through period vis-à-vis
Total GTV
Period Rohit Rohit comparable
(in INR cr)
Salgaocar Salgaocar period just
(in INR cr) (in INR cr) before
investigation
period
January 2021- June
2023 (Investigation 1,116 27,627 28,743 543.92
period)
July 2018 -
December 2020
(Comparable period 3,066 2,218 5,285 -
prior to Investigation
Period)

85. Although Nuvama had no written communication from the Big Client,
authorising SCPL/ Rohit Salgaocar to act on their behalf or to handle their
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 trades, the traders of Nuvama were taking instructions from Rohit Salgaocar to
execute trades of the Big Client. During the Investigation, Nuvama contended
that even though there was no written formal communication, the Big Client was
aware that Rohit Salgaocar was facilitating/managing their trades and to
substantiate the said contention, Nuvama submitted an email communication
with the Big Client, dated August 01, 2023, wherein trader of the Big Client
(BCTrader1) informed Nuvama that “yes we trust Salgaocar help us achieve
best execution as mandated by our funds, thank you for your attention to this
matter and we would like to continue on with the relationship as is”. However,
the aforesaid email was communicated after the search and seizure operation
was carried out by SEBI.

86. In view of the aforesaid discussions, following facts are noted:

i Nuvama entered into an agreement with SCPL/Rohit Salgaocar for referral
of clients;
ii The order flow from the Big Client to Nuvama increased by 543% during
the Investigation Period vis-à-vis the comparable period prior to the
Investigation Period and the quantum of gross traded value through Rohit
Salgaocar/SCPL increased by almost 12 times;
iii SCPL was entitled for 75% referral commission on the trades of the Big
Client;
iv Trades of the Big Client were being executed by traders of Nuvama as per
the instructions of SCPL/ Rohit Salgaocar without there being any written
mandate from the Big Client.

87. During the investigation period, Nuvama paid a total of INR 19,00,44,520
(around INR 19 crore) as referral fee/commission to Rohit Salgaocar.

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88. Thus, the total commission earned by Rohit Salgaocar during the investigation
period, from Motilal and Nuvama was around INR 27.06 crore which was only
in respect of the trades of the Big Client referred by SCPL/Rohit Salgaocar.

89. On analysis of the Bloomberg chats between Rohit Salgaocar and traders of
Motilal and Nuvama, as illustrated in Part G of this order, it is seen that:

i Traders of Motilal and Nuvama would update Rohit Salgaocar upon receipt
of the deal ticket (refer Bloomberg chats provided in Table no. 32).

ii Thereafter, Rohit Salgaocar would instruct traders of Motilal and Nuvama

to immediately place an order in the scrip and sometimes to also provide
them with the price and/or quantity at which such deal ticket was to be
executed. (refer Bloomberg chats provided in Table no. 32).

iii In some instances, it was observed that Rohit Salgaocar would start giving
instructions for trade even prior to the deal ticket/ order being received from
the Big Client by Motilal and Nuvama. To illustrate, on September 16, 2021,
Rohit Salgaocar instructed trader of Motilal, at 12:09:49 PM, to buy 5 lakh
Bharti Airtel at INR 725 (this order was in continuation to the buy orders
from morning that day), however, the trader of Motilal gave the confirmation
of receipt of the deal ticket at 12:10:08 PM only. The relevant extract of
Bloomberg chat between Rohit Salgaocar and Trader of Motilal is provided
below:
Table no. 25
Extract of Bloomberg chat between Rohit Salgaocar and Trader of Motilal
on September 16, 2021
Time From Message
12:09:49 Rohit Salgaocar - Strait Crossing 500k 725
12:09:53 Rohit Salgaocar - Strait Crossing Get ready

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 Time From Message
12:10:08 go the ticket I am ready on
Trader of Motilal
nse at 725
12:10:12 Rohit Salgaocar - Strait Crossing Go in
12:10:34 Trader of Motilal 477k pending
12:11:35 Trader of Motilal 137k pending
12:11:53 Rohit Salgaocar - Strait Crossing Reduce and wait
12:11:55 Trader of Motilal ok
12:16:02 Trader of Motilal 90k pending

iv After receiving trade related instructions from Rohit Salgaocar, the traders
of Motilal and Nuvama would continuously update Rohit Salgaocar about
the execution status of the trades (as seen in the table above as well as in
Part G of this order).

90. Thus, it can be seen that traders of Motilal and Nuvama were executing trades
on the instructions of Rohit Salgaocar, even though, the Big Client had never
authorised Motilal or Nuvama to take instructions from Rohit Salgaocar to
execute its trades.

91. A diagrammatic representation depicting the arrangement between TMs and

Rohit Salgaocar, arrangement between the Big Client and Rohit Salgaocar and
the flow of information regarding the Big Client is as under:

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 Figure no. 7
Flow of NPI regarding the trades of the Big Client

F.3 Misleading and false information provided by Rohit Salgaocar to traders of

the Big Client

92. Rohit Salgaocar, in his statement dated March 7, 2024 and July 22, 2024,
stated that he used to help Big Client find counterparties for its trades in the
Indian securities market. However, from the analysis of Bloomberg chats
between traders of the Big Client and Rohit Salgaocar, it has been seen that
Rohit Salgaocar used to provide false information about the identity of the
counterparties which he was in fact sourcing from Ketan Parekh. An illustration
in this respect is shown below.

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93. On December 08, 2021, BCTrader2 (trader of the Big Client) and Rohit
Salgaocar were seen to be discussing a buy trade in L&T and the Bloomberg
chat with respect to the same is placed below:

Table no. 26
Bloomberg chat between Big Client trader and Rohit Salgaocar on Dec 08, 2021

Time From Message

08:40:12 BCTrader2 – Big Client i also have LT to buy, trying not to pay above 1800
Rohit Salgaocar - Strait
08:46:06 Got it
Crossing
Rohit Salgaocar - Strait 500K LT corporate seller from treasury.... You would
10:25:23
Crossing care?
10:26:26 BCTrader2 – Big Client ok
Rohit Salgaocar - Strait
10:26:40
Crossing done
Rohit Salgaocar - Strait Insurance for 200k and local HNI for 50k.. Any care
12:17:26
Crossing total 250k
Rohit Salgaocar - Strait
12:53:41
Crossing 350k 1833
12:54:11 BCTrader2 – Big Client ok

94. As seen from the chat above, Rohit Salgaocar, at around 10:25 am offered
500K L&T saying that a corporate treasury was the seller. Thereafter, at 12:17
pm he offered 250K L&T saying that 200K was from Insurance and 50K from a
local HNI. Thereafter, he increased the offer size to 350K.

95. However, from the analysis of the trade log, it is observed that in this trade,
FR2/Salasar Stock Broking Limited and FR5/APR Properties Private Limited
matched almost 85.42% of the buy quantity of the Big Client (8,50,000 shares).
Further, both the FRs had built the long position in L&T, just prior to the entry

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 of the Big Client. Thus, it is clear that FR2 and FR5 did NPI-based trades. The
table below provides the details of the same:

Table no. 27
Summary of trades undertaken by FR2 and FR5 on December 08, 2021

Average
Sum of
Partic Buy/ Trade Start Trade Trade Price Match
Information Trade
ulars Sell Time End Time Range Vol.
Qty
(in INR)
Buy trades FR5 Buy 09:15:38 10:14:50 3,50,000 1,825.29 -
by FRs, prior
to first
FR2 Buy 10:15:38 10:20:21 11,905 1,829.06 -
matching
instance
BC Buy 10:28:45 10:28:45 5,00,000 1,833.92 -
Matching –
FR2 Sell 10:28:45 10:28:45 40,000 1,834.00 40,000
Instance 1
FR5 Sell 10:28:45 10:28:45 4,20,000 1,834.00 4,17,495
Between first FR5 Buy 10:30:45 12:20:52 2,41,578 1,831.49 -
and second FR5 Sell 12:32:49 12:35:56 1,841 1,837.00 -
matching FR2 Buy 10:54:33 11:50:44 85,838 1,830.94 -
instance FR2 Sell 12:10:06 12:14:53 7,743 1,835.66 -
BC Buy 12:55:54 12:56:10 3,07,883 1,833.00
Matching –
FR2 Sell 12:55:54 12:55:54 75,000 1,833.00 75,000
Instance 2
FR5 Sell 12:55:54 12:55:54 2,00,000 1,833.00 1,93,576
After second BC Buy 13:12:19 14:06:57 42,117 1,833.00 -
matching FR5 Buy 14:21:46 14:47:32 30,263 1,829.99 -
instance FR2 Buy 14:47:33 15:04:08 25,000 1,828.06 -

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 Table no. 28
Matching between the big client and the FRs on December 08, 2021

Buyer Name Trade Time Seller Name Trade Quantity

FR2 40,000
10:28:45
FR5 4,17,495
AXXXP7 FUND
FR2 75,000
12:55:54
FR5 1,93,576
Grand Total 7,26,071

Table no. 29
Long positions built by each of the FR during the day
Time period/FR FR2 FR5
Prior to first matching at 10:28:45 hrs 11,905 3,50,000
Between first matching at 10:28:45 hrs and second
85,838 2,41,578
matching at 12:55:54 hrs
After second matching at 12:55:54 hrs 25,000 30,263
Total 1,22,743 6,21,841

96. From the tables above, following facts are seen:

i The trades of Big Client have matched with the FRs which were arranged
by Ketan Parekh;

ii Rohit Salgaocar and Ketan Parekh, together, knowing that the Big Client
would be buying shares of L&T that day, first bought the shares through
various FRs, and subsequently squared off the positions by matching it with
the trades of the Big Client;

7
The identity of the Fund of Big Client is masked and will be revealed to the Noticees during inspection.
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 iii Rohit Salgaocar was providing false details about the counterparty to the
Big Client trader when he told him that the seller in the trade was a
corporate treasury, an insurance company and a local HNI;

iv Thus, in the garb of identifying pools of liquidity for the Big Client trade,
Rohit Salgaocar, along with Ketan Parekh, was essentially running a
scheme involving trading on the basis of the NPI about the impending
orders of the Big Client in various scrips, through the accounts of various
FRs, and profiting unduly from such trades.

97. Further, as per the statement of Rohit Salgaocar, he used to route almost 90% of the
Big Client trades through Nuvama and Motilal, from which he earned an aggregate
commission of around INR 27.06 crores. Further, 90% of these trades were being
fulfilled by Ketan Parekh alone. The commissions earned by Rohit Salgaocar could
not have been possible without the aforesaid scheme orchestrated by Rohit
Salgaocar in connivance with Ketan Parekh and therefore the gains made through
commissions by Rohit Salgaocar are also in the nature of ill-gotten gains.

G. ILLUSTRATIONS OF NPI-BASED TRADING ACTIVITIES IN THE ACCOUNTS OF

FRs

98. Trading activities in the accounts of various FRs have been examined based on
the trend of order placement by FRs which matched with the orders of the Big
Client as well as the correlation between such trades and flow of NPI between
various Noticees. In case where multiple instances of matching are observed
between FRs and Big Client on a particular day, order placement analysis is
illustrated below for a particular time patch only.

99. To illustrate that the trades carried out by FRs were in fact NPI-based trades,
following evidences have been provided in illustrations in ensuing paragraphs:

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 i scrip, quantity, price and timing of trades undertaken by FRs and Big Client
on a particular day;
ii Bloomberg chats between trader(s) of the Big Client and Rohit Salgaocar
showing timed communication of NPI to Rohit Salgaocar which included
scrip and quantity/price of the impending order of the Big Client in various
scrips;
iii Bloomberg chats between traders of Motilal and Nuvama with Rohit
Salgaocar showing that Rohit Salgaocar was instructing traders for
execution of the orders of Big Client and was getting prompt updates about
the execution status of orders from them;
iv chats between Ketan Parekh and the FRs/ facilitators through WhatsApp
groups “Jack-Saro” and “Jack-ST” showing sufficient evidence that such
timely and precise communication of NPI by Ketan Parekh to FRs could
not have been possible without involvement of Rohit Salgaocar. (Note: The
co-relation and communication between Rohit Salgaocar and Ketan
Parekh has already been explained in paragraphs 32 to 36.)

100. Communication of NPI from Rohit Salgaocar to Ketan Parekh is inferred from the
following:
i IPDRs of the various mobile numbers of Ketan Parekh which matched with the
IP address of Rohit Salgaocar;
ii Statements made by Rohit Salgaocar and Ketan Parekh to the IA;
iii Simultaneous communication between Rohit Salgaocar and the traders of Big
Client on one hand and the trading instructions made by Ketan Parekh, directly
or indirectly to FRs on the other hand in a time co-ordinated manner.

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 G.1 Illustration of NPI-based trades by FR1 and FR2 in the scrip of Titan
Company Limited (TITAN/500114) on April 05, 2023
101. On analysis of the trade logs, it is observed that FR1 and FR2 have undertaken
NPI-based Trades against the orders of Sxxxxxxxxxxxd Inc., one of the Funds of
the Big Client, making an overall profit of INR 10,88,086.20 on that day.

102. It is observed that during the day FR1 and FR2 matched their sell orders with the
buy orders of the Big Client in three different time patches. During these time
patches, the Big Client bought 2.5 lakh shares out of which FR1 and FR2 matched
2,25,616 shares.

103. The trades in one of the time patches, showing matching of trades between the
Big Client and FR1 is illustrated and explained below:

Table no. 30
Trades undertaken by the FR1 and Big Client
Parti Buy Count Order Order Trade Trade Sum of Average Trade Matc
cular / of Start End Start End Trade Price Range (in h
s Sell Orders Time Time Time Time Qty INR) Vol.
09:25:5 09:25:5 2561.25-2577.95
FR1 Buy 5 09:20:08 09:20:08 76,000 -
9 9 (2568.81)
09:27:5 09:28:0 09:30:4 2569.15-2570.00
BC Buy 3 09:27:54 1,00,000 -
4 4 3 (2570)
09:30:2 09:37:3 2570-2572 87,0
FR1 Sell 7 09:27:49 09:27:49 98,174
7 1 (2570.07) 41

104. From the table above, it is seen that:

i FR1 had placed 5 Buy orders during the period between 09:20:08 to
09:25:59. A quantity of 76,000 shares was executed at an average price of
INR 2,568.81. It is noted that the price of the scrip increased, from INR
2,537.40 (previous day close price) to INR 2,574.60 i.e. till the time FR1
executed buy trades.
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 ii Subsequently, the Big Client placed 3 buy orders for a cumulative quantity
of 1,00,000 shares between 09:27:54 and 09:28:04 at a price of INR 2570
and the same got executed.
iii At that time, FR1 also placed 7 sell orders for shares between 09:27:49-
09:30:27. A quantity of 98,174 shares got executed and of this 87,041
shares matched with the order of the Big Client i.e., 88.66% of the total
shares sold by FR1.
iv FR1, during the aforementioned patch, oversold a net of 22,174 shares and
matched trades with the Big Client in 3 patches. Further, FR1 squared off
its entire position during the day.

105. While the trades executed by the Big Client and the FR1 have been exhibited
above, the manner in which the instructions in respect of the aforesaid trades
were passed between various entities is shown below.

Table no. 31
Instruction with respect to the positions taken by FR1 prior to entry of the Big
Client
Column 1: Column 2:
Bloomberg chat between the Big Trading Instructions from 955A (Ketan Parekh) on
Client trader and Rohit Salgaocar on WhatsApp group Jack-ST on April 05, 2023
April 05, 2023
Time From Message
08:41:26 BCTrader3 - I would like
Big Client to buy
HDFCB
and TTAN
today
08:41:28 Rohit Hi
Salgaocar - BCTrader3
Strait Crossing good
morning

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 Column 1: Column 2:
Bloomberg chat between the Big Trading Instructions from 955A (Ketan Parekh) on
Client trader and Rohit Salgaocar on WhatsApp group Jack-ST on April 05, 2023
April 05, 2023
08:41:46 BCTrader3 - about
Big Client $90m in
HDFCB,
$20m in
TTAN
08:42:01 Rohit Got it, am
Salgaocar - checking
Strait Crossing on these,
will be back

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 Column 1: Column 2:
Bloomberg chat between the Big Trading Instructions from 955A (Ketan Parekh) on
Client trader and Rohit Salgaocar on WhatsApp group Jack-ST on April 05, 2023
April 05, 2023

106. From Column 1 and 2 in table above, it is seen that:

i at around 8:41 am, Big Client trader told Rohit Salgaocar that they were
looking to buy shares of Titan. The trader had also provided the quantum
which they wanted to buy.
ii at around 9:16 am, Ketan Parekh simultaneously instructed to buy Titan in
the group “Jack-ST”. However, upon knowing that the buying by FRs was
happening in F&O, clarified that the buying was to be done in cash market.
iii at around 9:19 am and 9:24 am, Ketan Parekh gave 2 instructions for
buying 50,000 and 25,000 shares of Titan, each, in the group “Jack-ST”

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 and thereafter Rahul (employee of Sanjay Taparia) provided confirmation
in this regard at 9:21 am and 9:26 am.

107. In view of the above, the cumulative buying of 76,000 shares done in the account
of FR1 can be correlated with the impending order of the Big Client since Rohit
Salgaocar knew about the quantum of Titan shares which the Big Client wanted
to buy and accordingly passed this information to Ketan Parekh who then
instructed to buy 75,000 shares. It is seen that FR1 bought additional 1000 shares
on its own. The further flow of this NPI from Ketan Parekh to FRs can be seen in
the table below:
Table no. 32
Instructions with respect of the positions taken by the FR1 and BC, when
matching took place
Column 1: Column 2: Column 3:
Bloomberg chat between Big Bloomberg chat between Trading Instructions from
Client trader and Rohit Rohit Salgaocar and the 955A/Jack New (Ketan Parekh) on
Salgaocar on April 05, 2023 trader of Nuvama on April 05, WhatsApp
2023
Time From Message Messag
09:25:40 Rohit 100k Time From e
Salgaocar - TTAN 09:27:4 Trader of Recd
Strait would you 0 Nuvama TTAN
Crossing care? Rohit
09:26:42 BCTrader3 - Yea! 09:27:5 Salgaoc
GO IN
Big Client 0 ar - Strait
09:27:03 BCTrader3 - 2570 Crossing
Big Client 09:27:5 Trader of
ok
09:27:04 BCTrader3 - ? 2 Nuvama
Big Client 09:27:5 Trader of
ok
09:27:09 Rohit checking 4 Nuvama
Salgaocar - 09:27:5 Trader of
in
Strait 4 Nuvama
Crossing

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 Column 1: Column 2: Column 3:
Bloomberg chat between Big Bloomberg chat between Trading Instructions from
Client trader and Rohit Rohit Salgaocar and the 955A/Jack New (Ketan Parekh) on
Salgaocar on April 05, 2023 trader of Nuvama on April 05, WhatsApp
2023
09:27:21 Rohit That's 09:27:5 Trader of
47k
Salgaocar - done 9 Nuvama
Strait nuvama 09:28:0 Trader of
73k
Crossing pls 0 Nuvama
09:28:0 Trader of 27k
7 Nuvama pending
09:28:1 Trader of
87k
4 Nuvama
Rohit
09:29:5 Salgaoc
NOW?
7 ar - Strait
Crossing
09:30:0 Trader of TTAN
0 Nuvama 13k pendi
09:30:3 Trader of TTAN
3 Nuvama 99k
Trader of TTAN:
09:30:4
Nuvama completer
9
d
09:30:5 Trader of 100k @
5 Nuvama 2570

108. From the aforesaid table, it is seen that:

i (Column 1) At around 9:25 am, Rohit Salgaocar, continuing his earlier chat
with the trader of the Big Client, confirmed whether the Big Client would
purchase 1 lakh shares of Titan. Subsequently, the price of the shares (@
INR 2570) was also agreed upon and Rohit Salgaocar asked trader of the
Big Client to send the deal ticket to Nuvama at 9:27 am.

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 ii (Column 2) At around 9:27 am, the trader of Nuvama informed Rohit
Salgaocar that deal ticket was received from the Big Client trader and Rohit
Salgaocar instructed Nuvama’s trader to place the order. Afterwards,
Nuvama’s trader provided continuous updates to Rohit Salgaocar about the
execution of the order and in the end confirmed order completion at
9:30:49.

iii (Column 3) At around 9:27 am, Ketan Parekh, in the group “Jack-ST”
instructed to sell 1 lakh Titan shares at INR 2570, in response to which,
Rahul Saraf (employee of Sanjay Taparia) confirmed placing order of sell
of 1 lakh shares of Titan at INR 2570 per share sold at 09:28 AM. This can
be correlated with the cumulative selling of 98,174 shares done in the
account of FR1, as shown above. The instructions received were for
1,00,000 shares, however, FR1 placed orders of 1,01,000 shares.

109. In respect of the quantity and price at which the Big Client was to buy Titan
Limited, following is noted:
i Rohit Salgaocar had a vast experience of dealing with the Big Client, owing
to his long standing relationship with them. This enabled him to have a fair
insight about the impact of the Big Client orders on the existing demand
and supply in the market. Further, in the instant case, Big Client had upfront
indicated, as evident from their chat, that the Big Client wanted to buy Titan
worth 20 million USD. Thus, Rohit Salgaocar had a fair idea about the size
and the price at which the trades of the Big Client could be executed.

ii This becomes all the more evident, given the fact that on April 05, 2023,
the volume in the Titan jumped by almost 50% (14.8 lakhs) in comparison
to its last 30-day average volume (9.76 lakhs), with almost 65% of average
daily trading volume of last 30 days (6.35 lakhs) being contributed by the
Big Client and FRs.

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110. In view of the aforesaid illustration, it is seen that:
i The chats in the tables above and the timing of flow of NPI between various
entities prima facie establishes that the information of the forthcoming buy
order of the Big Client in the scrip Titan reached to Ketan Parekh in a
perfectly time-coordinated manner.

ii As Rohit Salgaocar received instructions from trader of the Big Client about
buying Titan that day, the same was communicated to Ketan Parekh, who
in turn instructed Sanjay Taparia (who had access to the trading account
of FR1) to buy shares of Titan. Thereafter, just when the Big Client ordered
to buy the shares of Titan, Ketan Parekh immediately instructed Sanjay
Taparia to place sell order, which matched with the buy order of the Big
Client.

iii This process of matching the Buy orders of the Big Client with the sell
orders of FRs happened 2 more times in the day, where trades were placed
through the account of FR1 and FR2.

iv Thus, armed with the knowledge of the NPI of the impending orders of the
Big Client, Ketan Parekh got trades of such large quantity executed in the
accounts of FR1 and FR2, which otherwise they would not have
undertaken. This resulted in FR1 and FR2 matching with almost 90.25% of
the buy quantity of the BC in the aforesaid time patches, leading to a total
square off profit of INR 10,88,086.20 for FR1 and FR2 as calculated in the
table below:

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 Table no. 33
Calculation of unlawful gains made under this illustration
Average Average
FR Buy Qty Buy Value Buy Price Sell Qty Sell Value Sell Price Profit
FR1 2,49,908 64,21,59,740 2,569.58 2,49,908 64,31,40,637 2,573.51 9,80,896.95
FR2 35,250 9,06,45,247 2,571.50 35,250 9,07,52,436 2,574.54 1,07,189.25
Total Profit made by the FRs 10,88,086.20

111. It is also seen that the value of the shares of Titan, bought by the Big Client on
April 05, 2023, was less than the targeted quantity and the Titan trade was
carried over next trading day (April 06, 2023), where FR1 again traded based
on NPI. The trades undertaken by FR 1 and the Big Client on April 06, 2023,
wherein FR1 earned a square off profit of INR 5,56,909, is provided in the table
below:
Table no. 34
Trades undertaken by FR 1 and the Big Client in on April 06, 2023
Average
Count Order Order Trade Trade Sum of
Buy/ Trade Price Match
Particulars of Start End Start End Trade
Sell Range (in Vol.
Orders Time Time Time Time Qty
INR)
2554.85-
FR 1 Buy 4 09:20:26 09:38:07 09:20:26 09:38:54 78,430 2560.00 -
(2559.39)
2571.00-
FR 1 Sell 1 09:21:44 09:21:44 09:22:02 09:22:02 1 2571.00 -
(2571.00)
2560.00-
BC Buy 4 09:39:46 09:39:46 09:39:49 09:42:36 1,50,000 2560.00 -
(2560.00)
2560.00-
FR 1 Sell 6 09:39:49 09:42:36 09:39:49 09:42:38 1,50,000 2561.00 1,37,869
(2560.00)

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 Average
Count Order Order Trade Trade Sum of
Buy/ Trade Price Match
Particulars of Start End Start End Trade
Sell Range (in Vol.
Orders Time Time Time Time Qty
INR)
2545.00-
FR 1 Buy 13 09:45:08 15:29:05 09:45:08 15:29:19 71,571 2557.00 -
(2552.90)

112. Thus, trades in a particular scrip have also been carried over to next day in
some instances and thus FRs have made unlawful gains over and above what
can be seen on a given day.

G.2 Illustration of NPI-based trades by FR2 in the scrip of HDFC Limited

(HDFC/500010) on September 19, 2022

113. On analysis of trade logs, it is observed that FR2 has undertaken NPI-based
trades against orders of AXXXP Fund, one of the funds of the Big Client, making
an overall profit of INR 12,68,193.00 on that day.

114. It is observed that during the day, FR2 matched its sell orders with the buy
orders of the Big Client in 1 time patch. During this time patch the Big Client
bought a total of 2.5 lakh shares of HDFC Limited out of which FR2 matched
99,173 shares.

115. The trades undertaken by FR2 and the Big Client in time period prior to
matching and during matching of orders are illustrated and explained below:

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 Table no. 35
Trades undertaken by the FR2 and Big Client during aforesaid time
period
Partic Buy Coun Order Order Trade Trade Sum of Average Trade Match
ulars / t of Start End Start End Time Trade Price Range (in Vol.
Sell Order Time Time Time Qty INR)
s
2428.80-2439.00
FR2 Buy 13 10:03:42 10:32:32 10:03:42 10:32:34 1,00,000 -
(2433.32)
Big
Buy 7 11:11:02 11:11:17 11:11:02 11:11:26 2,50,000 2446 -
Client
FR2 Sell 4 11:11:08 11:11:08 11:11:08 11:11:08 1,00,000 2446 99,173

116. From the table above, it is seen that:

i FR2 placed 13 Buy orders during the period between 10:03:42 to 10:32:32.
Entire quantity of 1,00,000 shares was executed at an average price of INR
2433.32.
ii Subsequently, the Big Client placed 7 buy orders for a cumulative quantity
of 2,50,000 shares during the period between 11:11:02 - 11:11:17. The
same got executed at an average price of INR 2446.
iii At that time FR2 also placed 4 sell orders at 11:11:08, and the entire
quantity of 1,00,000 shares got executed at an average price of INR 2446
of which 99,173 shares matched with the Big Client order i.e. 99.17% of
the total shares sold by FR2.

117. While the trades executed by the Big Client and the FR2 have been exhibited
above, the manner in which the instructions in respect of the aforesaid trades
were passed between various entities are shown below.

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 Table no. 36
Instructions in respect of the positions taken by the FR2, prior to the entry of the
Big Client
Column 1: Column 2:
Bloomberg chat between Big Client Trading Instructions from Jack New (Ketan Parekh) on
trader and Rohit Salgaocar on WhatsApp group Jack-Saro on September 19, 2022
September 19, 2022
Time From Message

BCTrader2 – i can buy

09:59:09 Big Client slug of
HDFC too

Rohit HDFC, not

09:59:32 Salgaocar - the banks
Strait Crossing right?

BCTrader2 – that's right.

09:59:42
Big Client HDFC

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118. From columns 1 and 2 in the table above, it is seen that:
i at around 9:59 am, trader of the Big Client told Rohit Salgaocar that they
would buy HDFC Limited.
ii at around 10:03 am, Ketan Parekh simultaneously started instructing to buy
HDFC in the group “Jack-ST”. Further, at around 10:32 am he instructed to
complete 1 lakh buy. The messages are reflected and acknowledged in the
group by “Sam” (name of the mobile kept in the office of FR2 as discussed
at paragraph 48) of buying 100K shares of HDFC @ 2433.80 @ 10:33AM.
This can be correlated with the cumulative buying of 1,00,000 shares of
HDFC Limited, done in the account of FR2, as seen in table above at an
average price of 2433.32 per share at 10:32:34.

119. The further flow of the aforesaid NPI from Ketan Parekh to FRs can also been seen
in the table below:

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 Table no. 37
Instructions with respect of the positions taken by the FR2 and Big Client, when
matching took place
Column 1: Column 2: Column 3:
Bloomberg chat between Big Client Bloomberg chat between Rohit Trading Instructions from Jack New
trader and Rohit Salgaocar on Salgaocar and the trader of (Ketan Parekh) on WhatsApp group
September 19, 2022 Nuvama on September 19, 2022 Jack-Saro
Time From Message Time From Message
11:08:00 Rohit Small Trader of Recd
11:10:43
Salgaocar - HDFC and Nuvama HDFC
Strait I don't Rohit
250k
Crossing think Salgaocar -
11:10:45 HDFC
grows Strait
2446
250k too Crossing
irch or Rohit
small? Salgaocar -
11:11:00 Go inb
11:08:41 BCTrader2 – looking Strait
Big Client Crossing
11:09:10 BCTrader2 – 2445 Trader of
11:11:02 ok
Big Client Nuvama
11:09:54 Rohit 2446? Trader of
11:11:06 26k done
Salgaocar - Nuvama
Strait Trader of
11:11:08 52k done
Crossing Nuvama
11:10:06 Rohit 250k Trader of 176k
11:11:11
Salgaocar - Nuvama done
Strait Trader of 200k
11:11:13
Crossing Nuvama done
11:10:15 BCTrader2 – Ok Trader of 224k
11:11:15
Big Client Nuvama done
11:10:19 Rohit thx Trader of 26k
11:11:25
Salgaocar - Nuvama pending
Strait Trader of
11:11:28 done
Crossing Nuvama

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 Column 1: Column 2: Column 3:
Bloomberg chat between Big Client Bloomberg chat between Rohit Trading Instructions from Jack New
trader and Rohit Salgaocar on Salgaocar and the trader of (Ketan Parekh) on WhatsApp group
September 19, 2022 Nuvama on September 19, 2022 Jack-Saro
11:10:23 Rohit Edel pls Trader of Bought
Salgaocar - 11:11:47 Nuvama 250k @
Strait 2446.00
Crossing
11:10:38 BCTrader2 – sent
Big Client

120. From the aforesaid table, it is seen that:

i (Column 1) At around 11:08 am, Rohit Salgaocar, continuing his earlier
chat with the trader of the Big Client, offered 2.5 lakhs shares at INR 2446
and the trader then agreed to the trade, after which Rohit Salgaocar asked
the Big Client trader to send the deal ticket to the Edelweiss (now Nuvama).
ii (Column 2) At around 11:10 am, the trader of Nuvama informed Rohit
Salgaocar that deal ticket was received from the Big Client and Rohit
Salgaocar instructed Nuvama’s trader to place the HDFC order.
Afterwards, Nuvama’s trader provided to Rohit, continuous updates about
the order and in the end confirmed order completion.
iii (Column 3) At around 11:11 am, Ketan Parekh instructed to sell HDFC at
INR 2446, in the group “Jack-Saro” to which Sam (mobile phone kept in the
office of FR2) confirmed at 11:11 AM that 1 lakh shares of HDFC had been
sold @ 2446. This can be correlated with the cumulative selling of 1,00,000
shares of HDFC Limited, in the account of FR2, as seen in the table above.
Further, as can be seen in table above, the instructions across 3 different
chat windows were time coordinated.

iv In respect of the quantity and price at which the Big Client was to buy HDFC
Limited, as explained above, Rohit Salgaocar, owing to his vast experience
of dealing with the Big Client and his insights in respect of the impact of the
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 Big Client orders on the existing demand and supply in the market, had a
fair idea about the size and the price at which the trades of the Big Client
could be executed.

v The aforesaid analysis gets supported by the fact that on September 19,
2022 the volume in the HDFC Limited jumped by almost 75% (45.85 lakhs)
in comparison to its 30-day average volume (26.17 lakhs). The Big Client
and FR2 contributed around 5.5 lakhs to this volume, which is roughly 21%
of the average daily trading volume of last 30 days.

121. In view of the aforesaid illustration, it is seen that:

i The chats in the tables above and the timing of flow of NPI between various
entities prima facie establishes that the information of the forthcoming buy
order of AXXXP Fund in the scrip of HDFC Limited reached to Ketan
Parekh in a perfectly time-coordinated manner.

ii As Rohit Salgaocar received instructions from trader of the Big Client about
buying HDFC Limited, he communicated the same to Ketan Parekh who in
turn instructed FR2 to buy shares of HDFC Limited.

iii Thereafter, just when the Big Client ordered to buy the shares of HDFC
Limited, Ketan Parekh immediately instructed FR2 to place sell order,
which matched with the buy order of the Big Client.

iv Thus, armed with the knowledge of the NPI of the impending buy orders of
the Big Client, Ketan Parekh got trades of such large quantity executed in
the account of FR2, which otherwise it would not have undertaken. This
resulted in FR2 matching with almost 39.67% of the buy quantity of the Big
Client in the aforesaid time-patch, and made a total square off profit of INR
12,68,193.00 as calculated in the table below:

_______________________________________________________________________________________
Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
Page 88 of 188
 Table no. 38
Calculation of unlawful gains made under this illustration
Average Average Sell
FR Buy Qty Buy Value Buy Price Sell Qty Sell Value Price Profit
FR2 1,00,000 24,33,31,808 2,433.32 1,00,000 24,46,00,001 2,446.00 12,68,193.00

G.3 Illustration of NPI-based trade by FR1, FR2 and FR3 in the scrip of Policy
Bazar Limited (PB Fintech/ 543390) on November 11, 2022

122. On analysis of the trade logs, it is observed that FR1, FR2 and FR3 have undertaken
NPI-based Trades against the orders of two funds of the Big Client (Big Client)
namely AXXXP Fund and Axxxxxxn Fund, making an overall profit of INR 18,55,650
on that day.

123. It is observed that during the day, two funds of the Big Client (AXXXP Fund and
Axxxxxxn Fund) sold a total of 52.5 lakh shares of Policy Bazar Limited, in multiple
time patches. During 3 time patches, either of FR1, FR2 and FR3 matched their buy
orders with the sell orders of the Big Client, resulting in matched quantity of 20,61,291
shares.

124. Of the 3 time patches wherein NPI-based trading was observed, trading in 2 time
patches has been shown wherein the first patch involves matching of trades of FR2
and the Big Client and the second time patch involves matching of trades of FR1,
FR2 and FR3 with that of the Big Client.

125. The trades in the first time patch, showing matching of trades between the Big Client
and FR2 is illustrated and explained below:

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Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
Page 89 of 188
 Table no. 39
Trades undertaken by FR2 and Big Client
Part Bu Count Order Order Order Trade Trade Sum Average Mat
icul y/ of Start End Limit Start End of Trade Price ch
ars Sel Order Time Time Price Time Time Trade Range (in Vol.
l s Range Qty INR)
FR2 Sell 16 09:15: 09:58: 379.5 - 09:15: 10:01: 5,00,0 379.50-383.75 -
00 48 383.75 00 48 00 (382.62)

Big Sell 7 10:02: 10:02: 382 10:02: 10:02: 17,50, 382.00-383.45 -

Clie 16 16 16 16 000 (382.00)
nt
FR2 Bu 7 10:01: 10:02: 382 10:02: 10:02: 5,00,0 382.00-382.00 4,95
y 50 14 16 16 00 (382.00) ,873

126. From the table above, it is seen that:

i Between 09:15:00 to 09:58:48, FR2 had placed 16 sell orders, in which 5,00,000
shares were executed at an average price of INR 382.62.

ii Around 10:02:16 am, Big Client placed 7 sell orders of which 17,50,000 shares
which got executed at an average price of INR 382.

iii Between 10:01:50 - 10:02:14, FR2 placed 7 buy orders for 5,00,000 shares which
got executed at an average price of INR 382 and of this 4,95,873 shares matched
with the Big Client order i.e., 99.17% of the total shares bought by FR2.

127. While the trades executed by the Big Client and FR2 have been exhibited above, the
manner in which the instructions in respect of the aforesaid trades were passed
between various entities are shown below.

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Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
Page 90 of 188
 Table no. 40
Instructions in respect of the positions taken by the FR2, prior to the entry of the
Big Client
Column 1: Column 2:
Bloomberg chat between Big Client Trading Instructions from Jack New (Ketan Parekh)
trader and Rohit Salgaocar on on WhatsApp group Jack-Saro
November 11, 2022
Time From Message
Hi BCTrader2
Good Morning.
Back in the
PLM north of
1000 for blocks,
Rohit
APTUS 325 ob
08:02:2 Salgaocar
and
5 - Strait
POLICYBZ(ther
Crossing
e are whispers
around that
someone is
trying to build a
book)]
yo rohit
morning.
BCTrader
08:07:1 Hopefully helps
2 -Big
4 some of this
Client
stuff i'm trying
to sell
Rohit This POLICYBZ
08:08:5 Salgaocar should only be
3 - Strait north of 390
Crossing right?
BCTrader let's say 380
08:11:3
2 -Big but won't get
9
Client there

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Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
Page 91 of 188
 Column 1: Column 2:
Bloomberg chat between Big Client Trading Instructions from Jack New (Ketan Parekh)
trader and Rohit Salgaocar on on WhatsApp group Jack-Saro
November 11, 2022

_______________________________________________________________________________________
Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
Page 92 of 188
 Column 1: Column 2:
Bloomberg chat between Big Client Trading Instructions from Jack New (Ketan Parekh)
trader and Rohit Salgaocar on on WhatsApp group Jack-Saro
November 11, 2022

128. From Column 1 and 2 in table above, it is seen that:

i before market hours, Rohit Salgaocar and trader of the Big Client were
discussing about Policy Bazar and trader of the Big Client confirmed to
Rohit Salgaocar that they would sell Policy Bazar that day.
_______________________________________________________________________________________
Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
Page 93 of 188
 ii from 9:00 am to 9:58 am, Ketan Parekh gave multiple instructions to sell
scrip of Policy Bazar at various price in the WhatsApp group “Jack-Saro”.

129. In view of the above, cumulative selling of 5,00,000 shares done in the account of
FR2 can be correlated with the impending order of the Big Client since Rohit
Salgaocar knew about the quantum of shares which the Big Client wanted to sell and
accordingly passed this information to Ketan Parekh who then instructed FRs to take
position in the market. The further flow of NPI is as under:
Table no. 41
Instructions with respect to the positions taken by the FR2 and Big Client
Column 1: Column 2: Column 3:
Bloomberg chat between Big Bloomberg chat between Rohit Trading Instructions from Jack New
Client trader and Rohit Salgaocar Salgaocar and the trader of (Ketan Parekh) on WhatsApp group
on November 11, 2022 Nuvama on November 11, 2022 Jack-Saro
Time From Message Time From Message
Rohit Trader
09:52:3 Salgaocar - 10:02: of
750k? Completed
7 Strait 21 Nuvama
Crossing Wealth

Rohit POLICYBZ:
Trader
09:52:5 Salgaocar - POLICY Sold 1.75
10:03: of
4 Strait BZ mln @
19 Nuvama
Crossing 382.00 on
Wealth
NSE
10:01:0 BCTrader2 - 382 or
0 Big Client better

Rohit
10:01:0 Salgaocar - 382. For
2 Strait 1.75
Crossing

10:01:0 BCTrader2 -
done
9 Big Client

_______________________________________________________________________________________
Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
Page 94 of 188
 Column 1: Column 2: Column 3:
Bloomberg chat between Big Bloomberg chat between Rohit Trading Instructions from Jack New
Client trader and Rohit Salgaocar Salgaocar and the trader of (Ketan Parekh) on WhatsApp group
on November 11, 2022 Nuvama on November 11, 2022 Jack-Saro
Rohit
10:01:1 Salgaocar - Nuvama
4 Strait pls
Crossing

10:01:4 BCTrader2 -
sent
9 Big Client

130. From the aforesaid table, it is seen that:

i (Column 1) At around 9:52 am, Rohit Salgaocar, continuing with his earlier
chat with the trader of the Big Client, discussed the price and quantity of
shares of PolicyBazaar which were to be sold. The Big Client agreed to sell
17.5 lakhs shares in PolicyBazaar at the rate of INR 382 per share.
Thereafter, Rohit Salgaocar asked the trader of the Big Client to send deal
ticket to the Nuvama.
ii (Column 3) At around 10:01 am, Ketan Parekh, simultaneously instructed
to buy Policy Bazar at INR 382 in the group “Jack-Saro”, to which Sam
(mobile phone kept in the office of FR2) confirmed buying of 5 lakh shares
of Policy Bazar. The same can be correlated with the buy trade of 5 lakh
shares in the account of FR2.

iii (Column 2) Between 10:02:21 and 10:03:19 am, Nuvama’s trader informed
Rohit Salgaocar about completion of sell order received from the Big Client
trader i.e., total 17.5 lakh shares of Policy Bazar sold at INR 382.00 on
NSE. Further, as can be seen in table above, the instructions across 3
different chat windows were time coordinated.

_______________________________________________________________________________________
Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
Page 95 of 188
131. In respect of the quantity and price at which the Big Client was to sell Policy Bazar,
the following is noted:

i In the morning itself, the trader of the Big Client had given the price range
to Rohit Salgaocar. Further, owing to Rohit Salgaocar’s vast experience of
dealing with the Big Client, he had a fair idea about the size of the trades
which the Big Client executed.

ii This becomes all the more evident, given that on November 11, 2022 the
volume in the Policy Bazar jumped by almost 5891% (5.09 Cr) in
comparison to its 30-day average volume (8.5 lakhs). The Big Clients, FR1,
FR2 and FR3 contributed around 79.30 lakhs to this volume, which is
roughly 930% of the average daily trading volume of last 30 days.

iii Further, it is seen that the 1st instance of matching happened at around
10:02:16 am, and the total volume contributed by the Big Client and FR2
till that time was around 22.50 lakhs, which is 32.42% of their total volume
on the day.

132. In view of the aforesaid illustrations, it is seen that:

i The chats in the tables above and the timing of flow of information between
various entities, prima facie establishes that the information of the
forthcoming sell order of AXXXP Fund in the scrip of Policy Bazar reached
to Ketan Parekh in a perfectly time-coordinated manner.

ii As Rohit Salgaocar received the instructions from trader of the Big Client
about selling Policy Bazar that day, the same was communicated to Ketan
Parekh, who in turn instructed FR2 to sell shares of Policy Bazar Limited.
Thereafter, just when the Big Client ordered to sell the shares of Policy

_______________________________________________________________________________________
Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
Page 96 of 188
 Bazar Limited, Ketan Parekh immediately instructed FR2 to place buy
order, which matched with the sell order of the Big Client.

133. The trades in the second time patch, showing matching of trades of FR1, FR2 and
FR3 with that of the Big Client are illustrated and explained below:
Table no. 42
Trades undertaken by the FR1, FR2, FR3 and Big Client
Part Bu Cou Order Order Order Trade Trade Sum of Average Mat
icul y/ nt of Start End Limit Start End Trade Trade Price ch
ars Sel Ord Time Time Price Time Time Qty Range (in INR) Vol.
l ers Range
FR1 Sell 17 10:04:56 10:54: 383.9- 10:04: 11:05: 5,58,53 384.00-386.05 -
22 385.6 56 19 1 (384.88)

FR1 Buy 5 10:17:45 11:10: 382.5- 10:17: 11:10: 1,32,50 382.50-385.00 -

12 385.1 45 12 0 (384.23)

FR2 Buy 5 10:22:04 10:23: 383.5- 10:22: 10:29: 25,000 383.50-384.50 -

26 384.5 05 46 (384.00)

FR2 Sell 13 10:03:55 11:10: 384-386 10:04: 11:15: 6,05,86 384.00-386.00 -

22 36 52 9 (384.75)

FR3 Sell 2 11:09:51 11:10: 384.5 11:09: 11:15: 1,50,00 384.50 -

08 51 09 0

Big Sell 11 11:14:32 11:16: 384.5 11:15: 11:18: 25,00,0 384.50

Clie 27 09 26 00
nt

FR1 Buy 5 11:15:54 11:16: 384.5 11:15: 11:16: 4,08,53 384.50 4,08
20 54 20 1 ,529

FR2 Buy 7 11:15:39 11:16: 384.50 11:15: 11:16: 5,80,86 384.50 5,79
13 39 13 9 ,001

_______________________________________________________________________________________
Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
Page 97 of 188
Part Bu Cou Order Order Order Trade Trade Sum of Average Mat
icul y/ nt of Start End Limit Start End Trade Trade Price ch
ars Sel Ord Time Time Price Time Time Qty Range (in INR) Vol.
l ers Range
FR3 Buy 2 11:15:51 11:16: 384.50 11:15: 11:16: 1,30,00 384.50 1,29
42 51 42 0 ,998

134. From the table above, it is seen that:

i FR2 placed 13 sell orders between 10:03:55 to 11:10:22 in which 6,05,869
shares got executed at an average price of INR 384.75.FR2 also placed 5
buy orders between 10:22:04 to 10:23:26 in which 25,000 shares got
executed at an average price of INR 384.00.

ii Similarly, FR1 placed 17 sell orders between 10:04:56 to 10:54:22 in which

5,58,531 shares were executed at an average price of INR 384.88. FR1
also placed 5 buy orders between 10:17:45 to 11:10:12 in which 1,32,500
shares were executed at an average price of INR 384.23.

iii FR3 also placed 2 sell orders between 11:09:51 to 11:10:08 in which
1,50,000 shares were executed at an average price of INR 384.50.

iv Subsequently, Big Client placed 11 sell orders for a cumulative quantity of

25,00,000 shares during the period between 11:14:32 – 11:16:27. The
same got executed at an average price of INR 384.50.

v At that time FR1, FR2 and FR3 placed 5, 7 and 2 buy orders, respectively,
for a cumulative quantity of 11,19,400 shares, between 11:15:39 –
11:16:42, and 11,19,400 shares got executed at an average price of INR
384.50, of which 11,17,528 shares matched with the Big Client order i.e.,
99.83% of the total shares bought by FRs.

_______________________________________________________________________________________
Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
Page 98 of 188
 135. While the trades executed by the Big Client and the FRs have been exhibited above,
the manner in which the instructions in respect of the aforesaid trades were passed
between various entities are shown below.

Table no. 43
Instructions with respect to the positions taken by the FR2 and Big Client, when
matching took place
Column 1: Column 2: Column 3:
Bloomberg chat between Big Bloomberg chat between Rohit Trading Instructions from 955A/Jack
Client trader and Rohit Salgaocar Salgaocar and the trader of New (Ketan Parekh) on WhatsApp
on November 11, 2022 Nuvama on November 11, 2022
Messag Time From Message
Time From e Trader of Received
going to Nuvama POLICYB
10:01:5 BCTrader2 - eat 11:10:49 Wealth Z
2 Big Client lunch Trader of
now Nuvama
11:11:08 Wealth 384.50
Rohit
Rohit
10:01:5 Salgaocar -
11:11:12 Salgaocar Call me
9 Strait
Trader of
Crossing thanks
Nuvama
Rohit 11:11:34 Wealth yes
10:02:0 Salgaocar - Trader of
3 Strait Keep Nuvama complete
Crossing looking 11:18:33 Wealth d
11:21:26 Trader of
Rohit
Nuvama POLICYB
10:02:0 Salgaocar -
Wealth Z: Sold @
7 Strait
384.50 on
Crossing ?
BSE
10:01:0 BCTrader2 -
9 Big Client not now

_______________________________________________________________________________________
Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
Page 99 of 188
 Column 1: Column 2: Column 3:
Bloomberg chat between Big Bloomberg chat between Rohit Trading Instructions from 955A/Jack
Client trader and Rohit Salgaocar Salgaocar and the trader of New (Ketan Parekh) on WhatsApp
on November 11, 2022 Nuvama on November 11, 2022
10:02:1 BCTrader2 -
eating
3 Big Client

Rohit Buyer
10:47:4 Salgaocar - for
9 Strait 2.5mn
Crossing at 384

back.
counter
11:06:5 BCTrader2 -
384.50
4 Big Client
for
2.5mn

Rohit
11:07:1 Salgaocar -
9 Strait One
Crossing min

Rohit
11:09:1 Salgaocar -
1 Strait
Crossing 384.50?

Rohit
11:09:1 Salgaocar -
4 Strait
Crossing 2.5mn

Rohit
11:10:0 Salgaocar -
2 Strait rang the
Crossing bell

_______________________________________________________________________________________
Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
Page 100 of 188
 Column 1: Column 2: Column 3:
Bloomberg chat between Big Bloomberg chat between Rohit Trading Instructions from 955A/Jack
Client trader and Rohit Salgaocar Salgaocar and the trader of New (Ketan Parekh) on WhatsApp
on November 11, 2022 Nuvama on November 11, 2022
11:10:1 BCTrader2 - yes
5 Big Client done

Rohit
11:10:1 Salgaocar -
8 Strait
Crossing thanks

Rohit
11:12:1 Salgaocar -
3 Strait
Crossing nuvama

Rohit
11:12:1 Salgaocar -
9 Strait I will do
Crossing on bse

so you
want
me to
11:13:1
send all
8
to
BCTrader2 - Nuvam
Big Client a?

Rohit
11:13:2 Salgaocar -
2 Strait
Crossing Yes pls

11:13:3 BCTrader2 -
3 Big Client sent

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Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
Page 101 of 188
 Column 1: Column 2: Column 3:
Bloomberg chat between Big Bloomberg chat between Rohit Trading Instructions from 955A/Jack
Client trader and Rohit Salgaocar Salgaocar and the trader of New (Ketan Parekh) on WhatsApp
on November 11, 2022 Nuvama on November 11, 2022
Rohit
11:14:4 Salgaocar -
4 Strait
Crossing thx

136. From the aforesaid table, it is seen that:

i (Column 1) At around 10:01 am, Rohit Salgaocar continued with his earlier
chat with the trader of the Big Client, in respect of the sell trade in Policy
Bazar, wherein the price, quantity and the Exchange (in this case BSE) on
which the trade was to be executed was agreed upon. Subsequently, Rohit
Salgaocar asked the Big Client trader to send the deal ticket to the Nuvama.

ii (Column 2) At around 11:10 am, the trader of Nuvama informed Rohit

Salgaocar that deal ticket is received from the Big Client. Subsequently,
Rohit Salgaocar instructed Nuvama’s trader to call him. Afterwards,
Nuvama’s trader provided confirmation to Rohit of order completion.

iii (Column 3) Between 10:03 am and 11:10 am Ketan Parekh gave multiple
instructions to sell Policy Bazar at various prices in the group “Jack-Saro”.
This can be correlated with the buy and sell trades done in the account of
FR2. At 11:10 am, it can also be observed from the chat that Ketan Parekh
told FR2 to be ready to buy Policy Bazar and to cover the shares sold on
BSE. At 11:16 am, FR2 confirmed that the buy order for 5,80,869 shares
had been executed on BSE out of which, 5,79,001 trades matched with the
Big Client.

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Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
Page 102 of 188
 iv FR1 and FR 3 had also created net short position, by selling shares in cash
segment, in Policy Bazar and most of this short position created by FR1
and FR3 had also been squared off by them and matched with the Big
Client in the aforesaid time patch. By doing this, both FR1 and FR 3 had
matched 4,08,529 and 1,29,998 trades with the Big Client, respectively.

137. In respect of the quantity and price at which Big Client was to buy Policy Bazar, it is
seen that:
i In respect of the quantity and price at which Big Client was to sell Policy
Bazar, as explained above, Rohit Salgaocar, owing to his vast experience
of dealing with the Big Client and his insights in respect of the impact of the
Big Client orders on the existing demand and supply in the market, had a
fair idea about the size and the price at which the trades of the Big Client
could be executed.

ii This gets supported by the fact that on November 11, 2022 the volume in
the Policy Bazar jumped by almost 5891% (5.09 Cr) in comparison to its
30-day average volume (8.5 lakhs). The Big Clients, FR1, FR2 and FR3
contributed around 79.12 lakhs to this volume, which is roughly 930% of
the average daily trading volume of last 30 days.

iii Further, it is seen that the Exchange at which the trade is going to be
executed was communicated to the FRs so that the net short position
created gets squared off with the intended Big Client. It is to be noted that
the short position created by the FRs, would not have otherwise been
created.

138. In view of the aforesaid illustration, it is seen that:

i The chats in the aforesaid table and the timing of flow of information
between various entities, prima facie establishes that the information of the
_______________________________________________________________________________________
Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
Page 103 of 188
 forthcoming sell order of the Big Client in the scrip of Policy Bazar reached
to Ketan Parekh in a perfectly time-coordinated manner.

ii As Rohit Salgaocar received the instructions from traders of the Big Client
about the impending trades of the Big Client on that day, the same was
communicated to Ketan Parekh, who in turn instructed Sanjay Taparia
(who had access to account of FR1 and FR3)8 and FR2, to sell shares of
Policy Bazar. Thereafter, just when the Big Client ordered to sell the shares
of Policy Bazar, Ketan Parekh immediately instructed Sanjay Taparia and
FR2, to place buy order, which matched with the buy order of the Big Client.

iii This process of matching the Buy orders of the Big Client with the sell
orders of FRs happened 3 times in the day, where trades were placed
through the account of FR1, FR2 and FR3.

iv Thus, armed with the knowledge of the impending buy orders of the Big
Client, Ketan Parekh got trades of such large quantity executed in the
accounts of FR1, FR2 and FR3, which otherwise they would not have
undertaken. This resulted in a match of 39.26% of the sell quantity of the
Big Client in the aforesaid time patches and a total square off profit of INR
18,55,650 for FR1, FR2 and FR3 as calculated in the table below:

Table no. 44
Calculation of unlawful gains made under this illustration
Average Average
FR Buy Qty Buy Value Buy Price Sell Qty Sell Value Sell Price Profit
FR1 8,18,693 31,63,02,063 386.35 8,16,693 31,57,69,389 386.64 2,40,026.05

FR2 16,90,964 65,15,38,290 385.31 16,90,964 65,30,00,219 386.17 14,61,929.00

8
Connection of Sanjay Taparia and FR3 is discussed at paragraph 45 and 46.
_______________________________________________________________________________________
Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
Page 104 of 188
 Average Average
FR Buy Qty Buy Value Buy Price Sell Qty Sell Value Sell Price Profit
FR3 1,70,000 6,52,81,269 384.01 1,55,000 5,96,74,852 385.00 1,53,694.97
Total Profit made by the FRs 18,55,650

G.4 Illustration of NPI-based trades by FR 2 and FR5 in the scrip of

Cholamandalam Investment and Finance Company Limited (CHOLAFIN /
511243) on January 09, 2023

139. On analysis of the trade logs, it is observed that FR2 and FR5 have undertaken NPI-
based trades against the orders of AXXXP Fund, one of the funds of the Big Client,
making an overall profit of INR 70,63,705.40.

140. It is observed that during the day, the Big Client sold around 9 lakh shares of
Cholamandalam Investment and Finance Company Limited (hereinafter “CIFC” or
“Chola”). FR2 and FR5 matched their buy orders with the sell orders of the Big Client,
matching the sell order of the Big Client with a quantity of 4,60,085.

141. The trades undertaken by FR2, FR5 and Big Client prior to matching and during
matching of the orders are illustrated and explained below:
Table no. 45
Trades undertaken by the FR2, FR5 and Big Client
Parti Buy Count Order Order Trade Trade Sum of Average Trade Matc
cular / of Start End Start End Trade Price Range (in h
s Sell Orders Time Time Time Time Qty INR) Vol.
09:03:1 09:17:1 09:07:1 09:19:2 660.00-667.00
FR5 Sell 4 80,310 -
3 1 9 0 (661.21)

Big 09:19:3 09:19:3 09:19:3 09:21:5 660.00 - 660.60

Clien Sell 7 9,00,000 -
7 7 7 1 (660.00)
t

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Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
Page 105 of 188
 Parti Buy Count Order Order Trade Trade Sum of Average Trade Matc
cular / of Start End Start End Trade Price Range (in h
s Sell Orders Time Time Time Time Qty INR) Vol.
09:20:2 09:20:3 09:20:2 09:20:3 660.00 - 660.00 1,47,
FR2 Buy 3 1,50,000
7 2 7 2 (660.00) 946

09:19:4 09:20:5 09:19:4 09:20:5 659.85 - 660.00 3,12,

FR5 Buy 4 3,12,810
0 0 0 0 (660.00) 139

09:38:3 09:38:3 09:58:5 675.95-682.60

FR5 Sell 19 9:58:43 2,32,500 -
7 7 4 (678.77)

13:54:3 14:29:3 13:54:3 14:30:1 676.00 - 679.00

FR2 Sell 39 1,50,000 -
4 1 4 4 (677.34)

142. From the table above, it is seen that:

i Big Client placed 7 sell orders at 09:19:37. The same got executed at an
average price of INR 660.00. It is noted that FR5 placed 4 sell orders by
09:19:20 am, i.e. before Big Client entered the market, in which 80,310
shares were executed. The price decreased from around INR 667.90 to
INR 660.06 during this period owing to large sell orders placed by FR5.

ii FR2 placed 3 buy orders between 09:20:27-09:20:32, in which 1,50,000

shares got executed at an average price of 660, of which 1,47,946 shares
matched with the Big Client order i.e., 98.63% of the total shares bought by
FR2. Further, FR5 placed 4 buy orders between 09:19:40-09:20:50 in
which 3,12,810 shares, got executed at an average price of 660, of which
3,12,139 shares matched with the Big Client order i.e., 99.78% of the total
shares bought by FR5. Thus, FR2 and FR5 cumulatively bought 4,60,085
shares from the Big Client which means they matched 51.12% of the Big
Client order.

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Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
Page 106 of 188
 iii Afterwards, during the period between 13:54:34 to 14:29:31, FR2 placed
39 Sell orders in which 1,50,000 shares got executed at an average price
of INR 677.34. FR5 placed 19 sell orders between 09:38:37 to 09:58:43 in
which 2,32,500 shares got executed at an average price of INR 678.77.
Thus, it is seen that based on the NPI-based trading instructions, FRs were
making unlawful gains from trades which were executed after matching
with the Big Client also.

143. The discussion between Rohit Salgaocar and the trader of Big Client about CIFC
started on the previous working day i.e. January 06, 2023, where also NPI-based
trades were executed by FR5. The relevant extracts of the Bloomberg chats between
Rohit Salgaocar and the trader of Big Client on January 06, 2023 are shown below:

Table no. 46
Bloomberg chats between Rohit Salgaocar and the trader of Big Client on
January 06, 2023
Time From Message
09:07:48 BCTrader2 - Big Client can also sell CIFC
09:30:03 Rohit Salgaocar - Strait Crossing 200k CIFC?
09:30:59 BCTrader2 -Big Client mkt 680 or better yes
09:31:28 Rohit Salgaocar - Strait Crossing 681
09:31:31 Rohit Salgaocar - Strait Crossing Done
09:36:45 Rohit Salgaocar - Strait Crossing Continue to look 680 ob?
10:53:56 BCTrader2 -Big Client would stll do mkt here
10:54:19 Rohit Salgaocar - Strait Crossing Will look

144. As can be seen from table above, on January 06, 2023, BCTrader2 told Rohit
that he wanted to sell CIFC. Thereafter, during the day Rohit Salgaocar did a trade
of 200K shares in CIFC for Big Client. Thereafter, the trader of Big Client confirmed
that he was still interested in selling CIFC indicating that he had more quantity which
could be sold, to which Rohit Salgaocar replied that he would look. Hence, it is seen

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Page 107 of 188
 that Rohit Salgaocar, owing to his vast experience of dealing with the Big Client, had
a fair idea about the size of the trades that the Big Client was looking to execute.

145. While, the trades executed by the Big Client, FR2 and FR5 have been exhibited
in Table no. 45, the manner in which the instructions in respect of the aforesaid trades
were passed between various entities are shown below.

Table no. 47
Instruction with respect to the positions to be taken in the scrip on January
09, 2023
Column 1: Column 2:
Bloomberg chat between Big Client Trading Instructions from Jack New (Ketan Parekh) on
trader and Rohit Salgaocar on WhatsApp group Jack-Saro
January 9, 2022
Time From Message
Hi BCTrader2
08:20:45 Rohit
Good
Salgaocar -
Morning. Just
Strait
checking if
Crossing
back to look
for blocks
in CIFC and
levels
please?
MAXHEALTH
at 430 ob
PLM 980 ob
and RLXF at
970 ob thanks
BCTrader2 morning
08:23:23
(Big Client) Rohit. all
good. cifc
650 and
better

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 146. From Column 1 and 2 in table above, it is seen that:
i At around 8:23 am on January 09, 2023, trader of the Big Client indicated
to Rohit Salgaocar that he was interested in Chola (CIFC) with a price
range of “650 and better”;
ii At around 09.08 am, Ketan Parekh simultaneously communicated in the
WhatsApp group “Jack-Saro” that Chola (CIFC) cash would be selling on
that day.

147. The further flow of the aforesaid NPI from Ketan Parekh to FRs is depicted in the
table below:
Table no. 48
Instructions with respect to the positions taken by the FR2 and Big Client
Column 1: Column 2: Column 3:
Bloomberg chat between Big Bloomberg chat between Rohit Trading Instructions from Jack New
Client trader and Rohit Salgaocar Salgaocar and the trader of (Ketan Parekh) on WhatsApp group
on January 09, 2023 Nuvama on January 09, 2023 Jack-Saro
Time From Message
09:16:41 Rohit 1mn you Time From Message
Salgaocar - care
09:1 Trader of Recd Order
Strait CIFC?
9:24 Nuvama to sell CIFC
Crossing
09:16:47 Rohit Rang the 09:1 Trader of 900k @ 660

Salgaocar - bell 9:27 Nuvama

Strait 09:1 Trader of Ready

Crossing 9:30 Nuvama
BCTrader2 Looking
09:17:03 (Big Client) 09:1 Rohit
9:34 Salgaocar Go in
BCTrader2 Yes
09:17:21 (Big Client) 09:1 Trader of
09:17:35 Rohit 660 Can I 9:36 Nuvama Ok
Salgaocar - show?
09:1 Trader of 83k
Strait
9:43 Nuvama
Crossing

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 Column 1: Column 2: Column 3:
Bloomberg chat between Big Bloomberg chat between Rohit Trading Instructions from Jack New
Client trader and Rohit Salgaocar Salgaocar and the trader of (Ketan Parekh) on WhatsApp group
on January 09, 2023 Nuvama on January 09, 2023 Jack-Saro
09:17:39 BCTrader2 Yes 09:1 Trader of 135k
(Big Client) 9:48 Nuvama
09:17:41 BCTrader2 and that
09:2 Trader of 390k
(Big Client) would be it
0:35 Nuvama
09:17:55 BCTrader2 as in no
(Big Client) more after 09:2 Trader of 633k
09:17:55 Rohit That's 0:49 Nuvama
Salgaocar - done,
09:2 Trader of 775k
Strait
1:23 Nuvama
Crossing
09:18:06 Rohit U want to 09:2 Trader of 867k
Salgaocar - keep back 1:43 Nuvama
Strait some?
09:2 Trader of completed
Crossing
1:55 Nuvama
09:18:14 BCTrader2 i hav 112k
(Big Client) left. will 09:2 Trader of CIFC:Sold

keep 3:34 Nuvama 900k @ 660

09:18:20 BCTrader2 nuvama?

(Big Client)
09:18:22 Rohit Shud I do
Salgaocar - 900 ?
Strait
Crossing
09:18:43 BCTrader2 you think
(Big Client) that's
better?
09:18:45 Rohit Yes
Salgaocar - nuvama
Strait
Crossing
09:18:53 BCTrader2 worried it
(Big Client) will not
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 Column 1: Column 2: Column 3:
Bloomberg chat between Big Bloomberg chat between Rohit Trading Instructions from Jack New
Client trader and Rohit Salgaocar Salgaocar and the trader of (Ketan Parekh) on WhatsApp group
on January 09, 2023 Nuvama on January 09, 2023 Jack-Saro
trade so
much
today
09:19:00 BCTrader2 ok 900
(Big Client)
09:19:11 Rohit 900k is
Salgaocar - odne 660
Strait
Crossing

148. From columns 1, 2 and 3 in the table above, it is seen that:

i at around 9:19 am, Rohit Salgaocar got a confirmation from the trader of
the Big Client about the sell order of 900,000 shares in CIFC and the deal
ticket is sent to Nuvama.

ii at around 9:19 am, Nuvama’s trader informed Rohit Salgaocar about

receipt of CIFC sell order from the Big Client and thereafter, Rohit
Salgaocar instructed Nuvama’s trader to place the order. Afterwards,
Nuvama’s trader provided Rohit with continuous updates about the status
of execution of the order and in the end confirms order completion at
around 9:22 am.

iii at around 9:19-9:20 am, Ketan Parekh, in the group “Jack-Saro”, instructed
to sell Chola at 664 and cover Chola at 660. To this Sam (mobile kept in
the office of FR2) confirmed buying 1.5 lakh Chola at INR 660 and pending
sell order of 1 lakh at INR 664. However, immediately afterwards Ketan
Parekh instructed in the group to remove selling i.e. to delete the pending
sell order in the scrip Chola, which had just been placed.

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 iv at around 1:51 pm, Ketan Parekh in the group “Jack-Saro”, instructed to
reverse the existing positions in Cash and Futures of Chola and Sam
(mobile kept in the office of FR2) reversed both the positions and confirmed
about the same in the group. The trade reversed in the cash market can be
correlated with the cumulative sell of 1.5 lakh shares of Chola, in the
account of FR2.

v In respect of the quantity and price at which the Big Client was looking to
sell CIFL, the trader of the Big Client had given the price range to Rohit
Salgaocar in the morning itself. Further, as stated above, the discussion
about CIFL has been continued from previous working day i.e. January 06,
2023, wherein the trader of the Big Client had indicated that he has more
quantity which can be sold. Given that Rohit Salgaocar had vast experience
of dealing with the Big Client, it can be said that he had a fair idea about
the size of the trades that the Big Client was looking to execute.

vi Further, on January 09, 2023, the volume in the CIFL jumped by almost 3
times (39.66 lakhs) in comparison to its 30-day average volume (13.36
lakhs). The Big Client, FR2 and FR5 contributed around 13.63 lakhs to this
volume, which is roughly 102% of the average daily trading volume of last
30 days. Further, it is seen that the instance of matching happened at
around 9:19-9:20 am, and the total volume contributed by the Big Client,
FR2 and FR5 till that time was around 13.63 lakhs, which is 100% of their
volume on the day.

149. In view of the aforesaid illustration, it is seen that:

i The chats in the tables above and the timing of flow of NPI amongst various
entities prima facie establishes that the information of the forthcoming sell

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 order of AXXXP Fund in the scrip of CIFL reached to Ketan Parekh in a
perfectly time-coordinated manner.

ii As Rohit Salgaocar received the instructions from trader of the Big Client
about selling CIFL that day, the same was communicated to Ketan Parekh,
who in turn instructed about the same to FR2. Thereafter, just when the Big
Client ordered to sell the shares of CIFL, Ketan Parekh immediately
instructed FR2 to place buy order, which matched with the sell order of the
Big Client.

iii This process of matching the sell order of the Big Client with the buy orders
of FRs happened at around 9:19-9:20 am, where trades were placed
through the account of FR2 and FR5.

iv Thus, armed with the knowledge of the impending sell orders of the Big
Client, Ketan Parekh got trades of such large quantity executed in the
accounts of FR2 and FR59, which otherwise they would not have
undertaken. This resulted in a match of 51.12% of the sell quantity of the
Big Client and a total square off profit of INR 70,63,705.40 for FR2 and FR5
as calculated in the table below:
Table no. 49
Calculation of unlawful gains made under this illustration
Average Average
FR Buy Qty Buy Value Buy Price Sell Qty Sell Value Sell Price Profit
FR2 1,50,000 9,90,00,000 660.00 1,50,000 10,16,01,369 677.34 26,01,369.20
FR5 3,12,810 20,64,54,594 660.00 3,12,810 21,09,16,930 674.27 44,62,336.20
Total Profit made by the FRs 70,63,705.40

9
Flow of NPI from Ketan Parekh to FR5 is discussed in Part D.5 of this order.
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 G.5 Illustration of NPI-based trades by FR 2 and FR6 in the scrip of Tube
Investments of India Limited (TIINDIA/540762) on May 18, 2022

150. Upon analysis of the trade logs, it is observed that FR2 and FR6 have undertaken
NPI-based trades against the orders of AXXXP Fund, one of the funds of the Big
Client, making an overall profit of INR 7,53,405.65.

151. It was observed that during the day FR2 and FR6 matched their buy orders with the
sell orders of AXXXP Fund in two time patches. During the aforesaid patches, the
Big Client sold around 2.25 lakh shares of Tube Investments of India Limited out of
which FRs matched 2,23,150 shares.

152. The trades undertaken by the FR2, FR6 and the Big Client in time period prior to
matching and during matching of orders are illustrated and explained below:

Table no. 50
Trades undertaken by the FR2, FR6 and Big Client during aforesaid Patch
Partic Buy/ Co Order Order Trade Trade Sum of Average Match
ulars Sell unt Start End Time Start End Time Trade Trade Vol.
of Time Time Qty Price
Ord Range (in
ers INR)
1666.00-
FR2 Sell 29 09:15:00 09:31:20 09:15:00 09:32:24 1,50,000 1681.30 -
(1669.45)
1670.00-
FR6 Sell 1 09:33:12 09:33:12 09:33:12 09:33:12 3367 1674.50 -
(1670.33)
Big
Sell 4 09:35:31 09:36:13 09:35:56 09:36:36 2,00,000 1666.00
Client

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Partic Buy/ Co Order Order Trade Trade Sum of Average Match
ulars Sell unt Start End Time Start End Time Trade Trade Vol.
of Time Time Qty Price
Ord Range (in
ers INR)
1661.95-
FR2 Buy 4 09:36:05 09:36:11 09:36:05 09:36:11 1,65,000 1666.00 1,64,600
(1666.00)
1662.15-
FR6 Buy 1 09:35:56 09:35:56 09:35:56 09:35:56 35,000 1666.00 34,628
(1665.99)
1667.00-
FR2 Sell 1 09:37:41 09:38:01 09:37:41 09:40:17 15,000 1668.05
(1667.00)
1669.00-
FR6 Sell 20 09:41:57 14:46:28 09:48:30 14:51:10 51,360 1674.00
(1670.90)
1669.00-
Big
Sell 1 14:51:29 14:51:29 14:51:29 14:51:48 25,000 1669.50
Client
(1669.00)
1668.00-
FR6 Buy 2 14:45:06 14:51:48 14:45:16 14:51:48 26,153 1669.00 23,922
(1668.91)
1669.80-
FR6 Sell 3 14:52:54 15:25:24 14:53:30 15:25:24 6,426 1671.00
(1670.68)

153. From the table above, it is seen that:

i between 9:15 am and 9:31 am, FR2 had placed 29 sell orders wherein a
quantity of 1,50,000 shares was executed at an average price of INR
1,669.45. It is noted that the price of the scrip has decreased from INR
1,692.90 (previous day close price) to INR 1,666.00 till the time trade with
the Big Client had matched. At 9:33 am, FR6 also placed sell order which
got executed for 3367 shares at an average price of INR 1670.33.

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 ii between 9:35 am and 9:36 am, the Big Client placed 4 sell orders wherein
2,00,000 shares got executed at an average price of INR 1,666.00.

iii at around 9:36 am, FR2 and FR6 also placed buy orders wherein for
1,65,000 shares and 35,000 shares, respectively got executed and a total
of 1,99,228 shares got matched with the Big Client order i.e., 99.61% of the
total shares sold by the Big Client.

iv at around 9:37 am, FR2 placed 1 sell order wherein 15,000 shares got
executed at an average price of INR 1667.00. Subsequently FR6 sold
51,360 shares at an average price of INR 1670.90 which got executed
between 9:48 am and 2:51 pm.

v at around 2:51 pm, FR6 again matched trade with the Big Client in another
time-patch. Further, it was seen that FR6 squared off its entire position
during the day.

154. While the trades executed by the Big Client, FR2 and FR6 have been exhibited
above, the manner in which the instructions in respect of the aforesaid trades were
passed from Big Client to FR2 are shown below:

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 Table no. 51
Instruction with respect to positions taken by the FR2, prior to entry of
the Big Client
Column 1: Column 2:
Bloomberg chat between Big Client Trading Instructions from Jack New (Ketan Parekh) on
trader and Rohit Salgaocar on May 18, WhatsApp group Jack-Saro
2022
Time From Message
09:07:04 BCTrader4- Big Im trying to
Client sell some
TIINDIA.
Know any
recent
buyers?
09:08:43 Rohit I will check
Salgaocar - with the last
Strait Crossing few buyers,
and be
back asap
09:08:51 BCTrader4 - ty
Big Client

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 Column 1: Column 2:
Bloomberg chat between Big Client Trading Instructions from Jack New (Ketan Parekh) on
trader and Rohit Salgaocar on May 18, WhatsApp group Jack-Saro
2022

155. From Column 1 and 2 in table above, it is seen that:

i at around 09:07 am the Big Client trader told Rohit Salgaocar that they
would sell TIINDIA.
ii from 9:11 am onwards Ketan Parekh gave multiple sell instructions for
TIINDIA. During the course of these instructions, Sam (mobile phone kept
in the office of FR2), provided updates about the orders placed. At 9:32 am,
Sam confirmed that 1.5 lakh TIINDIA is sold and no more margin left for
placing further trades.

156. The further flow of the aforesaid NPI-based trading instructions from Ketan Parekh
to FR2 is depicted in the table below:

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 Table no. 52
Instructions with respect to the positions taken by the FR2, FR6 and Big Client, during
matching phase
Column 1: Column 2: Column 3:
Bloomberg chat between Big Client Bloomberg chat between Rohit Trading Instructions from Jack New (Ketan
trader and Rohit Salgaocar on May 18, Salgaocar and the trader of Parekh) on WhatsApp group “Jack-Saro”
2022 Nuvama on May 18, 2022
Time From Message Messag
09:31:36 Rohit Salgaocar 125K tiindia Time From e
- Strait Crossing ? 09:34:50 Rohit Get
09:33:53 BCTrader4 - Big What px? Salgaoca ready
Client r - Strait 200k1666
09:34:04 Rohit Salgaocar Sorry 200k Crossing
- Strait Crossing 1866? 09:34:53 Trader of Sure
09:34:12 BCTrader4- Big Yes Nuvama
Client 09:35:01 Trader of Ready
09:34:16 Rohit Salgaocar 1666 sorry Nuvama
- Strait Crossing 09:35:28 Rohit Go in
09:34:18 BCTrader4- Big Which Salgaoca
Client broker? r - Strait
09:34:25 Rohit Salgaocar Edel pls Crossing
- Strait Crossing 09:35:30 Trader of ok
09:34:26 BCTrader4- Big 1666 Nuvama
Client 09:35:31 Trader of in
09:34:47 BCTrader4- Big Done sent Nuvama
Client 09:35:47 Trader of Nil so far
09:34:57 Rohit Salgaocar thanks Nuvama
- Strait Crossing 09:36:01 Trader of 34k done
09:35:10 BCTrader4- Big ty Nuvama
Client 09:36:11 Trader of 134k
Nuvama done
09:36:13 Trader of 184k
Nuvama done
09:36:21 Trader of 767 shs
Nuvama pending

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 Column 1: Column 2: Column 3:
Bloomberg chat between Big Client Bloomberg chat between Rohit Trading Instructions from Jack New (Ketan
trader and Rohit Salgaocar on May 18, Salgaocar and the trader of Parekh) on WhatsApp group “Jack-Saro”
2022 Nuvama on May 18, 2022
09:37:15 Trader of TIINDIA.
Nuvama Sold 200k
@
1666.00
on NSe

157. From columns 1, 2 and 3 in the table above, it is seen that:

i At around 9:31am, Rohit Salgaocar continuing with his earlier chat with the
trader of the Big Client, offered 2 lakh shares of TIINDIA at INR 1666. Big
Client trader agreed to the trade and sought broker name to which Rohit
Salgaocar responded “Edelweiss” (now Nuvama).

ii between 9:35 am and 9:37 am, Rohit Salgaocar instructed the trader of
Nuvama to get ready for 200 thousand shares for INR 1666 and then
instructed Nuvama’s trader to place the TIINDIA order. Afterwards,
Nuvama’s trader provided to Rohit, continuous updates about the order and
in the end confirmed order completion.

iii at 9:35 am, Ketan Parekh, in the group “Jack-Saro”, instructed to buy 1.65
lakh TIIINDIA at INR 1,666, to which Sam (mobile phone kept in the office
of FR2) confirmed that the 1.65 lakh TIINDIA was bought. The trade can
be correlated with the cumulative buy of 1.65 lakh shares of TIINDIA, in the
account of FR2.

iv The above trade resulted in an excess long quantity of 15,000 shares in

the account of FR2. In this respect Ketan Parekh, at 9:37 am instructed to
sell, after which Sam (mobile phone kept in the office of FR2) confirmed

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 the buy and sell of 1.65 lakh shares in TIINDIA. The excess 15,000 shares
were sold by FR2 at 9:37 am.

v In respect of the quantity and price at which Big Client was to buy TIINIDIA,
as explained above, Rohit Salgaocar, owing to his vast experience of
dealing with the Big Client and his insights in respect of the impact of the
Big Client orders on the existing demand and supply in the market, had a
fair idea about the size and the price at which the trades of the Big Client
could be executed.

vi This gets supported by the fact that on May 18, 2022, the volume in the
TIINIDIA jumped by almost 8.3 times (16.23 lakhs) in comparison to its 30
days’ average volume (1.95 lakhs). The Big Client, FR2 and FR6
contributed around 7.01 lakh shares to this volume, which is roughly 360%
of the average daily trading volume of last 30 days.

158. In view of the aforesaid illustration, it is seen that:

i The chats in the tables above and the timing of flow of information between
various entities, prima facie establishes that the information of the
forthcoming sell order of AXXXP Fund in the scrip TIINDIA reached to
Ketan Parekh in a perfectly time-coordinated manner.

ii As Rohit Salgaocar received the instructions from the Big Client about
selling TIINIDA that day, the same was communicated to Ketan Parekh,
who in turn instructed FR2 to sell shares of TIINIDA. Thereafter, just when
the Big Client orders to sell the shares of TIINDIA, Ketan Parekh
immediately instructed FR2 to place buy order, which matched with the sell
order of the Big Client.

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 iii Thus, armed with the knowledge of the impending sell orders of the Big
Client, Ketan Parekh got trades of such large quantity executed in the
account of FR2 and FR610, which otherwise it would not have undertaken.
This resulted in a match of 99.18% of the sell quantity of the Big Client in
the aforesaid time patches and a total square off profit of INR 7,53,405.65
for FR2 and FR6 as calculated in the table below:
Table no. 53
Calculation of unlawful gains made under this illustration
Average Average
FR Buy Qty Buy Value Buy Price Sell Qty Sell Value Sell Price Profit
FR2 1,65,000 27,48,89,667 1,666.00 1,65,000 27,54,22,676 1,669.23 5,33,008.85
FR6 61,153 10,19,56,719 1,667.24 61,153 10,21,77,116 1,670.84 2,20,396.80
Total Profit made by the FRs 7,53,405.65

Conclusion from the aforesaid illustrations

159. From the aforesaid illustrations, it is observed that FRs, either directly or through
facilitators, used to build positions in the same scrips ahead of the impending order
of the Big Client based on the NPI-based trading instructions received from Ketan
Parekh. As and when the substantial impending orders of the Big Client were placed
in the market, the FRs took counter positions upon instructions received from Ketan
Parekh to match with the position of the Big Client. This would lead to FRs either
squaring off of their initial position taken in the scrip or creating excess long or short
position in the scrip, which they eventually square off during the day and thus
generated huge illegal gains in a short span of time.

160. It is observed that the circumstances in which FRs were receiving instructions from
Ketan Parekh and thereafter trading in the securities markets revealed that they were
aware that these trading instructions were not genuine and were only possible with

10
Flow of NPI from Ketan Parekh to FR6 is discussed is discussed in Part D.5 of this order.
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Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
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 leakage of the substantial impending transactions in such scrips for the following
reasons:
i Being associated with securities market for a long time, FRs should have
known that the precise quantity/price and timing of the trading instruction
on a repetitive basis was not possible without access to some non-public
information regarding impending trades in the scrips that were being front
run;
ii The nature of the trading instructions communicated to FRs i.e. to take
positions on instant basis and then to square off such trades within the
same day to earn huge profits in a short span of time should have raised a
doubt in the minds of FRs regarding the sincerity of the trading instructions;
iii FRs were sharing profits earned through NPI-based trades with Ketan
Parekh in clandestine manner through banking and non-banking channels
as explained in Part I of this order;
iv The FRs were receiving trading instructions from Ketan Parekh who is
widely known for fraudulent activities in the securities markets and is still
undergoing criminal proceedings as detailed in Part M of this order and as
such there ought to have been suspicion regarding the authenticity of the
trading instructions.

161. In view of the above, I am of the view that FRs were fully aware about the nature of
fraudulent trading activity being committed through their trading accounts since they
were aware that the trading instructions received from Ketan Parekh were based on
some non-public information relating to the scrips in which they were executing
trades. Further, since large orders placed by FRs were repeatedly matching with the
counterparty at the desired price, they ought to have known, given their long
association with the securities markets, that the trading instruction received from
Ketan Parekh were matching substantial orders of another trader in those scrips.
Hence, while executing trading instructions received from Ketan Parekh, FRs were
aware that they were in possession of information which was not publically available

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Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
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 and there was a high probability that such information was regarding a substantial
impending transaction in securities.

162. Further, as illustrated above, these leakages were happening because Rohit
Salgaocar was divulging NPI about the impending order of the Big Client in various
scrips to Ketan Parekh, for executing the fraudulent scheme. Thus, it resulted in
unfair gains to following entities:
I. All FRs, in the form of profit made from the NPI-based trades carried out
in their trading accounts; and
II. Rohit Salgaocar, in the form of undue commission earned from Motilal
and Nuvama.

H. CALCULATION OF TOTAL UNLAWFUL GAINS MADE BY NOTICEES FROM

TRADING BASED ON NPI AND COMMISSION INCOME OF ROHIT SALGAOCAR

163. From the analysis of the trading activities and price of buy and sell transactions of
the FRs, clearly identifiable profit generating trades were found to have been
executed on various days during the Investigation Period through which the FRs
prima facie generated unlawful gains of INR 38.70 crores as depicted herein below:

Table no. 54
Profit earned by FRs during the Investigation Period

Equity Segment Equity Derivative Segment

Average Square Average
Gross Square off
Entit Cale No of Gross Traded Gross off Calend No of Gross
Traded earned
y ndar instan Value (INR In Traded earned ar instan Traded
Value (INR (INR In
days ces lakhs) Value (INR (INR In days ces Value (INR
In lakhs) lakhs)
In lakhs) lakhs) In lakhs)
FR1 85 97 4,79,943.93 4,947.88 559.54 26 26 16,954.90 652.11 41.37
FR2 175 218 9,65,519.81 4,428.99 1,241.02 4 4 5,265.12 1,316.28 4.18
FR3 43 46 3,73,959.92 8,129.57 485.63 - - - - -
FR4 3 3 20,332.25 6,777.42 17.22 - - - - -
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 Equity Segment Equity Derivative Segment
Average Square Average
Gross Square off
Entit Cale No of Gross Traded Gross off Calend No of Gross
Traded earned
y ndar instan Value (INR In Traded earned ar instan Traded
Value (INR (INR In
days ces lakhs) Value (INR (INR In days ces Value (INR
In lakhs) lakhs)
In lakhs) lakhs) In lakhs)
FR5 64 81 9,21,048.85 11,370.97 1,029.92 9 10 10,383.89 1,038.39 38.2
FR6 28 35 2,77,931.71 7,940.91 406.9 7 7 8590.58 1,227.23 46.39
Total 3740.23 130.14
Note: This table provides the instances where FRs earned a positive square off difference of INR 1 or more,
when day traded (80% squared off), commonly traded with the Big Client and there is matched quantity with
either of the FR.

164. Further, from the information provided by TMs, it was found that through trades
based on NPI, Rohit Salgaocar has also earned referral fee/commission of INR
8,06,29,054 (around INR 8.06 crore) and INR 19,00,44,520 (around INR 19 crore)
from Motilal and Nuvama, respectively. Thus, the total unlawful gain made by Rohit
Salgaocar is INR 27.07 crore which was only in respect of the trades of the Big Client
referred by SCPL/Rohit Salgaocar.

165. Thus, prima facie, Noticees made cumulative unlawful gains amounting to
approximately INR 65.77 crores (INR 38.70 crores by FRs + INR 27.07 crore by Rohit
Salgaocar). The individual and joint and several liabilities of Noticees are tabulated
in Table no. 64.

I. ILLUSTRATION OF PROFIT SHARING FROM FR TRADES

166. After elaborating the trade details, now I will examine the profit sharing between
various Noticees. From analysis of the WhatsApp data available on the devices
found during the Search and Seizure operation, statements made by FRs/ facilitators
and analysis of the bank statements of various entities, it is gathered that there were

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 numerous fund transfers, both through cash as well as bank transfers, between
Ketan Parekh and FRs/ facilitators.

167. Various illustrations of the money transfers between aforesaid entities have been
shown below, with the help of the screenshots of WhatsApp chats and extracts of
the bank account statements:
I. Fund transfers between Ketan Parekh and Sumit Sonthalia:
i Cash Transfer of INR 25 lakhs from Ketan Parekh (Jack New) to Sumit
Sonthalia, through Angadiya: With respect to this transaction,
discussions of Sumit Sonthalia with Ketan Parekh and with mobile
number XXX6123307 (saved as Sagar in the phone of Sumit Sonthalia
and Kau.New in the mobile of Sanjay Taparia) have been shown below.
Table no. 55
Cash transfer of INR 25 lakhs from Ketan Parekh (Jack New) to Sumit Sonthalia
Screenshot of chats from the WhatsApp of Chat Date Explanation
Sumit Sonthalia with
Jack 11/11/2022  Sumit asks Ketan
New Parekh for 25
(Ketan lakhs in Mumbai
Parekh)

Sagar 12/11/2022  Sumit messages

Sagar for 25 lakhs
in Mumbai, saying
that he had
discussed same
with Bhai (Ketan
Parekh).

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 Screenshot of chats from the WhatsApp of Chat Date Explanation
Sumit Sonthalia with
Sagar 14/11/2022  Sumit asked
Sagar about
update on fund
program.
 Sagar says that
funds will be
transferred
tomorrow.
Jack 14/11/2022  Sumit also asks
New Ketan Parekh for
(Ketan the fund program
Parekh) and tells that “Kau”
(Sagar) has told
him that 25 lakhs
will be transferred
tomorrow.
 Ketan Parekh, at
7:06 PM,
messages saying
that tell Kau that
funds are coming
tonight and will be
transferred
tomorrow.
Sagar 14/11/2022  Sumit sends same
message to Sagar.
 Also sends details
of Angadiya
(unofficial
channels) and
note, against
which payment is
to be made.

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 Screenshot of chats from the WhatsApp of Chat Date Explanation
Sumit Sonthalia with
Sagar 14/11/2022  Afterwards, Sagar
confirms, saying
tomorrow morning
it shall be done.

ii As seen in the chats above, Sumit Sonthalia was coordinating with

Ketan Parekh and Sagar in respect of a cash transfer of INR 25
lakhs. Further, Sumit Sonthalia in one of the chats with Ketan Parekh
said that Kau (mobile XXX6123307, saved in the name of Sagar in
his phone) had confirmed that transfer would happen tomorrow. In
response, Ketan Parekh told Sumit to message Kau that funds were
coming tonight and would be transferred tomorrow. Thereafter,
Sumit forwarded the same message to Sagar, saying “Bhai told to
message”.

iii Thus, mobile number XXX6123307, which is saved as Sagar in the

phone of Sumit Sonthalia or Kau New in the phone of Sanjay
Taparia, belongs to the same person and the said person works for
Ketan Parekh. Further, from the chats it is seen that Sumit Sonthalia
received INR 25 lakhs from Ketan Parekh, through Angadiya.

iv Cash Transfer of INR 50 lakhs from Sumit Sonthalia to Ketan Parekh

(Jack New), through Angadiya: This transaction involved
discussions only with mobile number XXX6123307, saved in the
name of Sagar (an associate of Ketan Parekh).

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 Table no. 56
Cash transfer of INR 50 lakhs from Sumit Sonthalia to Ketan Parekh (Jack New)
Screenshot of chats from the WhatsApp Date Explanation
of
Sumit Sonthalia
02/12/20  Sagar asks Sumit for
23 funds, saying that Boss
(Ketan Parekh) is asking.
 Sumit says a token of 50
lakhs will be done in
Mumbai

02/12/20  Sagar provides the details

23 of Angadiya and the note,
against which payment is
to be made.

03/12/20  Sumit, sends the photo of

23 same note to Sagar saying
“Paid” i.e. INR 50 lakhs
paid to the Angadiya.
 Sagar confirms receipt of
the same.

v From chats above, it can be seen that Ketan Parekh received INR
50 lakhs from Sumit Sonthalia, through Angadiya.

II. Fund transfers between Ketan Parekh and Sanjay Taparia:

i Bank Transfer of INR 65 lakhs from Ketan Parekh (Jack Latest.
New) to Sanjay Taparia
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 Table no. 57
Bank transfer of INR 65 lakhs from Ketan Parekh (Jack Latest.New) to Sanjay
Taparia
Screenshot of chats from the WhatsApp of Date Explanation
Sanjay Taparia
25/05/202  Sanjay Taparia sends account
3 details to Ketan Parekh (Jack
Latest. New), in which funds are
to be transferred.

25/05/202  Ketan Parekh confirms that INR

3 65 lakhs is transferred

Extract of Bank Statements 25/05/202  INR 65 lakh was transferred

Date Ba Account Nam Debit Credi 3 from the account of Realstone
nk Number e (in t Trading Company Private
Na INR) (in Limited to the account of
me INR) Samriddh Wire Products
25/05/ Uni 51010100 Reals 65,00 Private Limited, as confirmed
2023 on 6630212 tone ,000 by Ketan Parekh.
Ba Tradi
nk ng
of Com
pany

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 Screenshot of chats from the WhatsApp of Date Explanation
Sanjay Taparia
Ind Privat
ia e
Limit
ed
25/05/ Axi 91703006 Samri 65,00
2023 s 0547707 ddh ,000
Ba Wire
nk Prod
ucts
Privat
e
Limit
ed

ii From the aforesaid table, it can be seen that Ketan Parekh

transferred INR 65 lakhs to Sanjay Taparia, from the account of a
firm Realstone Trading Company Private Limited (hereinafter
referred to as “Realstone”).

iii Cash Transfer of INR 20 lakhs from Ketan Parekh to Sanjay Taparia,
through Angadiya: With respect to this transaction, discussions
between Sanjay Taparia with Shyam Rajkumar Saraogi, mobile no.
XXX0460230 (Shyam Rajkumar Saraogi of Salasar Stock Broking)
and Kau New, mobile number XXX6123307 (saved as Sagar in the
phone of Sumit Sonthalia) have been shown below.

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 Table no. 58
Cash transfer of INR 20 lakhs from Ketan Parekh to Sanjay Taparia
Screenshot of chats from the WhatsApp of Date Explanation
Sanjay Taparia
14/06/2023  Shyam sends details of a
person and the photo of
note to Sanjay Taparia.

15/06/2023  Sanjay Taparia send the

same details to Kau New

16/06/2023  Next day Sanjay Taparia

checks with Kau New if 20
lakhs have been
transferred.

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 Screenshot of chats from the WhatsApp of Date Explanation
Sanjay Taparia
19/06/2023  On June 19, 2023, Kau
New confirms that transfer
is done.
 Also sends photo of the
note and a receipt of
Angadiya, depicting details
of transfer and the name of
person which Shyam told to
Sanjay Taparia.

19/06/2023  Sanjay Taparia forwards

the same to Shyam.

iv From the table above, it can be seen that on June 14, 2023, Shyam
Rajkumar Saraogi sent details of a person and the photo of a 10
rupee note to Sanjay Taparia and thereafter on June 15, 2023,
Sanjay Taparia sent the same details to Kau.New (Associate of
Ketan Parekh). On June 19, 2023, Kau.New confirmed to Sanjay
Taparia that the transfer of money is done and also sent a photo of
the note and a receipt of Angadiya, depicting details of transfer (INR
20 lakhs) and the name of person which Shyam Rajkumar Saraogi
had informed to Sanjay Taparia on June 14, 2023. Thereafter
Sanjay Taparia forwards these details to Shyam Rajkumar Saraogi.

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 III. Fund transfers between Ketan Parekh and various entities of Rachit
Poddar (director of FR5 and FR6):
i From the aforesaid evidence, it is seen that Ketan Parekh had
transferred funds to Sanjay Taparia using the account of firm
Realstone. On analysis of the bank statement of this account, it is
noted that during the investigation period a total of 263 debit and
credit transactions have happened between the account of
Realstone and bank accounts of various firms of Rachit Poddar. A
summary of these transactions is as under:
Table no. 59
Fund transfers between Ketan Parekh and various entities of Rachit
Poddar
Money received Money paid from
Name of the account in the account of the account of
Account number
holder Realstone Realstone
(in INR) (in INR)
XXX00002635509 28,67,05,000.00 35,53,00,000.00
APR Properties Pvt Limited
XXX09836040066 25,86,63,232.00 22,78,16,000.00
Basukinath Properties Pvt
XXX72694719 5,65,50,000.00 5,06,00,000.00
Limited
R R Food Import LLP XXX00070966191 6,69,10,632.00 17,42,50,000.00
Hello Money Advisors LLP XXX09022357 2,38,70,483.00 -
Griebs Commosales XXX09334796 2,38,75,387.00 -
Total 71,65,74,734.00 80,79,66,000.00

ii Out of the account holders mentioned in the aforesaid table, NPI-

based trades were undertaken using the accounts of APR
Properties Private Limited and Basukinath Properties Private
Limited, of which Rachit Poddar is a Director. Further, RR Food
Import LLP, Hello Money Advisors LLP and Griebs Commosales

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 have only two partners viz. Rachit Poddar and Manju Poddar, aunt
of Rachit Poddar.

IV. Relationship between Realstone and Ketan Parekh

i On analysis of the bank account statement of the Realstone, it is
observed that the highest value of cumulative transfers (both debit
as well as credit) and highest number of transactions are observed
with an account of a firm called Classic Share and Stock Broking
Services Limited. A summary of the transactions between Realstone
and Classic Share is shown in the table below.
Table no. 60
Summary of the transactions between Realstone and Classic Share
Money Money paid Transaction
received in the from the count
Name of the account
Account number account of account of (both debit
holder
Realstone Realstone and credit)
(in INR) (in INR)
Classic Share And Stock XXX101005904421 1,02,02,89,859 84,13,78,688 500
Broking Services Limited

ii Classic Share and Stock Broking is an entity linked with Ketan

Parekh, as one of the Director of Classic Share is Kartik Parekh who
is brother of Ketan Parekh. Further, Ketan Parekh and Kartik Parekh
are common Directors in 4 companies namely – Triumph Securities
Limited, Classic Infin Limited, Panther Investrade Limited and
Saimangal Investrade Limited.

iii Thus it can be seen that the account of Realstone was in substance
used and controlled by Ketan Parekh.

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 V. Summary of bank transfers made between Realstone (front for
Ketan Parekh) and bank accounts of various FRs/ facilitators
i The table below shows the details of transactions done between the
bank account of Realstone Trading and bank accounts of FRs/
facilitators (as gathered from various WhatsApp chats between FRs
and Ketan Parekh/his associate and/or the bank account statement
of Realstone), during the investigation period.
Table no. 61
Summary of bank transfers made between Realstone and bank accounts of
various FRs/ facilitators
Money
Money paid
received in Transaction
Name of the from the
the account count
account Account number account of Details
of (both debit
holder Realstone
Realstone and credit)
(in INR)
(in INR)
APR XXX00002635509 28,67,05,000 35,53,00,000 117
Properties
XXX09836040066 25,86,63,232 22,78,16,000 94
Pvt Limited
Basukinath Rachit Poddar is Director of APR
Properties XXX72694719 5,65,50,000 5,06,00,000 14 Properties Private Limited and
Pvt Limited Basukinath Properties Private Limited
Griebs
XXX09334796 2,38,75,387 1
Commosales Rachit Poddar is Partner of Griebs,
Hello Money Hello Money, R R Food, along with his
Advisors XXX09022357 2,38,70,483 1 aunt, Ms. Manju Poddar.
LLP
RR Food
XXX00070966191 6,69,10,632 17,42,50,000 36
Import LLP

Sanghi Steel Rahul Saraf, employee of Sanjay

Udyog Pvt XXX033915 8,38,00,000 11,24,00,000 42 Taparia, shared the bank account details
Limited with the mobile number XXX6123307 (an

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 Money
Money paid
received in Transaction
Name of the from the
the account count
account Account number account of Details
of (both debit
holder Realstone
Realstone and credit)
(in INR)
(in INR)
associate of Ketan Parekh and which is
Askamdar
XXX8475000 8,45,00,000 7,97,00,000 27 saved as Kau. New in the phone of
Multicap LLP
Sanjay Taparia and Sagar in the phone
of Sumit Sonthalia)

Jaliyan
XXX0200000363 1,26,16,117 1,25,00,000 6
Commodity

Highgrowth Sanjay Taparia shared the bank account

Vincom PVT XXX001010230211 30,00,000 2 details with Ketan Parekh.
LIMITED

Samriddh
Wire
XXX030060547707 65,00,000 1
Products Pvt
Limited

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 Money
Money paid
received in Transaction
Name of the from the
the account count
account Account number account of Details
of (both debit
holder Realstone
Realstone and credit)
(in INR)
(in INR)
Sanjay Taparia shared the details of
bank account details to Kau New, an
associate of Ketan Parekh.
MVM
Commodities XXX40029324 65,00,000 27,84,610 4
Pvt Limited

168. The proof of information sharing between various entities pertaining to the account
numbers for transfer of money is show in the table below:
Table no. 62
Proof of information sharing between various entities
Name of Proof of information sharing
the Account
account number
holder

Sanghi
Steel
Udyog XXX033915
Pvt
Limited

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Askamda
r
XXX8475000
Multicap
LLP

Jaliyan
XXX02000003
Commod
63
ity

Highgrowt
h Vincom XXX00101023
PVT 0211
LIMITED

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MVM
Commodit
XXX40029324
ies Pvt
Limited

169. In view of the transactions/details showcased above, it is prima facie established that
there were regular cash/bank transactions between Ketan Parekh and various FRs/
facilitators. These transactions are nothing else but profit sharing amongst Noticees.

J. FACT FINDING TO SUPPORT ALLEGATION OF MODUS OPERANDI

170. The elaborate examination of the trading activities carried out in the account of FRs
prima facie indicates that orders were placed just ahead of the orders of the Big
Client based on the NPI about such impending orders in various scrips. As seen from
the extracts of Bloomberg chats produced in different parts of this order, it was Rohit
Salgaocar who, while advising traders of the Big Client, was in possession of time-
sensitive NPI pertaining to the impending orders of the Big Client in various scrips.
He was also instructing traders of Motilal and Nuvama about the execution of the
trades of the Big Client and was getting updates from them. Further, it has been
admitted in the statements under oath by both Rohit Salgaocar and Ketan Parekh
that they used to interact with each other over WhatsApp during the Investigation
Period and the same has also been corroborated by the data obtained from IPDR of
the mobile numbers of Ketan Parekh. Considering this and in light of the evidence
that Ketan Parekh was able to communicate this time-sensitive NPI which was
available with Rohit Salgaocar within minutes to the FRs. either directly or through
facilitators, leads to an inference that Ketan Parekh was obtaining the time-sensitive
NPI from Rohit Salgaocar over WhatsApp.
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171. In the present case, it has been prima facie noted from the factual details of trading
activities carried out in the accounts of the FRs that generally the first leg of order
placement was ahead of the order placement of the Big Client; and the second leg
(reversal of first trade) of such order was in sync with the order placement of the Big
Client. Further, in instances where any excess short or long position was created in
the account of FRs while matching with the Big client, the same was also squared
off during the day. In the process the aforesaid Noticees were successful in
generating quick profits. Such clearly identifiable profit generating trades were found
to have been executed on various days during the Investigation Period through which
the FRs generated unlawful gains of around INR 38.69 crores as provided in Table
no. 54.

172. Further, it is prima facie established from the details of WhatsApp chats and bank
statements of various Noticees that Ketan Parekh used to send/receive money both
in cash and through bank transfer to/from the facilitators and the FRs. Thus,
empowered with the information about the impending orders in various scrips,
Noticees unlawfully enriched themselves at the expense of other investors who were
not privy to such NPI.

K. EXAMINATION OF LEGAL ISSUES TO DETERMINE IF THERE IS A VIOLATION

173. In the instant matter, it is seen that the mechanism of execution of fraudulent trades
by the FRs is a modified form of “front running” since the FRs have applied ingenious
strategies to substantially increase their profits as compared to traditional front
running. The strategies employed are explained in detail in the ensuing paragraphs.

174. The term “front running” is defined under SEBI’s Circular no. CIR/EFD/1/2012 dated
May 25, 2012. While referring to the said definition, and other definitions of front

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 running, the Hon’ble Supreme Court in the matter of in the matter of SEBI Vs. Shri
Kanaiyalal Baldevbhai Patel and ors. [(2017) 15 SCC 1] observed as:
…17. SEBI has defined front-running in one of its circular
(CIR/EFD/1/2012 dated May 25, 2012) in the following manner-

Front-running; for the purpose of this circular, front running means

usage of non-public information to directly or indirectly, buy or sell
securities or enter into options or futures contracts, in advance of a
substantial order, on an impending transaction, in the same or related
securities or futures or options contracts, in anticipation that when the
information becomes public; the price of such securities or contracts
may change.

….

19. In actuality, front-running is more complicated than these definitions

suggest. It comprises of at least three forms of conduct. They are: (1)
trading by third parties who are tipped on an impending block trade
("tippee" trading); (2) transactions in which the owner or purchaser of the
block trade himself engages in the offsetting futures or options
transaction as a means of "hedging" against price fluctuations caused
by the block transaction ("self-front-running"); and (3) transactions where
a intermediary with knowledge of an impending customer block order
trades ahead of that order for the intermediary's own profit ("trading
ahead")….”

175. Based on the afore-quoted judgment, the following may be listed as ingredients to
classify a trading activity as front running:
I. There is existence of an information regarding a substantial order on
behalf of a Big Client in a particular security, and such information is not
available publicly;

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 II. Based on such information about impending orders in various scrips,
order (s) is/are placed in the account of Front Runner (“FR Order”) in the
securities in advance of the order (s) of the Big Client. The FR order is
placed in alignment with the order of the Big Client i.e. if the Big Client is
going to buy securities, the FR order will also be of buying shares and vice
versa.
III. The placement of the buy orders of the Big Client generally causes the
prices of the scrip to move upward or the sell orders of the Big Client
generally causes the price to move downwards.
IV. During the time of placement of orders of the Big Client, the Front Runner
squares off his position and earns the difference in price which is majorly
attributable to the orders of the Big Client.

176. To summarise, when Big Client is going to buy shares, the Front Runner follows a
pattern of Buy-Buy–Sell, where first Buy trades are carried out in the account of
Front Runner; second set of Buy trades are carried out in the account of the Big
Client generally causing the prices to move upward and the third set of Sell trades
are squaring off the position by Front Runner. Similarly, in Sell-Sell-Buy pattern, the
Front Runner first short sells the shares before sell orders of the Big Client are placed
in the system and eventually buys the shares and earns profit.

177. The Front Running activity can either be carried out in cash segment or may also be
carried out in the derivatives (Futures and Options) segment. Following the patterns
explained above, the Front Runner may take a long position (in case of Buy-Buy-Sell
pattern) or may take a short position (in case of Sell-Sell-Buy pattern).

178. As per the generally understood definition of front running, an FR basis the
information with respect to substantial impending transaction of the Big Client and
builds a position in the market prior to the entry of the order of Big Client.
Subsequently, when the Big Client order enters into the market, the FR matches the

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 order of the Big Client by placing its order in near proximity to the order of the Big
Client. To illustrate, having knowledge of an impending substantial buy order of a Big
Client, FR buys 1,00,000 shares of ABC at an average price of INR 97.
Subsequently, the Big Client places order to buy 5,00,000 shares of ABC at a price
of INR 100 and the front runner matches this buy order by placing a sell order of
1,00,000 ABC at a price of INR 100. Thus, in this process front runner squares off its
position and earns undue profits, which in the current example comes out to be INR
3,00,000. This modus operandi of front running is known as Buy-Buy-Sell (BBS).

179. Similarly, when a FR first sells and then later on matches the sell order of Big Client
by placing a buy order, it is categorized as Sell-Sell-Buy (SSB). This kind of BBS or
SSB front running trading pattern is identified as traditional front running.

180. However, in the instant matter, the trading pattern of many trades executed by the
FRs does not always follow traditional front running trading pattern. In certain
instances, the FRs have modified the usual modus operandi of front running and,
thus, have adopted a novel approach to benefit from the NPI with respect to
substantial impending transaction of the Big Client. After the traditional BBS and SSB
trading strategy, the prices in a scrip generally retrace to normal levels after the big
trades get executed. A person equipped with the knowledge of the impending big
order and knowing how the prices in the scrip behave post such big trades can
undertake NPI-based trades by matching quantities with Big Client as well as by
taking positions in larger quantities than the position of Big Client and then squaring
off their excess position when the prices in the scrip retrace to normal levels. In both
the instances, FR can make huge profits in a short span of time.

181. The aforesaid approach can be understood as Buy-Buy-Sell-Buy (BBSB) or Sell-

Sell-Buy-Sell (SSBS) or Sell-Buy-Sell (SBS) or Buy-Sell-Buy (BSB). The same is
explained below:

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 i. Buy-Buy-Sell-Buy (BBSB): Based on prior knowledge about impending
buy order of the Big Client, the FR takes a buy position in the scrip prior to
entry of the Big Client. When the Big Client places its buy order, the FR
matches it with its sell order. However, the sell quantity of the FR is higher
than the buy position, which it had earlier built in the scrip. Thereafter, during
the day as price in the scrip retraces to its normal level, the FR squares off
its short position in the scrip (i.e. built due to sell trades undertaken in excess
of its earlier buy position) by undertaking buy trades during the day. Thereby,
FR increases his payoff vis-à-vis the payoff he would have earned had he
only squared off his position against the trades of Big Client only. This
pattern of NPI-based trades is labelled as BBSB (shown in picture below).
Figure no. 8
Depiction of Buy-Buy-Sell-Buy (BBSB) Strategy

Sell by the
Buy by FR -
FR -
Buy by the Buy by the squares off
matching
FR Big Client excess
with Big
short
Client

ii. Sell-Sell-Buy-Sell (SSBS): The converse of BBSB trading strategy can be

understood as SSBS trading strategy. Based on prior knowledge about
impending sell order of the Big Client, the FR builds a sell position in the
scrip. When the Big Client places its sell order, the FR matches it with its
buy orders. However, the buy quantity of the FR is higher than the sell
position, which it had earlier built in the scrip. Thereafter, during the day as
price in the scrip retraces to its normal level, the FR squares off its long
position in the scrip (i.e., built due to buy trades undertaken in excess of its
earlier sell position) by undertaking sell trades. Thereby increasing his
payoff vis-à-vis the payoff he would have earned had he only squared off his

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 position against the trades of Big Client. This pattern of NPI-based trades is,
thus, labelled as SSBS (shown in picture below).
Figure no. 9
Depiction of Sell-Sell-Buy-Sell (SSBS) Strategy

Buy by
Sell by FR
Sell by the FR -
Sell by - squares
the Big matching
the FR off excess
Client with Big
long
Client

iii. Buy-Sell-Buy (BSB): Based on the prior knowledge about impending buy
order of the Big Client, the FR matches it with its sell trades. However, this
sell has been done by the FR without any initial buy in the scrip, thereby,
creating a short position in the scrip. Due to the buy order of the Big Client,
there is a sudden rise in the demand for the scrip, leading to rise in prices.
However, once the buy order of the Big Client gets executed, the price in
the scrip retraces to its normal level. Thus, FR squares off its short position
in the scrip (i.e. created by matching its sell trades with the buy trades of the
Big Client) throughout the day. This pattern of NPI-based trade is labelled
as BSB trading strategy (shown in picture below).
Figure no. 10
Depiction of Buy-Sell-Buy (BSB) Strategy

Buy by the Big Sell by the FR - matching Buy by FR - squares off

Client with Big Client short position

iv. Sell-Buy-Sell (SBS): Based on the prior knowledge about impending sell
order of the Big Client, the FR matches it with its buy trades. However, this
buy has been done by the FR without any initial sell in the scrip, thereby,
creating a long position in the scrip. Due to the sell order of the Big Client,
there was a sudden fall in the demand for the scrip, leading to depression in

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 prices. However, once the sell order of the Big Client gets executed, the
price in the scrip retraces to its normal level. FR squares off its long position
in the scrip (i.e. created by matching its buy order with the sell order of the
Big Client) throughout the day. This pattern of NPI-based trades is, thus,
labelled as SBS (shown in picture below).
Figure no. 11
Depiction of Buy-Sell-Buy (BSB) Strategy

Sell by Buy by the FR - Sell by FR -

the Big matching with squares off
Client Big Client long position

182. In the instant matter, in addition to the traditional BBS and SSB front-running
strategies, the FRs have used BBSB, SSBS, BSB and SBS trading strategies to take
advantage of the prior knowledge of the orders of the Big Client as explained above.
The aforesaid strategies are nothing but an extended form of front-running since the
orders are placed in securities by FRs, while directly or indirectly in possession of
information that is not publically available, regarding a substantial impending
transaction in that securities, its underlying securities or its derivative.

183. When the examination of trades carried out in the earlier part of this order is
considered with a lens of the definition of front running elaborated above, I hold,
prima facie, that the trades executed in the accounts of the FRs were in the nature
of extended front running of the trades of the Big Client. It is for this reason that in
this order profit makers who carried out extended form of front running are called
front runners. It may be emphasised that the trading patterns showing identifiable
patterns are themselves sufficient to prima facie hold such trades as extended front
running, however, the present case has direct evidence in the form of statement of
Noticees and also other corroborative evidences in term of Bloomberg chats,
Whatsapp Chats, phone calls, digital footprints of IP address etc.

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184. Having examined the trades executed in the account of the FRs, where it has been
observed with strong evidences that trades in the above mentioned Noticees account
were in the nature of extended front running the trades of the Big Client, it become
imperative now to make a further examination as to whether the acts on the part of
Noticees can prima facie be in violation of provisions of clauses (a), (b), (c) and (e)
of section 12A of the Securities and Exchange Board of India Act, 1992 and clauses
(a), (b), (c), (d) of regulation 3, sub-regulation (1) of regulation 4 and clause (q) of
sub-regulation (2) of regulation 4 read with clause (c) of sub-regulation (1) of
regulation 2 of the SEBI (Prohibition of Fraudulent and Unfair Trade Practices)
Regulations, 2003, (PFUTP Regulations). In case the answer to the above in
affirmative, it is to be examined whether the facts of the matter warrant an urgent
action while exercising power bestowed under the provisions of section 11, section
11B of the SEBI Act and clause (d) of sub-regulation 1 of regulation 11 of the PFUTP
Regulations. Before proceeding further, it is necessary to refer the relevant
provisions of law which are reproduced here under for reference:

“SEBI Act, 1992

Functions of Board.

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.

11 (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: —

…
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 (d) impound and retain the proceeds or securities in respect of any
transaction which is under investigation;

….

(4A) Without prejudice to the provisions contained in sub-sections (1), (2),

(2A), (3) and (4), section 11B and section 15-I, the Board may, by an order,
for reasons to be recorded in writing, levy penalty under sections 15A, 15B,
15C, 15D, 15E, 15EA, 15EB, 15F, 15G, 15H, 15HA and 15HB after holding
an inquiry in the prescribed manner.

Power to issue directions and levy penalty.

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
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 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.

(2) Without prejudice to the provisions contained in sub-section (1), sub-

section (4A) of section 11 and section 15-I, the Board may, by an order, for
reasons to be recorded in writing, levy penalty under sections 15A, 15B, 15C,
15D, 15E, 15EA, 15EB, 15F, 15G, 15H, 15HA and 15HB after holding an
inquiry in the prescribed manner.

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.

(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,
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 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;

….

(e) deal in securities while in possession of material or non-public information

or communicate such material or non-public information to any other person,
in a manner which is in contravention of the provisions of this Act or the rules
or the regulations made thereunder;

Delegation.

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.

Contravention by companies.

27. (1) Where a contravention of any of the provisions of this Act or any rule,
regulation, direction or order made thereunder has been committed by a
company, every person who at the time the contravention was committed
was in charge of, and was responsible to, the company for the conduct of the
business of the company, as well as the company, shall be deemed to be
guilty of the contravention and shall be liable to be proceeded against and
punished accordingly:

Provided that nothing contained in this sub-section shall render any such
person liable to any punishment provided in this Act, if he proves that the
contravention was committed without his knowledge or that he had exercised
all due diligence to prevent the commission of such contravention.

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 PFUTP Regulations

2. (1) In these regulations, unless the context otherwise requires, —

(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,

(7) deceptive behaviour 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.

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 (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;

Nothing contained in this clause shall apply to any general comments made in
good faith in regard to—

(a) the economic policy of the government

(b) the economic situation of the country

(c) trends in the securities market or

(d) any other matter of a like nature whether such comments are made in public
or in private;

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 thereunder;

(c) employ any device, scheme or artifice to defraud in connection with

dealing in or issue of securities which are listed or proposed to be listed on
a recognized stock exchange;

(d) engage in any act, practice, course of business which operates or would
operate as fraud or deceit upon any person in connection with any dealing in
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 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 thereunder. Prohibition of manipulative, fraudulent and
unfair trade practices

Regulation 4 (1) Without prejudice to the provisions of regulation 3, no person

shall indulge in a fraudulent or an unfair trade practice in securities.

Regulation 4 (2) Dealing in securities shall be deemed to be a fraudulent or

an unfair trade practice if it involves–

...(q) any order in securities placed by a person, while directly or indirectly in

possession of information that is not publically available, regarding a
substantial impending transaction in that securities, its underlying securities
or its derivative.”

185. As noted above that in case, records indicate violation of aforesaid provisions, it will
be required to be examined whether sufficient grounds are present necessitating
issuance of interim directions under sub-sections (1) and (4) of section 11, and sub-
section (1) of section 11B of the SEBI Act.

186. I note that the clauses (a), (b) and (c) of section 12A of the SEBI Act, 1992 and
regulations 3 and 4 quoted above, 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;
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

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 contravention of the provisions of the SEBI Act or rules or regulations;
or
v. dealing in securities while in possession of material or non-public
information or communicate such material or non-public information
to any other person in contravention of the provisions of the SEBI Act
or rules or regulations made thereunder.

187. Sub-regulation (1) of regulation 4 of the PFUTP Regulations prohibit any person to
indulge in fraudulent transaction and unfair trade practice in securities. The term
“fraud” of “fraudulent” are defined broadly in clause (c) of sub-regulation (1) of
regulation 2 of the PFUTP Regulations. An act of front running a trade is clearly
covered as “fraudulent transaction” in the definition. Further, clause (q) of sub-
regulation (2) of regulation 4 of the PFUTP Regulations stipulates that any order of
securities placed by a person while directly/indirectly in possession of an information
pertaining to a substantial impending transaction in such securities, shall be deemed
to be fraudulent transaction. This particular clause clearly makes front running a
fraudulent transaction. Thus, buying, selling or dealing in securities in a fraudulent
manner leads to violation of provisions of section 12A of the SEBI Act read with
regulations 3 and 4 of the PFUTP Regulations.

188. In the present case, it has been elaborated in detail based on factual evidence as to
how Rohit Salgaocar and Ketan Parekh have prima facie devised a scheme in where
Ketan Parekh was obtaining NPI about the impending order of the Big Client from
Rohit Salgaocar and passing trading instructions on the basis of such NPI to FRs,
either directly or through facilitators, who took positions in various scrips ahead of
the order of the Big Client in those scrips. As and when the orders on behalf of the
Big Client containing large quantities were placed, the FRs were directed to take
counter positions, so as to match with the order of Big Client. This would lead to FRs
either squaring off of their initial position taken in the scrip or creating excess long or
short position in the scrip, which they would eventually square off during the day,
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 thereby, generating undue profits in quick span of time. The investigation has also
brought out evidence about the sharing of unlawful profits between Noticees in cash
as well as banking transactions. All the acts on the part of Noticees elaborated in the
present order indicates towards the scheme that was crafted for personal gains and
to defraud the investors, as the NPI pertaining to the impending transactions in
various scrips was encashed to make unlawful gains in the accounts of the FRs.

189. In view of the analysis of the facts of the present case, I hold that there is a prima
facie case of fraudulent and unfair trade practice carried out by Noticees which
resulted in accrual of unlawful gains of INR 65,77,11,547 (INR 38.70 crores by FRs
+ INR 27.07 crore by Rohit Salgaocar) in the accounts of Rohit Salgaocar and the
FRs. The analysis carried out in the present order backed by evidence leads to a
prima facie conclusion that the violation of clauses (a), (b), (c), (e) of section 12 A
and clauses (a), (b), (c), (d) of regulation 3, sub-regulation (1) of regulation 4, clause
(q) of sub-regulation (2) of regulation 4 of the PFUTP Regulations have been
committed by Noticees herein as under:
i. Noticees have employed fraudulent/manipulative or deceptive device
or contrivance, in contravention of the provisions of the SEBI Act,
1992 and the PFUTP Regulations.
ii. Noticees have employed a device/scheme or artifice to defraud
investors and for that they have engaged in act, practice, course of
business which operated as fraud or deceit upon investors in
contravention of provisions of the SEBI Act, 1992 and the PFUTP
Regulations as quoted above.
iii. Noticees have dealt in securities or facilitated such dealing, while in
possession of material or non-public information in the form of
advance information about the impending orders in various scrips.
iv. The dealing in securities by the aforesaid Noticees in manner as
elaborated in the present order is fraudulent and an unfair trade
practice and was in the nature of extended front running.

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190. I note that in a similar matter (Madhu Chanda and others vs. SEBI, Appeal no. 335
of 2023, Date of decision: October 30, 2023) involving front running in multiple
accounts, the Hon’ble Securities Appellate Tribunal (SAT) has inter alia observed as:
“…We find that the very nature front running refers to an extremely precise
trading activity which is impossible to achieve unless the front runner had
access to the non-public information about the impending orders of the Big
Client (in this case the, Sterling group). For this reason, matching of common
scrip days, common percentage of shares, precise matching of price by the front
runner with the Big Client, earning significant amounts of profits on common
scrip days with the Big Client when compared to non-common scrip days are all
extremely strong indicators that the front runners were placing its orders ahead
of and in tandem with the large orders of the Big Client in order to make gains
for themselves. Thus, due to the trading based on prior information of trades of
the Sterling group, the front runners and the entities who facilitated them gained
unlawfully and caused loss to other investors / deprived the investors from
profits.
…We find that a sample analysis of the trades placed in the accounts of each
of the front runners vis-a-vis the trades in the account of the respective
Sterling group entity has been carried out meticulously in the WTM order as
well as the respective AO orders which clearly establish the manner in which
the front running trades were carried out.

191. On the basis of examination of evidences collected during the investigation, I prima
facie hold that:
i. Noticees were involved in extended front running the trades of the Big
Client.
ii. The said acts on the part of Noticees are fraudulent in terms of clause
(c) of sub-regulation (1) of regulation 2 of the PFUTP Regulations and
is violative of clauses (a), (b), (c) and (e) of section 12 A of the SEBI
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 Act, 1992 read with clauses (a), (b), (c), (d) of regulation 3, sub-
regulation (1) of regulation 4 and clause (q) of sub-regulation (2) of
regulation 4 of the PFUTP Regulations.

L. LIABILITY OF DIRECTORS OF FR1, FR2, FR5 AND FR6

192. Four of the FRs, in whose proprietary trading account NPI-based trades were carried
out namely, GRD Securities Limited, Salasar Stock Broking Limited, Basukinath
Properties Private Limited and APR Properties Private Limited are not natural person
but are companies incorporated in India. Section 27 of the SEBI Act enunciates the
liability of a director, manager, secretary or other officer of the company for the
contraventions committed by such company. In terms of sub-section (1) of section
27 of the SEBI Act, every person who at the time the contravention was committed
was in charge of, and was responsible to, the company for the conduct of its business
shall be deemed to be guilty of the contravention along with the company. However,
such presumption is rebuttable if such person proves that the contravention was
committed without his or her knowledge or that he or she had exercised all due
diligence to prevent the commission of such contravention.

193. In order to ascertain the liability of the person responsible for the conduct of its
business of the corporate FRs, a table containing the details of directors who were
in charge of, and were responsible to, the company for the conduct of its business
during the Investigation Period and the role played by them is provided below:

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 Table no. 63
Liability of the directors for contraventions committed by FR companies
Whether
Date of Date of
Designation charged Rationale for charging or not
Name appointment retirement
(Category) as charging the directors
of director of director
Noticee

GRD Securities Limited

Pramod Kumar Drolia was the

managing director and promoter of
GRD Securities Limited at the time
the contravention was alleged to be
Pramod committed by the company and was
Managing Director
Kumar 01/08/2007 Not retired Yes in such capacity in charge of, and
(Promoter)
Drolia responsible to, the company for the
conduct of its business and hence is
prima facie held to be guilty of the
alleged contravention committed by
GRD Securities Limited.
Bimal Kumar Drolia was the Whole-
Time Director and promoter of GRD
Securities Limited at the time the
Bimal Whole-Time contravention was alleged to be
Kumar Director 01/08/2007 Not retired Yes committed by the company and was
Drolia (Promoter) in such capacity in charge of, and
responsible to, the company for the
conduct of its business and hence is
prima facie held to be guilty of the

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 Whether
Date of Date of
Designation charged Rationale for charging or not
Name appointment retirement
(Category) as charging the directors
of director of director
Noticee
contravention committed by GRD
Securities Limited.
Anita Drolia was the executive
director and promoter of GRD
Securities Limited at the time the
contravention was alleged to be
committed by the company and was
Anita Director
06/01/2020 11/11/2021 Yes in such capacity in charge of, and
Drolia (Promoter)
responsible to, the company for the
conduct of its business and hence is
prima facie held to be guilty of the
contravention committed by GRD
Securities Limited.
Priya Saraf was an independent
director at the time the contravention
was alleged to be committed and in
such capacity is not deemed guilty of
alleged contravention committed by
the company since she is not
Priya Director
15/07/2022 Not retired Yes presumed to be in charge of the day-
Saraf (Independent)
to-day activities of the company.

However, the physical computer

system with CTCL ID
‘700020002063’ which was found in
the office of Sanjay Taparia was
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 Whether
Date of Date of
Designation charged Rationale for charging or not
Name appointment retirement
(Category) as charging the directors
of director of director
Noticee
registered in the name of Priya Saraf
(as detailed in Table no. 9) and hence
it is inferred that she facilitated trading
in the proprietary trading account of
GRD Securities Limited through her
CTCL ID. Since there is direct
evidence on record to show her
involvement in the alleged
contravention, she is deemed to be
in-charge of the company for the
contravention committed by the
company and hence deemed guilty.
Nainaa Drolia was an independent
director at the time the contravention
was committed and in absence of
direct evidence on record to show that
Nainaa Director
04/12/2021 15/07/2022 No she was in charge of, and responsible
Drolia (Independent)
to the company for the alleged
contravention, she is not held guilty of
the alleged contravention committed
by GRD Securities Limited.
Satyam Saraf was an independent
director at the time the contravention
Satyam Director
30/09/2016 Not retired No was committed and in absence of
Saraf (Independent)
direct evidence on record to show that
he was in charge of, and responsible
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 Whether
Date of Date of
Designation charged Rationale for charging or not
Name appointment retirement
(Category) as charging the directors
of director of director
Noticee
to the company for the alleged
contravention, he is not held guilty of
the alleged contravention committed
by GRD Securities Limited.

Salasar Stock Broking Limited

Kiran Kumar Sonthalia was the

Whole-Time Director of Salasar Stock
Broking Limited at the time the
contravention was alleged to be
Kiran committed by the company and was
Whole-Time
Kumar 30/12/1994 Not retired Yes in such capacity in charge of, and
Director(-)
Sonthalia responsible to, the company for the
conduct of its business and hence is
prima facie held to be guilty of the
contravention committed by the
company.
Shyam Saraogi was the Whole-Time
Director of Salasar Stock Broking
Limited at the time the contravention
Shyam Whole-Time was alleged to be committed by the
11/01/2019 Not retired Yes
Saraogi Director(-) company and was in such capacity in
charge of, and responsible to, the
company for the conduct of its
business and hence is prima facie
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 Whether
Date of Date of
Designation charged Rationale for charging or not
Name appointment retirement
(Category) as charging the directors
of director of director
Noticee
held to be guilty of the contravention
committed by the company. Further,
there is evidence on record to show
his direct involvement in the
commission of alleged contravention
as brought out in this order.

Further, as discussed in this order,

following evidences show his active
involvement in the alleged violations
as facilitator:

i. Shyam Saraogi was a member

of the WhatsApp group named
“Jack-Saro”, in which Ketan
Parekh provided NPI-based trade
instructions pursuant to which
such trades were executed from
the proprietary account of Salasar
Stock Broking Limited.

ii. Shyam Saraogi colluded with

Sanjay Taparia and an associate
of Ketan Parekh to transfer money
through Angadiya.

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Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
Page 163 of 188
 Whether
Date of Date of
Designation charged Rationale for charging or not
Name appointment retirement
(Category) as charging the directors
of director of director
Noticee
Pradeep Kumar Saraogi was an
independent director at the time the
contravention was alleged to be
committed by the company and in
such capacity is not prima facie held
to be guilty of alleged contravention
committed by the company since he
is not presumed to be in charge of the
day-to-day activities of the company.

However, the physical computer

system with CTCL ID
Pradeep
Director ‘700001002002’ through which the
Kumar 17/05/2005 Not retired Yes
(Independent) NPI-based trades were executed in
Saraogi
the proprietary trading account of
Salasar Stock Broking Limited was
found in the office of Company was
registered in the name of Pradeep
Kuma Saraogi (as detailed in Table
no. 12) and hence it is inferred that he
facilitated trading in the proprietary
trading account of Salasar Stock
Broking Limited through his CTCL ID.
Since there is direct evidence on
record to show his involvement in the
alleged contravention, he is deemed

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Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
Page 164 of 188
 Whether
Date of Date of
Designation charged Rationale for charging or not
Name appointment retirement
(Category) as charging the directors
of director of director
Noticee
to be in-charge of the company for the
contravention committed by the
company and hence prima facie held
guilty.
Ashok Tibrewal was the Whole-Time
Director of Salasar Stock Broking
Limited at the time the contravention
was alleged to be committed.
However, the evidence on record
shows that he has been in dispute
Ashok Whole-Time
30/12/1994 Not retired No with Salasar Stock Broking Private
Tibrewal Director(-)
Limited since 2016 (as per NCLT
case no. CP/21(KB) 2016) and is not
involved in the day to day operations
of the company. Accordingly, he is not
held guilty of the contraventions
committed by the company.

APR Properties Private Limited

Rachit Poddar was the director and

promoter of APR Properties Private
Rachit Director Limited at the time the contravention
30/09/2019 Not retired Yes
Poddar (Promoter) was alleged to be committed by the
company and was in such capacity in
charge of, and responsible to, the
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Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
Page 165 of 188
 Whether
Date of Date of
Designation charged Rationale for charging or not
Name appointment retirement
(Category) as charging the directors
of director of director
Noticee
company for the conduct of its
business and hence is prima facie
held to be guilty of the contravention
committed by the company.

Further, as discussed in this order,

following evidences show his active
involvement in the alleged violations
as facilitator:

i. Mobile number of Ketan Parekh

was saved as “Wellwisher” on the
mobile phone of Rachit Poddar;

ii. In the statement made by father

of Rachit Poddar i.e. Ashok Kumar
Poddar, he stated that Ketan
Parekh used to provide trade
related instructions to Ashok
Kumar Poddar over WhatsApp
call and messages. This is
corroborated by the analysis of
CDR which indicates that Ashok
Kumar Poddar had frequent

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Page 166 of 188
 Whether
Date of Date of
Designation charged Rationale for charging or not
Name appointment retirement
(Category) as charging the directors
of director of director
Noticee
interactions with Ketan Parekh
and his brother Kartik Parekh;

iii. In the statement made by

Ashok Kumar Poddar, he further
stated that he used to
communicate the NPI-based
trading instructions received from
Ketan Parekh to his son, Rachit
Poddar who then used to execute
the NPI-based trades in the
trading accounts of APR
Properties Private Limited and
Basukinath Properties Private
Limited through the systems
placed at their residence;

iv. The computer devices from

which NPI-based trades were
executed in the trading accounts
of APR Properties Private Limited
and Basukinath Properties Private
Limited were found at the
residential premises of Ashok
Kumar Poddar and Rachit Poddar;

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 Whether
Date of Date of
Designation charged Rationale for charging or not
Name appointment retirement
(Category) as charging the directors
of director of director
Noticee

v. The analysis of bank accounts

of various firms of Rachit Poddar
shows that during the
investigation period a total of 263
debit and credit transactions have
happened between the account of
Realstone (a firm associated with
Ketan Parekh) and bank accounts
of various firms of Rachit Poddar.

Manoj Kumar Agarwal was the

director and promoter of APR
Properties Private Limited at the time
the contravention was alleged to be
Manoj committed by the company and was
Director
Kumar 20/09/2022 Not retired Yes in such capacity in charge of, and
(Promoter)
Agarwal responsible to, the company for the
conduct of its business and hence is
prima facie held to be guilty of the
contravention committed by the
company.
Mahendra Kumar Agarwal was a
Mahendra
director of APR Properties Private
Kumar Director(-) 14/07/1995 25/04/2022 Yes
Limited at the time the contravention
Agarwal
was alleged to be committed and was
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 Whether
Date of Date of
Designation charged Rationale for charging or not
Name appointment retirement
(Category) as charging the directors
of director of director
Noticee
in such capacity in charge of, and
responsible to, the company for the
conduct of its business and hence is
prima facie held to be guilty of the
contravention committed by the
company.
Renu Agarwal was a director of APR
Properties Private Limited at the time
the contravention was alleged to be
committed and was in such capacity
Renu
Director(-) 31/01/2002 25/04/2022 Yes in charge of, and responsible to, the
Agarwal
company for the conduct of its
business and hence is prima facie
held to be guilty of the contravention
committed by the company.

Basukinath Properties Private Limited

Rachit Poddar was the director and

promoter of APR Properties Private
Limited at the time the contravention
Rachit was alleged to be committed by the
Director(Promoter) 30/09/2019 Not retired Yes
Poddar company and was in such capacity in
charge of, and responsible to, the
company for the conduct of its
business and hence is prima facie
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Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
Page 169 of 188
 Whether
Date of Date of
Designation charged Rationale for charging or not
Name appointment retirement
(Category) as charging the directors
of director of director
Noticee
held to be guilty of the contravention
committed by the company.

Further, as discussed in this order,

following evidences show his active
involvement in the alleged violations
as facilitator:

i. Mobile number of Ketan Parekh

was saved as “Wellwisher” on the
mobile phone of Rachit Poddar;

ii. In the statement made by father

of Rachit Poddar i.e. Ashok Kumar
Poddar, he stated that Ketan
Parekh used to provide trade
related instructions to Ashok
Kumar Poddar over WhatsApp
call and messages. This is
corroborated by the analysis of
CDR which indicates that Ashok
Kumar Poddar had frequent
interactions with Ketan Parekh
and his brother Kartik Parekh;
iii. In the statement made by
Ashok Kumar Poddar, he further

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 Whether
Date of Date of
Designation charged Rationale for charging or not
Name appointment retirement
(Category) as charging the directors
of director of director
Noticee
stated that he used to
communicate the NPI-based
trading instructions received from
Ketan Parekh to his son, Rachit
Poddar who then used to execute
the NPI-based trades in the
trading accounts of APR
Properties Private Limited and
Basukinath Properties Private
Limited through the systems
placed at their residence;

iv. The computer devices from

which NPI-based trades were
executed in the trading accounts
of APR Properties Private Limited
and Basukinath Properties Private
Limited were found at the
residential premises of Ashok
Kumar Poddar and Rachit Poddar;

v. The analysis of bank accounts

of various firms of Rachit Poddar
shows that during the
investigation period a total of 263

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 Whether
Date of Date of
Designation charged Rationale for charging or not
Name appointment retirement
(Category) as charging the directors
of director of director
Noticee
debit and credit transactions have
happened between the account of
Realstone (a firm associated with
Ketan Parekh) and bank accounts
of various firms of Rachit Poddar.

Manoj Kumar Agarwal was the

director and promoter of APR
Properties Private Limited at the time
the contravention was alleged to be
Manoj committed by the company and was
Kumar Director(Promoter) 20/09/2022 Not retired Yes in such capacity in charge of, and
Agarwal responsible to, the company for the
conduct of its business and hence is
prima facie held to be guilty of the
contravention committed by the
company.
Mahendra Kumar Agarwal was a
director of APR Properties Private
Limited at the time the contravention
Mahendra
was alleged to be committed and was
Kumar Director(-) 20/02/2001 25/04/2022 Yes
in such capacity in charge of, and
Agarwal
responsible to, the company for the
conduct of its business and hence is
prima facie held to be guilty of the

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 Whether
Date of Date of
Designation charged Rationale for charging or not
Name appointment retirement
(Category) as charging the directors
of director of director
Noticee
contravention committed by the
company.

194. In the matter of KK Ahuja v. V.K Arora (2009 10 SCC 48.), the Hon’ble Supreme
Court analysed the terms ‘in charge of’ and ‘responsible to’ in the context of vicarious
liability provisions and held that the ‘in-charge’ principle presents a factual test and
the ‘responsible to’ principle presents a legal test. The court held that a person would
be in-charge of the business of the company if the person is in overall control of the
day-to-day business of the company.

195. Thus, while an executive or whole-time director of the defaulting company can be
called to be ‘in charge of the business of the company’, an independent director or a
non-executive director, having no control over the day-to-day business of the
company might not be considered to be in charge of the business of the company
unless evidence to the contrary can be shown.

196. In view of the above and basis the legal principle contained in section 27 of the SEBI
Act, a rebuttable presumption can be drawn against the executive directors of the
FRs for fastening vicarious liability upon them for the contraventions committed by
the corporate FRs in the instant matter. Accordingly, for the reasons stated in the
table above. I find the aforesaid directors, except Nainaa Drolia, Satyam Saraf and
Ashok Tibrewal, are vicariously liable for the extended front-running activities
committed by the FR companies.

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Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
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 M. NEED FOR INTERIM EX-PARTE ORDER

197. I have already held that the acts imputed in the present order on Noticees are prima
facie held in violation of various provisions of the SEBI Act, 1992 and the PFUTP
Regulations. Now it would be important to examine as to whether this interim ex-
parte order is required to be passed. I note that sub-section (4) of section 11 and
section 11B allows SEBI to restrain persons from accessing the securities market
and prohibit any person associated with securities market to buy, sell or deal in
securities and to issue “such directions as may be necessary” in the interest of
investors of the securities market. The evidence of the present case speaks volume
about the intricate design that was at play. Traders of the Big Client were discussing
with Rohit Salgaocar prior to executing trades and such information was prima facie
encashed by Rohit Salgaocar by sharing the same with Ketan Parekh. While the
traders of the Big Client were discussing trades with Rohit Salgaocar for ensuring
counter parties for their trading, Rohit Salgaocar was using that information to make
illegal profits by routing information to Ketan Parekh. When the information reached
Ketan Parekh, he acted in a systematic manner and trades were executed in different
accounts which cumulatively generated unlawful profits. Ketan Parekh is not an
ordinary person. As discussed later, he was debarred from the securities markets for
14 years earlier also.

198. It is noted that a duty has been cast upon SEBI under section 11 to protect the
interests of investors in securities and to promote the development of and to regulate
the securities market. All the afore-quoted objects are equally crucial for growth of
the securities market. It is also noticed that any kind of manipulative activities by a
person or group of persons have impact on the securities market as a whole.
Therefore, it becomes essential that the investors and the securities market are
protected from the manipulative and unfair trade practices relating to securities
market and SEBI has been empowered to take any measures, as it deems fit to
achieve the mandate. The PFUTP Regulations have been framed with an objective
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Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
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 of preventing fraudulent and unfair trade practices relating to securities market, which
will aid in achieving the mandate of investor protection, regulation and development
of securities market.

199. A prima facie case of violation of various provisions of the SEBI Act, 1992 and the
PFUTP Regulations has already been made out against Noticees which is largely
backed by direct evidences on record. I observe that the association of some of the
Noticees to the securities market, their overall conduct and the manner in which they
have used technology to cover their tracks, necessitate to take emergent actions to
protect the integrity of the securities market, so that the interest of the investors is
not jeopardised. Further, at this stage, I also note the following factors:
I. All Noticees are closely associated with the securities market as
discussed above.
II. The trading activities which are prima facie swarmed with illicit design,
were repeatedly carried out for long period of time.
III. The concerned Noticees were able to generate large amount of profits
which is prima facie found to be unlawful, which may be siphoned off
beyond regulatory reach, if immediate steps are not taken.
IV. Further, I have considered other factors like the nexus that Noticees
have with each other; the use of technology by them to share
information, the sharing of profits of large amounts. Considering all
these factors, it becomes imperative for SEBI to protect siphoning off
of the unlawful gains made by Noticees, which may be liable for
disgorgement in the final proceedings.

200. At this juncture, it is also crucial to note that Ketan Parekh is a habitual offender and
has been found guilty of market manipulation in the past as well. Through his group
broking firms and investment companies, Ketan Parekh indulged in manipulative
trades which led to the stock markets crash in 2001. A Joint Parliamentary
Committee on Stock market scam and matters relating thereto was also constituted

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Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
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 on April 27, 2001 to probe, inter alia, into the irregularities and manipulations related
to the stock markets crash of 2001 and the Committee submitted its report on
December 19, 2002 wherein it noted that Ketan Parekh was the key player in the
scam and received large sums of money from banks as well as from Corporate
bodies during the period when SENSEX was falling rapidly and therefore
recommended SEBI to investigate the matter expeditiously. The investigations
conducted by SEBI into the alleged violations, inter alia, revealed that, Ketan Parekh
created artificial volumes and manipulations in various scrips during the period
between 1999 to 2001and accordingly various enforcements actions were initiated
against Ketan Parekh group entities including passing of various directions under
Section 11B of the SEBI Act, Adjudication Proceedings and Prosecution
Proceedings.

201. Vide SEBI order dated December 12, 2003, Ketan Parekh and his group entities
were prohibited from dealing in the securities in any manner, directly or indirectly,
and were also debarred from associating with the securities market for a period of
14 years. While the aforesaid order of debarment was in force, it was found that an
entity named Gibs Computers, which was controlled by Ketan Parekh, was trading
in the securities market despite clear embargo on Ketan Parekh to directly or
indirectly deal or associate with securities market. Accordingly, a monetary penalty
of one crore rupees was imposed on the entity by the Adjudicating Officer vide order
dated June 26, 2013.

202. SEBI has also initiated prosecution proceedings against Ketan Parekh and
connected entities. I note that in the said proceedings, Ketan Parekh has evaded the
service of summons, bailable warrants and non-bailable warrants and finally
appeared only after the issuance of proclamation by the court and after further follow-
ups by SEBI.

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Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
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203. In view of the above, considering the repetitive nature of violations by Ketan Parekh
and evidences gathered in the instant matter, I am of the view that an interim ex-
parte order is required to be passed in this matter to protect the interest of the
securities market and investors.

204. I seek to place reliance on the order of the Hon’ble Securities Appellate Tribunal,
passed in the matter of Amalendu Mukherjee Vs. SEBI (Appeal (L) no. 169 of
2020), wherein the Hon’ble Tribunal has underscored the necessity of passing
impounding orders by inter alia observing as:
“We are of the opinion that the WTM is empowered under the SEBI Act and
the Regulations to pass an ex-parte order in order to protect the interests of
securities market and the investors. If such impounding order is not passed,
it may result in defeating the ultimate direction of disgorgement if any, as
there would be chances of such monies being dissipated by the appellant.
…”

205. Based on the foundation of factors quoted above and in totality of the facts of the
present case, I am compelled to invoke the provisions under sub-section (1) of
section 11, sub-section (4) of section 11, section 11B of the SEBI Act, 1992 and
regulation 11 of the PFUTP Regulations, to hold that it is a fit case for passing interim
order and to impound the proceeds of prima facie unlawful gains made by Noticees.

N. BASIS OF DISGORGEMENT AND JOINT AND SEVERAL LIABILITY

206. Having held that in the facts of the present case, invocation of powers to issue interim
order is necessitated, the next issue that deserves consideration is fixing of prima
facie liability for impounding of unlawful gains which accrued due to deployment of
fraudulent scheme by Noticees. In this connection, I note that the explanation to sub-
section (1) of section 11B of the SEBI Act, 1992 inter alia empowers SEBI to issue

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Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
Page 177 of 188
 directions to any person, for disgorgement of wrongful gains made by him, by
contravention of any provision of the SEBI Act or the regulations made thereunder.

207. In order to fix the liability of the respective entities, it is noted that Rohit Salgaocar
was instrumental in obtaining the NPI about the substantial impending trades of the
Big Client in various scrips and Ketan Parekh, through facilitators and FRs, used
such information to execute front running trades.

208. Thus, apart from the FRs (in whose account the unlawful profit accrued), other
Noticees also played an active role for generation of the unlawful gains, making them
liable jointly and severally for impounding, with the respective Noticee in whose
account the profit accrued.

209. Further, in view of the findings in Part L of this order, the directors of various
companies are also liable to be proceeded against for the unlawful profits that
accrued to the Noticees and are held jointly and severally liable with their respective
companies, by virtue of section 27 of the SEBI Act, 1992.

210. In view of the aforesaid discussion and the calculation of unlawful gains made by
Noticees as detailed in Table no. 54, I hold that Noticees to be prima facie jointly and
severally liable for impounding of unlawful profits in the following manner:

Table no. 64
Joint and several liabilities of Noticees for impounding of wrongful gains
Amount of Entities jointly and
Sr. wrongful severally liable for
Noticee
No. gains made impounding of
(INR) wrongful gains
27,06,73,574
Rohit Salgaocar and
1. Rohit Salgaocar (Commission
Ketan Parekh
earnings)

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Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
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 Amount of Entities jointly and
Sr. wrongful severally liable for
Noticee
No. gains made impounding of
(INR) wrongful gains
Rohit Salgaocar, Ketan
6,00,91,126 Parekh, Sanjay Taparia,
(Profits made GRD Securities Limited,
2. GRD Securities Limited through Pramod Kumar Drolia,
fraudulent Bimal Kumar Drolia,
trading) Priya Saraf and Anita
Drolia
4,85,62,517
(Profits made
3. Anirudh Damani through
fraudulent Rohit Salgaocar, Ketan
trading) Parekh, Sanjay Taparia,
17,22,612 Anirudh Damani and
(Profits made Ashok Kumar Damani
4. Ashok Kumar Damani through
fraudulent
trading)
Subtotal 11,03,76,255

12,45,20,605 Rohit Salgaocar, Ketan

(Profits made Parekh, Sumit
Salasar Stock Broking
5. through Sonthalia, Salasar
Limited
fraudulent Stock Broking Limited,
trading) Kiran Kumar Sonthalia,
Shyam Saraogi and
Subtotal 12,45,20,605
Pradeep Kumar Saraogi

Rohit Salgaocar, Ketan

10,68,11,692 Parekh, Ashok Kumar
(Profits made Poddar, Basukinath
Basukinath Properties
6. through Properties Private
Private Limited
fraudulent Limited, APR Properties
trading) Private Limited, Rachit
Poddar, Manoj Kumar

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Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
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 Amount of Entities jointly and
Sr. wrongful severally liable for
Noticee
No. gains made impounding of
(INR) wrongful gains
Agarwal and Mahendra
Kumar Agarwal
Rohit Salgaocar, Ketan
Parekh, Ashok Kumar
Poddar, Basukinath
4,53,29,421
Properties Private
(Profits made
APR Properties Private Limited, APR Properties
7. through
Limited Private Limited, Rachit
fraudulent
Poddar, Manoj Kumar
trading)
Agarwal, Mahendra
Kumar Agarwal and
Renu Agarwal
Subtotal 15,21,41,113
TOTAL 65,77,11,547

O. INTERIM ORDER

211. Thus, after analysing all the evidences on record I hold that this is a fit case to
exercise powers of passing interim order so as to insulate the securities market and
to protect the unlawful gains, which may go beyond regulatory reach. Accordingly, I,
in exercise of the powers conferred upon me under sub-section (1) of section 11,
sub-section (4) of section 11, sub-section (1) of section 11B read with section 19 of
the SEBI Act, 1992 read with regulation 11 of the PFUTP Regulations, hereby by
way of the present interim order cum show cause notice, issue the following
directions, which shall remain in force until further orders:
I. An amount of INR 65,77,11,547 (Sixty Five Crore Seventy Seven Lakh
Eleven Thousand Five Hundred Forty Seven Rupees), being the total
unlawful gain earned from the alleged violations, shall be impounded,
jointly and severally in manner provided in Table no. 64 and the Noticees
are directed to credit/deposit jointly/severally the aforesaid amount of
unlawful gains to interest bearing savings account(s) created specifically
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Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
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 for the purpose in a Scheduled Commercial Bank. The Noticees shall
create interest bearing savings account(s) with Lien in favour of SEBI and
the amount kept therein shall not be released without permission from
SEBI.
II. Noticees no. 1 and 2 i.e. Rohit Salgaocar and Ketan Parekh devised the
entire scheme to unjustly enrich from the NPI pertaining to the Big Client
by orchestrating front running activities. Noticee no. 10 has admitted to be
a facilitator in the front running activities. Further, Noticees no. 2 and 10 i.e.
Ketan Parekh and Ashok Kumar Poddar had been prohibited from dealing
in the securities and debarred from associating with the securities market
in the past as well. Considering the same, Noticees no. 1,2 and 10 shall be
restrained from buying, selling or dealing in securities or associating with
any intermediary registered with SEBI, either directly or indirectly, with
immediate effect.
III. Banks, where Noticees no. 1 to 22 are holding bank accounts, shall be
directed that no debits shall be made, without permission of SEBI, in
respect of the bank accounts held jointly or severally by Noticees, except
for the purposes of transfer of funds to the interest bearing savings
account(s) as stipulated above. Further, this direction shall not apply to
those bank accounts of Noticees no. 3 and 4 which deal with clients’ funds,
since Noticees no. 3 and 4 are stock brokers registered with SEBI and deal
with funds of clients.
IV. Depositories shall also be directed that no debit shall be made, without
permission of SEBI, in respect of the demat accounts held by Noticees.
However, credits, if any, into the accounts may be allowed.
V. 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.

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 VI. The Registrar and Transfer Agents shall ensure that, they neither permit
any transfer nor redemption of securities, including Mutual Funds units,
held by Noticees.
VII. Noticees shall not dispose of or alienate any of their assets/properties, till
such time the amount of unlawful gain is credited to an interest bearing
savings account except with the prior permission of SEBI.
VIII. 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 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.
IX. The directions stipulated in paragraph (III), (IV), (V), (VI) and (VII) shall
cease to apply upon credit of unlawful gains to the interest bearing savings
account as stipulated in sub-paragraph (I) of this paragraph.
X. If the 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 on the date of this order. Banks
are allowed to debit the accounts for the purpose of complying with this
direction.

212. The prima facie observations/findings contained in this Order are made on the basis
of the material available on record. In light of the alleged violations of the provisions
of the SEBI Act, 1992 and the PFUTP Regulations by Noticees, this Order shall be
treated as a Show Cause Notice under sub-section (1) of section 11, sub-section (4)
of section 11, sub-section (4A) of section 11, sub-section (1) of section 11B, and sub-

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Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
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 section (2) of section 11B of the SEBI Act, 1992 read with regulation 11 of the PFUTP
Regulations read with SEBI (Procedure for Holding Inquiry and Imposing Penalties)
Rules, 2005, calling upon all the Noticees to show cause as to why suitable directions
shall not be passed against them, including directions as proposed hereunder:
I. Direction to disgorge an amount equivalent to the total gains made on
account of alleged extended front running along with interest;
II. Direction to restrain them from accessing the securities market and
prohibiting them from buying, selling or otherwise dealing in securities for
an appropriate period;
III. Direction to restrain them from associating with any registered
intermediary; and
IV. Directions for imposition of penalty under sub-section (4A) of section 11
and sub-section (2) of section 11B read with section 15HA of the SEBI Act,
1992 against all Noticees.

213. Noticees may file their replies to SEBI within 21 days from the date of receipt of this
Order and avail an opportunity of personal hearing in the matter, if they so desire.

214. This Order is without prejudice to any other action that SEBI may initiate under the
securities laws, as deemed appropriate.

215. This Order shall come into force with immediate effect and shall be in force till further
Orders.

216. A copy of this Order shall be forwarded to:

I. Noticees, Stock Exchanges, Depositories, Registrar and Share Transfer
Agents and Banks to ensure necessary compliance;
II. Big Client, Nuvama and Motilal, enabling them to take appropriate actions
for strengthening their internal controls to prevent occurrence of violations
noted in the present Order;

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Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
Page 183 of 188
 III. Concerned departments of SEBI which deal with the regulation of
registered intermediaries involved in the instant matter such as the funds
of Big Client, Nuvama, Motilal, Salasar Stock Broking Limited and GRD
Securities Limited for examination of violation of other securities laws, if
any.

KAMLESH Digitally signed by

KAMLESH CHANDRA
CHANDRA VARSHNEY
Date: 2025.01.02 17:44:04
VARSHNEY +05'30'

PLACE: MUMBAI KAMLESH C. VARSHNEY

DATE: JANUARY 02, 2025 WHOLE TIME MEMBER
SECURITIES AND EXCHANGE BOARD OF INDIA

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Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
Page 184 of 188
 LIST OF FIGURES MENTIONED IN THE ORDER

Figure no. 1 Screenshot of WhatsApp chat between Sanjay Taparia and Ketan Parekh
..................................................................................................................................24
Figure no. 2 Establishing identity of Ketan Parekh ....................................................25
Figure no. 3 WhatsApp chat showing instructions given by Ketan Parekh in the group
Jack-ST .....................................................................................................................30
Figure no. 4 Screenshot of a message in the WhatsApp group “Jack-ST” ................38
Figure no. 5 Screenshot of a message in the WhatsApp group “Jack-Saro” .............39
Figure no. 6 Flow of NPI-based trading instructions from Ketan Parekh to FRs .......43
Figure no. 7 Flow of NPI regarding the trades of the Big Client ................................67
Figure no. 8 Depiction of Buy-Buy-Sell-Buy (BBSB) Strategy .................................145
Figure no. 9 Depiction of Sell-Sell-Buy-Sell (SSBS) Strategy .................................146
Figure no. 10 Depiction of Buy-Sell-Buy (BSB) Strategy .........................................146
Figure no. 11 Depiction of Buy-Sell-Buy (BSB) Strategy .........................................147

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Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
Page 185 of 188
 LIST OF TABLES MENTIONED IN THE ORDER

Table no. 1 Details of entities whose premises were searched by SEBI .................... 3
Table no. 2 Details of contact numbers as obtained from various devices ................12
Table no. 3 IMEI analysis of various phone numbers of Ketan Parekh .....................19
Table no. 4 Location analysis of various phone numbers of Ketan Parekh ...............20
Table no. 5 Details confirmed by Hotels ....................................................................22
Table no. 6 Flight Details of Ketan Parekh ................................................................24
Table no. 7 Details of the WhatsApp group “Jack-ST” ..............................................31
Table no. 8 Details from CDR of Sanjay Taparia and Damanis ................................32
Table no. 9 Placement of orders in the trading account of GRD Securities Limited ..33
Table no. 10 Pattern of buying by FR1 and FR3 on November 11, 2022 ..................38
Table no. 11 Details of the members of the WhatsApp group “Jack-Saro”................40
Table no. 12 Placement of orders in the prop account of Salasar Stock Broking Limited
..................................................................................................................................41
Table no. 13 Details from CDR of Ashok Kumar Poddar...........................................42
Table no. 14 Details of trades executed by FRs before and during the Investigation
Period ........................................................................................................................44
Table no. 15 Trading profile of Salasar Stock Broking Limited (FR 2) .......................46
Table no. 16 Trading profile of GRD Securities Limited (FR1) ..................................48
Table no. 17 Trading profile of Anirudh Damani (FR 3) .............................................49
Table no. 18 Trading profile of Ashok Kumar Damani (FR4) .....................................50
Table no. 19 Trading profile of Basukinath Properties Private Limited (FR5) ............51
Table no. 20 Trading profile of APR Properties Private Limited (FR6) ......................52
Table no. 21 Extract of Bloomberg chat between Rohit Salgaocar and Trader of Big
Client .........................................................................................................................56
Table no. 22 Change in Gross Traded Value (GTV) in the order flow of the Big Client
to Motilal ....................................................................................................................60
Table no. 23 Clients referred to Nuvama by SCPL during the Investigation Period ..62
Table no. 24 Change in Gross Traded Value (GTV) in the order flow of the Big Client
to Nuvama .................................................................................................................63
Table no. 25 Extract of Bloomberg chat between Rohit Salgaocar and Trader of Motilal
on September 16, 2021 .............................................................................................65
Table no. 26 Bloomberg chat between Big Client trader and Rohit Salgaocar on Dec
08, 2021 ....................................................................................................................68
Table no. 27 Summary of trades undertaken by FR2 and FR5 on December 08, 2021
..................................................................................................................................69
Table no. 28 Matching between the big client and the FRs on December 08, 2021 .70
Table no. 29 Long positions built by each of the FR during the day ..........................70
Table no. 30 Trades undertaken by the FR1 and Big Client ......................................73

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Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
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Table no. 31 Instruction with respect to the positions taken by FR1 prior to entry of the
Big Client ...................................................................................................................74
Table no. 32 Instructions with respect of the positions taken by the FR1 and BC, when
matching took place ..................................................................................................77
Table no. 33 Calculation of unlawful gains made under this illustration ....................81
Table no. 34 Trades undertaken by FR 1 and the Big Client in on April 06, 2023 .....81
Table no. 35 Trades undertaken by the FR2 and Big Client during aforesaid time period
..................................................................................................................................83
Table no. 36 Instructions in respect of the positions taken by the FR2, prior to the entry
of the Big Client .........................................................................................................84
Table no. 37 Instructions with respect of the positions taken by the FR2 and Big Client,
when matching took place .........................................................................................86
Table no. 38 Calculation of unlawful gains made under this illustration ....................89
Table no. 39 Trades undertaken by FR2 and Big Client ............................................90
Table no. 40 Instructions in respect of the positions taken by the FR2, prior to the entry
of the Big Client .........................................................................................................91
Table no. 41 Instructions with respect to the positions taken by the FR2 and Big Client
..................................................................................................................................94
Table no. 42 Trades undertaken by the FR1, FR2, FR3 and Big Client ....................97
Table no. 43 Instructions with respect to the positions taken by the FR2 and Big Client,
when matching took place .........................................................................................99
Table no. 44 Calculation of unlawful gains made under this illustration ..................104
Table no. 45 Trades undertaken by the FR2, FR5 and Big Client ...........................105
Table no. 46 Bloomberg chats between Rohit Salgaocar and the trader of Big Client
on January 06, 2023................................................................................................107
Table no. 47 Instruction with respect to the positions to be taken in the scrip on January
09, 2023 ..................................................................................................................108
Table no. 48 Instructions with respect to the positions taken by the FR2 and Big Client
................................................................................................................................109
Table no. 49 Calculation of unlawful gains made under this illustration ..................113
Table no. 50 Trades undertaken by the FR2, FR6 and Big Client during aforesaid Patch
................................................................................................................................114
Table no. 51 Instruction with respect to positions taken by the FR2, prior to entry of the
Big Client .................................................................................................................117
Table no. 52 Instructions with respect to the positions taken by the FR2, FR6 and Big
Client, during matching phase .................................................................................119
Table no. 53 Calculation of unlawful gains made under this illustration ..................122
Table no. 54 Profit earned by FRs during the Investigation Period .........................124
Table no. 55 Cash transfer of INR 25 lakhs from Ketan Parekh (Jack New) to Sumit
Sonthalia .................................................................................................................126
Table no. 56 Cash transfer of INR 50 lakhs from Sumit Sonthalia to Ketan Parekh (Jack
New) ........................................................................................................................129
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Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
Page 187 of 188
Table no. 57 Bank transfer of INR 65 lakhs from Ketan Parekh (Jack Latest.New) to
Sanjay Taparia ........................................................................................................130
Table no. 58 Cash transfer of INR 20 lakhs from Ketan Parekh to Sanjay Taparia .132
Table no. 59 Fund transfers between Ketan Parekh and various entities of Rachit
Poddar.....................................................................................................................134
Table no. 60 Summary of the transactions between Realstone and Classic Share 135
Table no. 61 Summary of bank transfers made between Realstone and bank accounts
of various FRs/ facilitators .......................................................................................136
Table no. 62 Proof of information sharing between various entities ........................138
Table no. 63 Liability of the directors for contraventions committed by FR companies
................................................................................................................................159
Table no. 64 Joint and several liabilities of Noticees for impounding of wrongful gains
................................................................................................................................178

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Order in the matter of extended front running by Rohit Salgaocar, Ketan Parekh and others
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