interim order in the matter of radford global ltd

8/10/2019 Interim order in the matter of Radford Global Ltd.

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-----------------------------------------------------------------------------------------------------------------------------------------------------Order in the matter of Radford Global Ltd. Page 1of 27

WTM/RKA /ISD /161 /2014

SECURITIES AND EXCHANGE BOARD OF INDIA

ORDER

UNDER SECTION 11(1), 11(4) AND 11B OF THE SEBI ACT, 1992 AND SECTION 12A

OF THE SECURITIES CONTRACTS (REGULATION) ACT, 1956 - IN THE MATTER

OF RADFORD GLOBAL LIMITED AND OTHERS

1.

Pursuant to preliminary examination by Bombay Stock Exchange Limited ("BSE") in the

dealings in the shares of Radford Global Limited {hereinafter referred to as "Radford"},

Securities and Exchange Board of India ("SEBI") undertook a preliminary inquiry in the dealings

in the shares of Radford for the period January 28, 2013 to March 24, 2014 {hereinafter referred

to as "the examination period"}.

2. On January 28, 2013, pursuant to a stock split, the face value of each share of 10/- was reduced

to 2/- per share. Post stock-split, during the period January 29, 2013 to July 23, 2013 ("Patch

I"), the price of the scrip of Radford opened at 49.20, rose to a high of 86.00 and closed at

74.95. During the period July 24, 2013 to March 24, 2014 ("Patch II"), the price of the scrip

continuously fell from 74.10 to 4.89. An illustration of price/volume movement in the scrip

of Radford during the examination period is given below:

*It was noticed that during the period February 27, 2012 to January 28, 2013("Pre-Patch I") the price of the shares

of Radford was at 3.20, rose to a high of 241.35 and closed at 241.35.

0

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200000

400000

600000

800000

1000000

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No.of Shares Close Price

Brought to you by http://StockViz.biz


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3. The preliminary examination revealed that there was a pattern in which the shares of Radford

were being traded. The modus operandi adopted by the traders in the scrip is as under :

i. Firstly, shares were allotted on preferential basis in Pre-Patch I to entities connected/related

directly or indirectly to Radford.

ii.

Then, just prior to the expiry of lock-in of shares issued on preferential basis, Radfordannounced a stock-split to make a passage for preferential allottees to exit on expiry of the

lock-in since the stock split would reduce the per share price and increase liquidity.

iii. After the expiry of lock-in, it was noted that after the stock split, the preferential allottees

sold the shares to entities connected/related, directly or indirectly, to Radford

Group/Suspected Entities, thereby raking in huge profits.

iv. It was also noted that the said price movement was not backed by fundamentals of the

company and its financials.

4.

During the beginning of Pre-Patch I, on February 16, 2012, Radford had allotted 91,00,000equity shares of 10/- each at a premium of 5/- on preferential basis to 48 entities aggregating

to 13.65 cr. (list provided in Annexure A). Out of these 48 entities, 4 entities viz. Brij Bhushan

Singal, Neeraj Singal, Ritu Singal and Uma Singal are connected to the Radford and 19,00,000

shares (20.87% of total number of shares allotted) were allotted to these four entities. The shares

allotted on preferential basis to aforesaid allottees were locked-in for a period of 1 year in

compliance with Securities and Exchange Board of India (Issue of Capital and Disclosure

Requirements) Regulations, 2009. Thus, these shares held by the said 48 allottees pursuant to

preferential allotment and split were not tradable in this lock in period.

5. On analysing the financial statements of Radford, the following was observed:-

Table: I - Financial year-wise particulars of Radford

FY 2011-12 FY 2012-13 FY 2013-14

Total Number of paid

up Shares (Face Value)1,40,62,300(10) 7,03,11,500(2) 7,03,11,500(2)

Total Revenue 3.04 crore 22.28 crore 11.04 crore

Profit after tax 0.06 crore 0.46 crore 0.18 crore

Earning per share 0.01 0.07 0.03

6. From Table I, it is observed that the total number of paid up shares of Radford, after taking into

account the stock-split dated January 28, 2013, increased by 5 times to 70,311,500. From the

Annual Reports of Radford for FY 2011-12 and FY 2012-2013, it was observed that it is in the

business of Staffing Services, Textile and Real Estate and it had earned a profit of 6,17,264/-

during 2011-12 and 45,87,092/- during FY 2012-13. From the Annual Report of Radford for



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the FY 2012-2013 it is observed that for the FY ended 2012 the EPS was 0.01/- and for the

FY ended March 31, 2013 EPS was 0.07/-. It was further noted that during the Pre-Patch I

there was no material corporate announcement made by Radford which could support such

price rise in its scrip. It is observed from the above facts that the price rise of 7442% during Pre-

Patch I was not justified and aberrant. Also the movement was extremely aberrant vis-a-vis themovement of the stock market as the Sensex only moved from 17,645 to 20,103.

7. The sharp price rise in the scrip as discussed above was not supported by fundamentals of

Radford or any other external factor. The price in the scrip increased prior to the expiry of the

lock-in period on the shares held by the aforesaid allottees pursuant to preferential allotment and

split. After the expiry of the lock-in period, the price and volume in the scrip increased

substantially. Considering such pattern, the trading in the scrip in three patches as mentioned

above was analyzed. The analysis of the trading during the patches was carried out with a focus

on the following:-

The trading frequency;

The volume generated;

Contribution to price rise;

Buying behavior as observed from Last Traded Price ("LTP") data.

8. On analysis of trading activity in the Scrip, it was observed that certain entities was primarily

involved in pushing the price up during the lock in period, which is Pre-Patch I, by contributing

to positive LTP through first trades with negligible volumes. Another group of entities were

acting as buyers in Patch-I in order to provide exit to preferential allottees and in the process

creating artificial volume which has been dealt with in detail subsequently.

9.

During Pre-Patch I, the scrip opened at 3.20 (pre-split price) on February 27, 2012 and rose to

a high of 241.35 and closed at 241.35 on January 28, 2013. During this period, the scrip was

traded with an average volume of 98 shares per day and total volume of 11,950 shares in 121

trading days with an average of 1.6 trades per day. It was observed that price of the scrip was

influenced by certain entities primarily through first trades during this period. It was noticed that

these entities by putting 1 or 2 trades per day with negligible/ very less quantity of buy orders

contributed significantly to the price rise. From LTP analysis, it is observed that price of the

scrip increased from 3.20 to 241.35 mainly through first trades in 121 instances.

10.It was observed that in Pre-Patch I, out of a total of 121 instances of trades establishing new

high price in the scrip, certain entities established new high price on 91 instances (75.21% to

total instances). The contribution of these entities in establishing new high price was 204.3/-



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out of total price rise of 246.7/-, which constitutes 82.81% of the total new high prices. The

details of contribution to price rise by these entities during Pre-Patch I are as under:

Table II : Details of entities and their contribution to price rise in Pre-Patch I

Sr.No.

Clnt Name Clnt PanTrading MemberName

No.of Instances

% toTotalInstances

PosLTPContriof theClientas abuyer

TotPosContriIn Sec

PosContri (in%)

1Taran KumarRungta

ASVPR5947G Shilpa Stock BrokerPvt. Ltd.

14 11.57 45.21 246.7 18.33

2 Prem Lata Nahar AFAPN8764M 25 20.66 43.3 246.7 17.55

3ManjulabenSukhdev Pandya ALVPP7764J

Sanghavi BrothersBrokerage Ltd. 15 12.4 32 246.7 12.97

4Rajat Share BrokingPvt Ltd

AAACR2695BShilpa Stock BrokerPvt.Ltd.

6 4.96 25.5 246.7 10.34

5Rajesh PravinkumarJasani

ACWPJ4705BMonarch Research &Brokerage Pvt.Ltd.

7 5.79 24.85 246.7 10.07

6 Bharat Bagri Bagri AADHB8488ABcb BrokeragePvt.Ltd.

16 13.22 17.86 246.7 7.24

7Jayesh NarendraKesharia

AAEHJ1610DBharti Thakkar IndiaSecurities Pvt.Ltd.

8 6.61 15.58 246.7 6.32

Total 91 75.21 204.3 246.7 82.81

11.

It was also observed that most of these aforementioned entities had also traded and wereinstrumental in contributing to the price rise of other stocks. It was further observed that Taran

Kumar Rungta, Prem Lata Nahar and Rajat Share Broking Pvt. Ltd are related /connected to

Shilpa Stock Broker Pvt. Ltd and Bharat Bagri Bagri is relatedto BCB Brokerage Pvt. Ltd. through

whom they have traded. Ms. Prem Lata Nahar is the Mother of Rakesh Nahar who is the

owner/director of Shilpa Stock Broker Pvt. Ltd. and Bharat Bagri is the Promoter/ director of

BCB Brokerage Pvt. Ltd and share common address with BCB Brokerage Pvt. Ltd.

12.The selection of scrips for trading, the trading pattern and connectivity with brokers cast doubt

on the intent of these entities while trading in the securities market. The sheer number of scrips

with such dubious price-rise track record in which the said entities and their connected brokers

are involved also cast doubts on their conduct in the securities market.

13.On analysis of trading activity during Patch I, certain related/connected entities ("Radford

Group") to Radfordwere found to be net buyers to the preferential allottees and thereby created



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artificial demand for the supply of shares from preferential allottees. Further, it was also noticed

that a group of entities connected/related ("Suspected Entities") to each other, by virtue of

common address;/e-mail id. were trading in the shares of Radford amongst themselves. During

the Patch I, significant increase in the trading volume was observed and it appears that most of

the entities were acting as counterparty to the preferential allottees. Also on further examination

direct/ indirect relationship were established among these entities through Know Your Client

(KYC) details , their bank statements, off-market transactions amongst themselves, and

information available on the Ministry of Corporate Affairs (MCA) website. List of such entities

are annexed as Annexure - B and hereinafter referred to as the "Radford Group & Suspected

Entities".

14.It is observed that during Patch I, the preferential allottees were net sellers and entities forming

part of the Radford Group & Suspected Entities were net buyers, a snapshot of which is given

below:-

Table III - Exit provided by Radford Group & Suspected Entities to allottees

Shares

sold

% of

Total

allotted

shares

Shares

purchased

from

preferentialallottees

% of

preferential

shares Sold

Total

shares

bought in

the Patch Iby

% of Net

Buy

Preferential

Allottees4,15,99,539 91.43% - - - -

Radford Group

& Suspected

Entities

- -

2,76,84,200

(refer table

IV)

67.77% 4,08,51,126

70.01%

(refer table

IV)

15.It is observed from Table III that most of the trades were taking place between the preferential

allottees and the entities of Radford Group & Suspected Entities . During this period, the allotteeswere found to be selling and in the process gaining a huge profit/gain. It was observed that

Radford Group & Suspected Entities contributed 70.01% to the net buy trade during this patch. The

details of counter parties for sale transactions by preferential allottees is given below:



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Table - IV:Details of counter parties for sale transactions

Sr.

No. Client Name Clnt Pan

Net Buy

in Patch I

Vol ofNet

Buy inPatch I

Sharespurchase

d frompreferenti

al allottesduring

post splitperiod

% of sharesbought

frompreferential

allottes tothe NetBuy inPatch I

1 2 3 4 5 6 7=6/4*100

Radford Group

1Amrusha MercantilePrivate Limited

AALCA0340D 3317965 5.69 2281121 68.75

2Spice Merchants PrivateLimited

AAPCS7492G 3287475 5.63 2422355 73.68

3

Shelter Sales AgencyPrivate Limited ShelterSales Agency PrivateLimited Shelter SalesAgency Private Limited

AASCS1797F 3122146 5.35 2312395 74.06

4Udbal Mercantile PrivateLimited

AABCU2648C 2767601 4.74 1588720 57.40

5Devakantha TradingPrivate Limited

AADCD7044B 2475491 4.24 1705206 68.88

6Winall Vinimay PrivateLimited Ltd

AAACW8004B 2144989 3.68 1764206 82.25

7 Pine Animation Limited AAECM0267A 1858368 3.18 1081586 58.20

8Limestone PropertiesPrivate Limited

AACCL0133G 1764054 3.02 1357040 76.93

9Runicha MerchantsPrivate Limited

AAECR0580M 1584913 2.72 1325164 83.61

10Dhanleela Investments& Trading CompanyLimited

AAACR1770P 1464988 2.51 680586 46.46

11Apex CommotradePrivate Limited Ltd

AAJCA4459K 1223735 2.10 1033114 84.42

12Shivkhori Construction

Private Limited

AAPCS7850L 926220 1.59 896440 96.78

13Signet Vinimay PrivateLimited

AAMCS1712Q 903711 1.55 913195 101.05

14Anjali Suppliers PrivateLimited

AAJCA1784D 893000 1.53 747275 83.68

15Sanklap Vincom PrivateLimited

AAMCS1711P 892600 1.53 613910 68.78

16 Rangan Vincom Private AAGCR1715E 725705 1.24 720970 99.35



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Limited

17Pyramid Trading AndFinance Ltd

AAACP2548R 647675 1.11 518992 80.13

18Divyadrishti MerchantsPvt Ltd

AABCD8147K 537000 0.92 499448 93.01

19 Divya Drishti TradersPvt Ltd AABCD8146J 532000 0.91 450691 84.72

20Ladios Trading PrivateLimited

AACCL3868N 507160 0.87 473093 93.28

21Skm Travels PrivateLimited

AAICS0688K 494050 0.85 443724 89.81

22Avlokan DealcomPrivate Limited

AALCA1583G 389706 0.67 368706 94.61

23Topwell PropertiesPrivate Limited

AADCT8403C 250000 0.43 160600 64.24

24Esquire Enclave PrivateLimited

AACCE7065J 225000 0.39 87233 38.77

25Natural Housing PrivateLimited

AADCN6251G 200000 0.34 183926 91.96

26Radison PropertiesPrivate Limited

AAFCR2818B 160125 0.27 114517 71.52

27 Ridhi Vincom Pvt Ltd AAECR9858C 115000 0.20 115000 100.00

28Dhanraksha VincomPvt Ltd

AADCD6028P 113390 0.19 112390 99.12

29Kingfisher PropertiesPrivate Limited

AAECK3394G 95000 0.16 92400 97.26

30Vibgyor FinancialServicepvt Ltd

AAACV8378B 82000 0.14 37840 46.15

31Blue Circle ServicesLimited

AAACB2131L 64073 0.11 60323 94.15

32Amrit Sales PromotionPvt Limited

AACCA3220D 47000 0.08 47000 100.00

33Burlington FinanceLimited

AABCB2575P 34500 0.06 30000 86.96

34Bazigar Trading PrivateLimited

AABCB3052B 34500 0.06 32347 93.76

35Katyani CommoditiesPrivate Limited

AAECK6244R 25000 0.04 70000 280.00

36Manimudra VincomPrivate Limited AADCM4316K 23500 0.04 23200 98.72

37Devatma DistributorsPrivate Limited

AADCD7140G 11950 0.02 11950 100.00

38Symphony Merchant PvtLtd

AADCS5411K 5000 0.01 5000 100.00

39 Scope Vyapar Pvt. Ltd. AAICS6023N 0 0.01 11000 0.00

Total (I) 33946590 58.18 25392663 74.80



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Suspected Entities

1Jayant Security &Financeltd AAACJ4848G 3430961 5.88

1535303 44.75

2 Trimurthi Finvest Ltd AAACT6383N 1051222 1.80 329978 31.39

3 Purvi Finvest Limited AABCP6564C 1077750 1.85 129253 11.99

4 East West Finvest IndiaLimited AAACE6834D 1123353 1.92

224803 20.01

5East West Finvest IndiaLimited AADCE1236G 221250 0.38

72200 32.63

Total (II) 6904536 11.83 2291537 33.19

Grand Total (I+II) 40851126 70.01 27684200 67.77

16.It is observed that 46 allottees made a collective profit of 313.01 Crore on their total

investment of 12.99 crore, a substantial return of approximately 2309 % on their investment ina period of 18 months (including the lock in period). It is evident from the above analysis of

trading in Patch I that the entities of Radford Group & Suspected Entities provided a hugely

profitable exit to the allottees, who also were related directly/indirectly to Radford. The

profit/gain earned by the allottees during Patch I is given below:-

Table V: Details of the trades carried out by allottees and profit calculation

SrNoClient

Name

PANQty

Allotted

Qty PostStock

Split (Jan29, 2013)

Priceafter

StockSplit

QtyBought

in OffMarket

QtySold in

OffMarket

TotalQty in

Hand

Sum ofSOLD

QTY

Sell

Rate

Profit Earned

()

Balance

Qty

1

AchalChandBalar

ABAPB8617M

150000 750000 3 0 500000 250000 189060 80.36 146250256094

0

AbhishekAchalchand Balar

AATPB8811B

0 0 3 250000 0 250000 166000 85.22 136488468400

0

PiyushKumarBalar

AEMPB6394Q

0 0 3 250000 0 250000 140000 83.39 112540281100

00

2AfsarZaidi

AADPZ8571G

100000 500000 3 0 0 500000 500000 80.04 38522857 0

3

AmreshAnantraiMody

AACPM4024E

100000 500000 3 0 450000 50000 50000 79.85 3842500 0

HasumatiAnantraiMody

AJSPM7935P

0 0 3 450000 0 450000 450000 83.85 36381293 0

4

Anil RajatAgarwal& Sons(Huf)

AAFHA0709M

60000 300000 3 0 0 300000 300000 69.11 19831633 0



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SrNoClientName

PANQtyAllotted

Qty PostStockSplit (Jan29, 2013)

PriceafterStockSplit

QtyBoughtin OffMarket

QtySold inOffMarket

TotalQty inHand

Sum ofSOLDQTY

SellRate

Profit Earned

()

BalanceQty

5AshokJiwrajka

AACPJ3610K

250000 1250000 3 0 0 1250000 1250000 79.18 95222911 0

6BabitaMittal

AAIPG4573G

150000 750000 3 0 0 750000 750000 79.34 57254421 0

7 BimalDesai

AAKPD3160A

200000 1000000 3 9001 0 1009001 1009001 83.22 80945955 0

8BrijBhushanSingal

AEFPS6298M

580000 2900000 3 0 0 2900000 2900000 82.12 229451547 0

9DalsukhUjamshi

Trevadia

ACDPT3428N

100000 500000 3 0 0 500000 500000 81.3 39148937 0

10DilipChotalalMorzaria

AADPM9919M

200000 1000000 3 0 0 1000000 1000000 55.79 52788678 0

11Dilip

JiwrajkaAAGPJ8756J

250000 1250000 3 0 0 1250000 1250000 79.2 95246103 0

12G MLingaraju

AEYPM5850Q

200000 1000000 3 0 0 1000000 1000000 71.91 68913912 0

13G MPrasannaKumar

AHEPG0025A

200000 1000000 3 0 0 1000000 1000000 76.72 73720095 0

14G S AnithKumar

ADPPK9874N

200000 1000000 3 0 0 1000000 1000000 77.8 74800649 0

15Harikishan S

Virmani

AAJPV4754H

100000 500000 3 0 0 500000 500000 82.99 39994974 0

16Hitesh

JainAABPJ2835R

100000 500000 3 0 0 500000 500000 82.64 39819781 0

17

HukamsinghBhawarsinghjiRajpurohit

AABPR9949J

100000 500000 3 0 0 500000 500000 81.16 39080552 0

18

Jyoti Anil

Trevadia

ABWPT8

000C 100000 500000 3 0 0 500000 500000 81.39 39195997 0

19JyotsnaJitendraDesai

AHPPD4223L

200000 1000000 3 0 9001 990999 990999 70.65 67041531 0

20KalpitaSureshLuniya

AAAPL9611J

100000 500000 3 0 0 500000 500000 58.83 27916282 0

21KamalIndurPunwani

AFFPP5207G

100000 500000 3 0 0 500000 500000 79.31 38156782 0

22

MayuriDarshanBhanushali

AKJPB8572F

100000 500000 3 0 0 500000 500000 72.34 34669719 0

23MohanMittal

APFPM0496Q

150000 750000 3 0 0 750000 750000 79.86 57648728 0

24Mohit

AggarwalADSPA9301K

150000 750000 3 0 0 750000 750000 76.29 54964382 0

25MukeshMittal

AJGPM2125D

150000 750000 3 0 0 750000 750000 80.1 57826737 0

26NareshNemchand Shah

ACRPS0182J

400000 2000000 3 0 0 2000000 2000000 78.78 151568641 0

27NeerajSingal

ANRPS7986B

580000 2900000 3 0 0 2900000 2900000 79.61 222156517 0



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SrNoClientName

PANQtyAllotted

Qty PostStockSplit (Jan29, 2013)

PriceafterStockSplit

QtyBoughtin OffMarket

QtySold inOffMarket

TotalQty inHand

Sum ofSOLDQTY

SellRate

Profit Earned

()

BalanceQty

28

NishitAgarwalBeneficiary Trust

AABTN3350K

200000 1000000 3 0 0 1000000 1000000 78.55 75549009 0

29Pinky

AgarwalACGPA7438L

200000 1000000 3 0 0 1000000 1000000 82.47 79471984 0

30

PratikAgarwalBeneficiary Trust

AABTP7516K

200000 1000000 3 0 0 1064874 1064874 79.01 76033232 0

31PraveenKumar

Agarwal

ACSPA4725A

200000 1000000 3 0 0 1000000 500000 78.47 377350005000

00

32

PraveenKumar

AgarwalHuf

AAIHP6229C

200000 1000000 3 0 0 1000000 1000000 82.6 79600930 0

33RajendraMangilal

Jain

ACPPJ9853R

100000 500000 3 0 0 500000 500000 82.61 39805257 0

34Renu

AggarwalAAEPA1694C

150000 750000 3 0 0 750000 750000 79.96 57719482 0

35RenuMittal

AGMPM1488Q

150000 750000 3 0 0 750000 750000 81.27 58703897 0

36RituSingal

ABHPS3711M

515000 2575000 3 0 0 2575000 2575000 82.77 205404070 0

37Santosh

AggarwalABAPA4548E

150000 750000 3 0 0 750000 750000 80.11 57833909 0

38ShaileshMangilal

Jain

AAAPJ6765F

100000 500000 3 0 0 500000 500000 82.4 39700599 0

39Shilpa

AggarwalAEXPA1230M

150000 750000 3 0 0 750000 750000 75.32 54238750 0

40Surendra

JiwrajkaAACPJ4316L

250000 1250000 3 0 0 1250000 1250000 79.2 95249153 0

41 SushantInvestments

ACAFS8650G

250000 1250000 3 0 0 1250000 239604 78.75 18149101 1010396

42TanviBhavik

Trevadia

AFAPT5888A

100000 500000 3 0 0 500000 500000 80.07 38535769 0

43TarunAggarwal

AOQPA9034E

150000 750000 3 0 0 750000 750000 79 57001648 0

44UjwalaNamdevMane

AAEPM5924H

100000 500000 3 0 0 500000 500000 46.16 21577500 0

45UmaSongal

ANRPS7987A

225000 1125000 3 0 0 1125000 1125000 78.6 85053164 0

46YogeshPopatlal

Thakkar

AAPPT1825P

200000 1000000 3 0 0 1000000 1000000 80.15 77154413 0

Total 8660000 43300000 959001 959001 43300000 41599539 313,01,56,898 1765336

17.The transactions wherein the entities of Radford Group & Suspected Entities bought most of the

shares sold by the allottees cannot be just a coincidence particularly when sellers by virtue of

being allotees andprima facieconnected / have nexus with Radford and its promoters/ directors

and buyers are the entities connected with Radford and its promoters /directors. From the



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analysis presented for Pre-Patch I, it is observed that the shares of Radford were not in demand

by the general investors of the market and saw very low volume on most of the trading days and

hence could not have commanded the price as observed in Patch I. In any market, a sudden

supply, if not matched by similar demand, leads to price fall. Considering the same, any rational

investor would not have dumped a large number of shares without facing the risk of a significantprice fall until and unless he was sure of the demand side absorbing the supply. In this peculiar

case, the entities of Radford Group & Suspected Entities created the demand against the supply

from the preferential allotters. In the whole process, the principle of price discovery was kept

aside and the market lost its purpose. It is evident from the above analysis that the Radford Group

& Suspected Entities provided a hugely profitable exit to the allottees. This could be only possible

if the allottees, Radford Group & Suspected Entities and Radford and its promoter/ directors were

hand in glove with each other. The said finding is also corroborated by the fact that in few

instances/ cases, it is observed that the buyers are related /connected entities of preferential

allottees.

18.From the facts stated above, it can be safely assumed that the entire modus operandi of allotting

preference shares at a premium, announcing a stock split and then bringing in connected entities

to provide exit was a scheme devised to rake in ill-gotten gains.

19.In Patch II, the price of the shares of Radford has decreased from 74.10 to 4.89, i.e. a fall of

approximately 93.4%. Also the volumes have again decreased by 67% of the volume of Patch I.

On analysis of the top 20 sellers during the period, it was noted that 9 entities of the Radford

Group & Suspected Entities have sold approximately 37% of the net traded volume. Also onanalysis of the negative LTP contribution, it was noted that the top 20 entities had contributed

72% of the price fall of which only 13% was contributed by Radford Group & Suspected Entities . It

indicates that a sizeable quantum of gullible investors had started trading in the shares of

Radford and were disposing at any possible price.

20.From the analysis of the trading across Patches, it can be comfortably stated that the modus

operandiof allotting shares on preferential basis at a premium, pumping the share price artificially

and then dumping the price so that the same cycle could be repeated, demonstrates the mala fide

of the Radford Group & Suspected Entities . Also the mechanism is being presumably used todeceive the authorities by laundering black money and raking in tax-free profits.

21.It was noted that the price movement of the shares are negligible Post examination period till

the date of this order.



12/27


22.From the above examination and factors as described in Annexure B, I note that the allottees,

Radford and Radford Group & Suspected Entities are connected to each other. In this regard, I note

that the Hon'ble SAT has, in many cases such as Classic Credit Ltd. vs. SEBI (SAT Appeal no.

68/2003, Order dated December 8, 2006), Classic Credit Ltd. vs. SEBI (SAT Appeal no. 76/ 2003,

Order dated January 9, 2007) and Veronica Financial Services Ltd. vs. SEBI (SAT Order datedAugust 24, 2012), held that connection/relations can be established on the basis of factors

including the common addresses, common directors/ shareholders, etc.

23.It is pertinent to mention that the key to the scheme of operations employed by Radford Group &

Suspected Entities prima facie lies in the preferential allotment of shares made by Radford. Due to a

lock-in of one year on shares any gains made on the sale of such shares makes them eligible for

long term capital gains ("LTCG"). From the observations of the preliminary inquiry it is inter alia

noted that :-

a)

the fund brought in by way of preferential allotment was utilised for purposes otherthan those disclosed;

b) even when substantial number of shares i.e. 91 lakh shares (455 lakh shares after split)

were locked-in and non transferable / tradable, price of the scrip increased substantially

to the extent of 7442% with a very small chunk of volume / purchases by certain

entities;

c) After the expiry of the lock-in period (i.e. in Patch I), the average volume increased

astronomically to the extent of 505066% (5050 times). Such increase in volume was

mainly on account of matched trading amongst Radford Group & Suspected Entities and

allottees.

d) 46 out of the 48 preferential allottees sold 91.43% shares allotted to them by Radford at

the price increased on account of the aforesaid manipulative trading in Pre-Patch I.

24.From the above facts and circumstances it can reasonably be inferred that the preferential

allottees acting in concert with Radford Group & Suspected Entities have misused the stock

exchange system to generate fictitious LTCG. It is pertinent to note that LTCG is tax exempt.

25.

In the facts and circumstances of this case, I am of the view that preferential allotment was used

as a tool for implementation of the dubious plan, device and artifice of Radford Group & SuspectedEntities and preferential allottees. One could argue that in order to make LTCG, the preferential

allottees in question could have bought in secondary market and waited for a year before selling

the shares. In the instant case, probably the preferential allotment route was preferred over

secondary market route because the share capital of Radford prior to preferential allotment was

very small, i.e., 1,40,62,300 shares (Face Value: 10) to accommodate the required fictitious



13/27


LTCG of 313 crore approximately. As such the capital expansion through preferential

allotment and stock split provided much bigger source to the persons involved in terms of

volume and price manipulation to facilitate the whole operation.

26.Since prior to the trading in its scrip during the Examination Period, Radford did not have any

significant financial standing in the securities market, in my view, the only way it could have

increased its share value is by way of market manipulation. In this case, it is noted that the traded

volume and price of the scrip increased substantially only after Radford Group & Suspected Entities

and allottees started trading in the scrip. The average volume increased by 5,05,066 % (5050

times) during the Patch I, i.e., from 98 shares per day to 4,95,063 shares per day and the price

increased by 74.8% during the same period, i.e., from 49.2 to 86. Radford Group & Suspected

Entities were trading in the scrip above the LTP and their trades created artificial volumes and

manipulated the price of the scrip during the examination period. It is further noted that on the

days when Radford Group & Suspected Entities were not trading, the trading volumes in the scripwere very low and the substantial increase in traded volumes as observed in this case was mainly

due to their trading. I further note that Radford Group & Suspected Entities and allottees traded

amongst themselves as substantiated by their matching contribution to net buy and net sell in

Patch I. There was no change in the beneficial ownership of the substantial number of traded

shares as the buyers and sellers both were part of the common group and were acting in

league/concert to provide LTCG benefits to the allottees. In view of the above, Iprima facie find

that Radford Group & Suspected Entities and allottees used securities market system to artificially

increase volume and price of the scrip for making illegal gains to and to convert ill-gotten gains

into genuine one.

27.I am of the considered view that the scheme, plan, device and artifice employed in this case,

apart from being a possible case of money laundering or tax evasion which could be seen by the

concerned law enforcement agencies separately, is prima facie also a fraud in the securities market

inasmuch as it involves manipulative transactions in securities and misuse of the securities

market. The manipulation in the traded volume and price of the scrip by a group of connected

entities has the potential to induce gullible and genuine investors to trade in the scrip and harm

them. As such the acts and omissions of Radford Group & Suspected Entities and allottees are

fraudulent as defined under regulation 2(1)(c) of the SEBI (Prohibition of Fraudulent and Unfair

Trade Practices relating to Securities Market) Regulations, 2003 (PFUTP Regulations) and are

in contravention of the provisions of regulations 3(a), (b), (c) and (d) and 4(1), 4(2)(a), (b), (e)

and (g) thereof and section 12A(a), (b) and (c) of the SEBI Act, 1992. The said regulations are

reproduced hereunder:-



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SEBI ACT

Prohibition of manipulative and deceptive devices, insider trading and substantial

acquisition of securities or control.

"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;"

PFUTP REGULATIONS, 2003

"Prohibition of certain dealings in securities

3. No person shall directly or indirectly

(a) buy, sell or otherwise deal in securities in a fraudulent manner;

(b) use or employ, in connection with issue, purchase or sale of any security listed or proposed to be listed in a

recognized stock exchange, any manipulative or deceptive device or contrivance in contravention of the

provisions of the Act or the rules or the regulations made there under;

(c) employ any device, scheme or artifice to defraud in connection with dealing in or issue of securities which

are listed or proposed to be listed on a recognized stock exchange;

(d) engage in any act, practice, course of business which operates or would operate as fraud or deceit upon any

person in connection with any dealing in or issue of securities which are listed or proposed to be listed on a

recognized stock exchange in contravention of the provisions of the Act or the rules and the regulations made

there under.

4. Prohibition of manipulative, fraudulent and unfair trade practices

(1) Without prejudice to the provisions of regulation 3, no person shall indulge in a fraudulent or an unfairtrade practice in securities.

(2) Dealing in securities shall be deemed to be a fraudulent or an unfair trade practice if it involves fraud

and may include all or any of the following, namely:-

(a) indulging in an act which creates false or misleading appearance of trading in the securities market;



15/27


(b) dealing in a security not intended to effect transfer of beneficial ownership but intended to operate only as

a device to inflate, depress or cause fluctuations in the price of such security for wrongful gain or avoidance of

loss;

(c)

(d) (e)any act or omission amounting to manipulation of the price of a security;

(f) .

(g) entering into a transaction in securities without intention of performing it or without intention of change of

ownership of such security; "

28.I note that the directors of Radford during the relevant time (i.e. Prakash Bhawarlal Biyani,

Manish Nareshchandra Shah, Rajesh Kumar Maheshwari and Nitin Shivratan Murarjka), being

in control of the day to day affairs of Radford, had the knowledge of its acts and omissions. They

were also under an obligation to ensure that acts and transactions of Radford were not inviolation of any of the applicable provisions of SEBI Regulations or other applicable laws. I,

therefore,prima facie find that these directors were responsible for Radford's acts and omissions

in this case.

29.I am of the opinion that a detailed investigation of the entire scheme employed in this case is

necessary to find out the role of any other entity therein including LTP contributors, Suspected

entities, connection amongst the concerned entities and the ultimate owners of funds used for

manipulating the price of the scrip. Therefore, while SEBI would investigate into the probable

violations of the securities laws, the matter may also be referred to other law enforcementagencies such as Income Tax Department, Enforcement Directorate and Financial Intelligence

Unit for necessary action at their end as may be deemed appropriate by them.

30.SEBI strives to safeguard the interests of a genuine investor in the Indian securities market. The

acts of artificially increasing the price of scrip mislead investors and the fundamental tenets of

market integrity get violated with impunity due for such acts. Under the facts and circumstances

of this case, Iprima facie find that the acts and omissions of Radford Group & Suspected Entities and

allottees as described above is inimical to the interests of participants in the securities market.

Therefore, allowing the entities that areprima facie found to be involved in such fraudulent, unfairand manipulative transactions to continue to operate in the market would shake the confidence

of the investors in the securities market.

31.Considering these facts and the indulgence of a listed company in such a fraudulent scheme,

plan, device and artifice as prima facie found in this case, I am convinced that this is a fit case

where, pending investigation, effective and expeditious preventive and remedial action is



16/27


required to be taken by way of ad interim ex -parte in order to protect the interests of investors and

preserve the safety and integrity of the market.

32.In view of the foregoing, in order to protect the interest of the investors and the integrity of the

securities market, I, in exercise of the powers conferred upon me in terms of section 19 readwith section 11(1), section 11 (4) and section 11B of the SEBI Act, 1992, pending

inquiry/investigation and passing of final order in the matter, hereby restrain the following

persons/entities from accessing the securities market and buying, selling or dealing in securities,

either directly or indirectly, in any manner, till further directions:-

Sr. No. Client Name Client PAN

Company

1 Radford Global Ltd. AABCM5771E

Directors of Radford Global Ltd.

2 Prakash Bhawarlal Biyani AJNPB0702E

3 Manish Nareshchandra Shah AELPS8560A

4 Rajesh Kumar Maheshwari ACJPM4653L

5 Nitin Shivratan Murarka AMBPM9321M

Promoters of Radford Global Ltd.

6 Radford InvestmentServicesPvtLtd AACCG9982A

Director of Radford Investment Services Pvt. Ltd.7 Roshan Dwarkani ATXPD7040B

8 Suresh Kumar Saini BCXPS0818J

Preferential Allottees

9 AachalchandBalar ABAPB8617M

10 PiyushKumarBalar AEMPB6394Q

11 AbhishekKumarBalar AATPB8811B

12 AfsarZaidi AADPZ8571G

13 AmreshA.Mody AACPM4024E

14 HasumatiA.Mody AJSPM7935P

15 AnilRajatAgarwal&Sons.Huf. AAFHA0709M

16 AshokBJiwrajka AACPJ3610K

17 BabitaMittal AAIPG4573G

18 BimalJDesasi AAKPD3160A

19 BrijBhushanSingal AEFPS6298M



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20 DalsukhUjamshiTrevadia ACDPT3428N

21 DilipBJiwrajka AAGPJ8756J

22 DilipChotalalMorzaria AADPM9919M

23 GMPrasannaKumar AHEPG0025A

24 GSAnithKumar ADPPK9874N

25 HariKishanSuderlalVermani AAJPV4754H

26 HiteshMangilalJain AABPJ2835R

27 HukamsinghB.Rajpurohit AABPR9949J

28 JyotiAnilTrevadia ABWPT8000C

29 JyotsnaJitendraDesai AHPPD4223L

30 KalpitaLuniya AAAPL9611J

31 KamalPunwani AFFPP5207G

32 LingarajuGM AEYPM5850Q

33 MayuriDarshanBhanushali AKJPB8572F

34 MohanMittal APFPM0496Q35 MohitAggarwal ADSPA9301K

36 MukeshMittal AJGPM2125D

37 NareshNemchandShah ACRPS0182J

38 NeerajSingal ANRPS7986B

39 NishitAgarwalBenTrust AABTN3350K

40 PinkyAgarwal ACGPA7438L

41 PratikAgarwalBenTrust AABTP7516K

42 PraveenKumarAgarwal ACSPA4725A

43 PraveenKumarAgarwalHuf AAIHP6229C44 RajendraMangilalJain ACPPJ9853R

45 RenuAggarwal AAEPA1694C

46 RenuMittal AGMPM1488Q

47 RituSingal ABHPS3711M

48 SantoshAggarwal ABAPA4548E

49 ShaileshMangilalJain AAAPJ6765F

50 ShilpaAggarwal AEXPA1230M

51 SmtUjwalaNamdevMane AAEPM5924H

52 SurendraBJiwrajka AACPJ4316L

53 SushantInvestments ACAFS8650G

54 TanviBhavikTrevadia AFAPT5888A

55 TarunAggarwal AOQPA9034E

56 UmaSingal ANRPS7987A

57 YogeshPopatlalThakkar AAPPT1825P



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Radford Group

58 Amrit Sales Promotion Pvt Limited AACCA3220D

59 Amrusha Mercantile Private Ltd AALCA0340D

60 Anjali Suppliers Private Limited AAJCA1784D

61 Apex Commotrade Private Limited AAJCA4459K

62 Avlokan Dealcom Private Limited AALCA1583G

63 Bazigar Trading Private Limited AABCB3052B

64 Blue Circle Services Limited AAACB2131L

65 Burlington Finance Limited AABCB2575P

66 Devakantha Trading Private Limited AADCD7044B

67 Devatma Distributors Private Limited AADCD7140G

68Dhanleela Investments & Trading CompanyLimited

AAACR1770P

69 Dhanraksha Vincom Pvt Ltd. AADCD6028P70 Divya Drishti Traders Pvt Ltd AABCD8146J

71 Divyadrishti Merchants Pvt Ltd AABCD8147K

72 Esquire Enclave Private Limited AACCE7065J

73 Katyani Commodities Private Limited AAECK6244R

74 Kingfisher Properties Private Limited AAECK3394G

75 Ladios Trading Private Limited AACCL3868N

76 Limestone Properties Private Limited AACCL0133G

77 Manimudra Vincom Private Limited AADCM4316K

78 Natural Housing Private Limited AADCN6251G

79 Pine Animation Limited AAECM0267A

80 Pyramid Trading And Finance Ltd AAACP2548R

81 Radison Properties Private Limited AAFCR2818B

82 Rangan Vincom Private Limited AAGCR1715E

83 Ridhi Vincom Pvt Ltd AAECR9858C

84 Runicha Merchants Private Limited AAECR0580M

85 Sanklap Vincom P Ltd AAMCS1711P

86 Scope Vyapar Private Limited AAICS6023N

87 Shelter Sales Agency Pvt Ltd # AASCS1797F

88 Shivkhori Construction Private Limited AAPCS7850L89 Signet Vinimay Private Limited AAMCS1712Q

90 SKM Travels Private Limited AAICS0688K

91 Spice Merchants Private Limited AAPCS7492G

92 Symphony Merchant Pvt Ltd AADCS5411K

93 Topwell Properties Private Limited AADCT8403C

94 Udbal Mercantile Private Limited AABCU2648C



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95 Vibgyor Financial Service Pvt Ltd AAACV8378B

96 Winall Vinimay Private Limited AAACW8004B

Suspected Entities

97 Jayant Security & Financeltd AAACJ4848G

98 Trimurthi Finvest Ltd AAACT6383N

99 Purvi Finvest Limited AABCP6564C

100 East West Finvest India Limited AAACE6834D

101 East West Finvest India Limited AADCE1236G

Other

102 Taran Kumar Rungta ASVPR5947G

103 Prem Lata Nahar AFAPN8764M

104 Manjulaben Sukhdev Pandya ALVPP7764J

105 Rajat Share Broking Pvt Ltd AAACR2695B

106 Rajesh Pravinkumar Jasani ACWPJ4705B

107 Bharat Bagri Bagri AADHB8488A

108 Jayesh Narendra Kesharia AAEHJ1610D

33.

This order is without prejudice to the right of SEBI to take any other action that may be initiated

against the aforementioned entities in accordance with law.

34.This order shall come into force with immediate effect. The Stock exchanges and the

depositories are directed to ensure that all the above directions are strictly enforced.

35.The persons/entities against whom this Order is passed may file their objections, if any, within

twenty one days from the date of this order and, if they so desire, avail themselves of an

opportunity of personal hearing before the Securities and Exchange Board of India, on a date

and time to be fixed on a specific request, received from the said persons/entities.

Sd/-

DATE:DECEMBER 19, 2014 RAJEEV KUMAR AGARWALPLACE: MUMBAI WHOLE TIME MEMBER




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Annexure A: List of Preferential Allottees as received from BSE

Sr.

No.Name of the Allottee

Permanent

Account

Number (PAN)

No. of

shares

allotted

Qty Post Stock

Split (Jan 29,

2013)

1AachalchandBalar/PiyushKumarBal

ar/AbhishekKumarBalar

ABAPB8617M/

AEMPB6394Q/

AATPB8811B

150000 750000

2 AfsarZaidi AADPZ8571G 100000 500000

3 AmreshA.Mody/HasumatiA.ModyAACPM4024E/

AJSPM7935P100000 500000

4 AnilRajatAgarwal&Sons.Huf. AAFHA0709M 60000 300000

5 AshokBJiwrajka AACPJ3610K 250000 1250000

6 BabitaMittal AAIPG4573G 150000 7500007 BimalJDesasi AAKPD3160A 200000 1000000

8 BrijBhushanSingal AEFPS6298M 580000 2900000

9 DalsukhUjamshiTrevadia ACDPT3428N 100000 500000

10 DilipBJiwrajka AAGPJ8756J 250000 1250000

11 DilipChotalalMorzaria AADPM9919M 200000 1000000

12 GloryInvestmentServicesPvtLtd AACCG9982A 340000 1700000

13 GMPrasannaKumar AHEPG0025A 200000 1000000

14 GSAnithKumar ADPPK9874N 200000 1000000

15 HariKishanSuderlalVermani AAJPV4754H 100000 500000

16 HiteshMangilalJain AABPJ2835R 100000 500000

17 HukamsinghB.Rajpurohit AABPR9949J 100000 500000

18 JyotiAnilTrevadia ABWPT8000C 100000 500000

19 JyotsnaJitendraDesai AHPPD4223L 200000 1000000

20 KalpitaLuniya AAAPL9611J 100000 500000

21 KamalPunwani AFFPP5207G 100000 500000

22 LingarajuGM AEYPM5850Q 200000 1000000

23 MayuriDarshanBhanushali AKJPB8572F 100000 500000

24 MohanMittal APFPM0496Q 150000 750000

25 MohitAggarwal ADSPA9301K 150000 750000

26 MukeshMittal AJGPM2125D 150000 750000

27 NareshNemchandShah ACRPS0182J 400000 2000000

28 NeerajSingal ANRPS7986B 580000 2900000



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29 NishitAgarwalBenTrust AABTN3350K 200000 1000000

30 PinkyAgarwal ACGPA7438L 200000 1000000

31 PratikAgarwalBenTrust AABTP7516K 200000 1000000

32 PraveenKumarAgarwal ACSPA4725A 200000 1000000

33 PraveenKumarAgarwalHuf AAIHP6229C 200000 100000034 RajendraMangilalJain ACPPJ9853R 100000 500000

35 RamchandraSatre ACAPS9829D 100000 500000

36 RenuAggarwal AAEPA1694C 150000 750000

37 RenuMittal AGMPM1488Q 150000 750000

38 RituSingal ABHPS3711M 515000 2575000

39 SantoshAggarwal ABAPA4548E 150000 750000

40 ShaileshMangilalJain AAAPJ6765F 100000 500000

41 ShilpaAggarwal AEXPA1230M 150000 750000

42 SmtUjwalaNamdevMane AAEPM5924H 100000 500000

43 SurendraBJiwrajka AACPJ4316L 250000 1250000

44 SushantInvestments ACAFS8650G 250000 1250000

45 TanviBhavikTrevadia AFAPT5888A 100000 500000

46 TarunAggarwal AOQPA9034E 150000 750000

47 UmaSingal ANRPS7987A 225000 1125000

48 YogeshPopatlalThakkar AAPPT1825P 200000 1000000

Total 9100000 45500000



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Annexure B: Radford Group & Suspected Entities and the basis of connection /relationship

amongst them.

Based on the KYC and Bank Statement analysis, off market analysis, data available with the

exchange and MCA details, Radford Group & Suspected Entities were observed to be dealing inthe scrip during the period of examination. Their basis of connection and transaction details is given

below:

SrNo

Client Name andPAN

Member Nameand Code

Basis of Connection

Radford Group

1

DhanleelaInvestments &

Trading CompanyLimited

GEPL Capital Pvt.Ltd. (724)

On analyzing the bank statement submitted by thetrading member Gepl Capital Pvt. Ltd for its

client Dhanleela Investments & Trading CompanyLimited, it was observed that the client hasreceived / transferred funds from / to thecompany Radford Global Limited. It was alsoobserved that it has transferred funds to NeerajSingal, Brij Bhushan Singal and Ritu Singal

(AAACR1770P)

2

Pyramid TradingAnd Finance Ltd

C.D.EquisearchPvt.Ltd. (87)

On analyzing the bank statement submitted by thetrading member C.D Equisearch Pvt Ltd for itsclient Pyramid Trading and Finance Limited, itwas observed that the client has received /transferred funds from / to the company RadfordGlobal Limited

(AAACP2548R)

3

Pine AnimationLimited

Mehta EquitiesLtd. (122)

On analyzing the bank statement submitted by thetrading member C.D Equisearch Pvt Ltd for itsclient Pyramid Trading and Finance Limited, itwas observed that the client has transferred fundsto the Pine Animation Limited. From the analysisof bank statement of Pine Animation Limited, itwas observed that funds were transferred to oneEntity Blue Circle Services Ltd.

(AAECM0267A)

4

Amrit SalesPromotion PvtLimited

Arch Finance Ltd.(3257)

From the analysis of bank statement of Amrit SalesPromotion Pvt. Ltd., it was observed that funds

were received from Blue Circle Services Ltd.(AACCA3220D)

5Burlington FinanceLimited


As per bank statement of the client 'Amrit SalesPromotion Pvt Limited', it has received /transferred funds from / to 'Burlington FinanceLimited' and 'Symphony Merchant Pvt Ltd'.

(AABCB2575P)

6SymphonyMerchant Pvt Ltd


(AADCS5411K)



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7

Bazigar TradingPrivate Limited Arch Finance Ltd.

(3257)

The client 'Bazigar Trading Private Limited' and theclient 'Amrit Sales Promotion Pvt Limited' havecommon phone number and email-id viz,'9831714151' and '[email protected],[email protected]' respectively.

(AABCB3052B)

8

ManimudraVincom PrivateLimited Arch Finance Ltd.

(3257)

As per UCC database updated by the tradingmember Arch Finance Ltd for its clients entity viz.Bazigar Trading Private Limited (S.No 41) andManimudra Vincom Private Limited have sameaddress viz, 19 R.N. Mukherjee Lane, 2nd Floor,Kolkata, West Bengal-700001

(AADCM4316K)

9Blue CircleServices Limited

Mehta EquitiesLtd. (122)

The clients 'Blue Circle Services Limited', 'DevatmaDistributors Private Limited' and 'Anjali SuppliersPrivate Limited' has common email id viz,[email protected]'

(AAACB2131L)

10

DevatmaDistributorsPrivate Limited

The CalcuttaStock Exchange

Ltd. (990)(AADCD7140G)

11Anjali SuppliersPrivate Limited

Madhya PradeshStock ExchangeLtd. (991)(AAJCA1784D)

12Rangan VincomPrivate Limited

The CalcuttaStock ExchangeLtd. (990)

Rangan Vincom Private Limited' has transferredshares to 'Devatma Distributors Private Limited' inthe off market.(AAGCR1715E)

13

KatyaniCommoditiesPrivate Limited


As per the MCA website, Rangan Vincom PrivateLimited and Katyani Commodities PrivateLimited have common address viz, 4, N.S Road,1st Floor, Kolkata, West Bengal-700001.(AAECK6244R)

14Ladios TradingPrivate Limited


Rangan Vincom Private Limited', 'Ladios TradingPrivate Limited', 'Avlokan Dealcom PrivateLimited' has common phone number viz,'9831432937'.

(AACCL3868N)

15Avlokan DealcomPrivate Limited

The CalcuttaStock ExchangeLtd. (990)(AALCA1583G)



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16

KingfisherProperties PrivateLimited

Gateway FinancialServices Ltd.(3199)

On analyzing the bank statement of the client it wasobserved that the client has received / transferredfunds from / to 'Esquire Enclave Private Limited,Fairlink Housing Pvt Ltd. Further, from the bankstatement analysis, the client 'Kingfisher Properties

Pvt. Ltd.' has also transferred the funds to 'SignetVinimay Pvt Ltd' . On analyzing the bank statementof the Fairlink Housing Pvt. Ltd., it was observedthat the client had received / transferred fundsfrom / to group entities viz, 'Kingfisher PropertiesPrivate Limited', 'Divyadrishti Merchants PrivateLimited', 'Divyadrishti Traders Pvt Ltd'. Further,the client has also received / transferred funds toits other connected / related entities viz, TopwellProperties Pvt Ltd. On analyzing the bankstatement received from the trading member KorpSecurities Ltd for its client Fairlink Housing

Private Limited, it was observed that the said entityhas received funds from an entity viz, VenkateshSales Pvt Ltd which as per the MCA website hasthe common address as that of one of the directorviz, Dhruv Narayan Jha of the company BlueCircle Services Limited viz, P-27, Princep Street,3rd Floor, Kolkata, West Bengal 700072.Further, as per MCA website the email address ofVenkatesh Sales Pvt Ltd and Blue Circle ServicesLtd is common viz,[email protected].

(AAECK3394G)

21

Topwell PropertiesPrivate Limited


On analyzing bank statement of the TopwellProperties Private Limited, it was observed thatfunds were received/transferred among EsquireEnclave Private Limited, Radison PropertiesPrivate Limited, Kingfisher Properties PrivateLimited, Shivkhori Construction Pvt. Ltd. NaturalHousing Private Limited And Limestone PropertiesPrivate Limited. Funds were also transferred toSignet Vinimay Pvt. Ltd.and Sankalp Vincom Pvt.Ltd.

(AADCT8403C)

17

Esquire Enclave

Private Limited

Gateway Financial

Services Ltd.(3199)

The clients 'Kingfisher Properties Private Limited',

Esquire Enclave Private Limited, 'RadisonProperties Private Limited', 'Shivkhori ConstructionPrivate Limited', 'Limestone Properties PrivateLimited', 'Topwell Properties Private Limited' and'Natural Housing Private Limited' has commonaddress, email id and common directors viz, 95A C.R Avenue, 1st Floor, Kolkata, West Bengal 700073, [email protected] and Vishal Sharma

(AACCE7065J)

18Radison PropertiesPrivate Limited

Gateway FinancialServices Ltd.(3199)(AAFCR2818B)

19ShivkhoriConstructionPrivate Limited




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(AAPCS7850L) and Chiranjit Mahanta.

20

LimestoneProperties PrivateLimited


(AACCL0133G)

22 Natural HousingPrivate Limited Gateway FinancialServices Ltd.(3199)(AADCN6251G)

23

DivyadrishtiMerchants Pvt Ltd

Millennium StockBroking PrivateLimited (6151)

As per the KYC submitted by the trading member'Korp Securities Ltd.' for its clients 'DivyadrishtiMerchants Pvt Ltd', 'Divya Drishti Traders PvtLtd', 'Dhanraksha Vincom Pvt Ltd.' and 'Ridhi

Vincom Pvt Ltd', all the clients have commonaddress viz, '163 B, M.G Road, 3rd Floor, KolkataWest Bengal700007'.

(AABCD8147K)Korp SecuritiesLtd. (6213)

24

Divya DrishtiTraders Pvt Ltd

Millennium StockBroking PrivateLimited (6151)

(AABCD8146J)Korp SecuritiesLtd. (6213)

25DhanrakshaVincom Pvt Ltd.

Korp SecuritiesLtd. (6213)

(AADCD6028P)

26Ridhi Vincom PvtLtd

Korp SecuritiesLtd. (6213)

(AAECR9858C)

27

RunichaMerchants PrivateLimited

The CalcuttaStock ExchangeLtd. (990) As per the KYC submitted by the trading member

'The Calcutta Stock Exchange Ltd' for its clients'Runicha Merchants Private Limited', 'SignetVinimay Private Limited', 'Winall Vinimay PrivateLimited' and 'Sanklap Vincom P Ltd' and as per theMCA Website, all the clients have common addressviz, '23/1, Principal Khudiram Bose Road, Kolkata,West Bengal 700006 and common directors viz,Abhiset Basu and Pradip Dey.

(AAECR0580M)

28Signet VinimayPrivate Limited

The CalcuttaStock ExchangeLtd. (990)(AAMCS1712Q)

29Winall VinimayPrivate Limited

The CalcuttaStock ExchangeLtd. (990)(AAACW8004B)

30Sanklap Vincom PLtd

The CalcuttaStock ExchangeLtd. (990)(AAMCS1711P)

31Spice MerchantsPrivate Limited


As per the KYC submitted by the trading member'The Calcutta Stock Exchange Ltd' for its clients'Runicha Merchants Private Limited', 'SignetVinimay Private Limited', 'Winall Vinimay PrivateLimited', 'Spice Merchants Private Limited' and'Apex Commotrade Private Limited Ltd', all clientshave common email id viz, [email protected] common phone number viz, 9836488845

(AAPCS7492G)

32

Apex CommotradePrivate Limited The Calcutta

Stock ExchangeLtd. (990)(AAJCA4459K)



26/27


33

DevakanthaTrading PrivateLimited #

Vishesh CapitalPvt.Ltd. (3272)

As per the bank statement submitted by the tradingmember 'Vishesh Capital Pvt.Ltd.' for its client'Devakantha Trading Pvt Ltd', it was observed thatthe client has received / transferred fund from / to'Spice Merchants Pvt Ltd'.

(AADCD7044B)

34

Shelter SalesAgency Pvt Ltd #

Anand Rathi Share& Stock BrokersLtd. (949)

As per the KYC submitted by the trading member'Vishesh Capital Pvt.Ltd.' for its client 'DevakanthaTrading Pvt Ltd' and 'Anand Rathi Share & StockBrokers Ltd.' and 'Comfort Securities Ltd' for itsclient 'Shelter Sales Agency Pvt Ltd', both theclients have common phone number viz,'8108780561'.

(AASCS1797F)Progressive ShareBrokers Pvt.Ltd.(967)Comfort SecuritiesLtd. (3186)

35

Udbal MercantilePrivate Limited #

SunteckWealthmax CapitalPrivate Limited

(3070)

As per the KYC submitted by the trading member'Vishesh Capital Pvt.Ltd.' for its client 'DevakanthaTrading Pvt Ltd' and 'Sunteck Wealthmax CapitalPrivate Limited' and 'Vishesh Capital Pvt.Ltd.' forits client 'Udbal Mercantile Private Limited', RekhaArvind Gaud and Kalavatidevi Pratap NarayanGaud who are directors of Devakantha TradingPrivate Limited and Udbal Mercantile PrivateLimited respectively has common address viz,Safalya 806 A, Mahavir Nagar, Kandivali West,Mumbai400067.

(AABCU2648C)Vishesh CapitalPvt.Ltd. (3272)

36

AmrushaMercantile PrivateLtd #

Anand Rathi Share& Stock BrokersLtd. (949)

As per the KYC submitted by the trading member'Vishesh Capital Pvt.Ltd.' for its client 'UdbalMercantile Private Limited' (S.No 16) and 'Anand

Rathi Share & Stock Brokers Ltd.' and 'ComfortSecurities Ltd' for its client 'Amrusha MercantilePrivate Ltd', both the clients has common phonenumber viz, 8108780562.

(AALCA0340D)

Progressive Share

Brokers Pvt.Ltd.(967)Comfort SecuritiesLtd. (3186)

37SKM TravelsPrivate Limited


The company 'Winall Vinimay Private Limited(S.No 9) and 'SKM Travels Private Limited' havecommon director viz, 'Abhiset Basu.(AAICS0688K)

38

Scope VyaparPrivate Limited Gateway Financial

Services Ltd.(3199)

As per the bank statement submitted by the tradingmember The Calcutta Stock Exchange Ltd' for itsclient 'Winall Vinimay Pvt Ltd', it was observed thatthe client has received / transferred fund from / to

Scope Vyappar Pvt Ltd'

(AAICS6023N)

39Vibgyor FinancialService Pvt Ltd

India Infoline LtdThe client Vibgyor Financial Service Pvt Ltd hasreceived shares in off market from Scope VyaparPrivate Limited.(AAACV8378B)

Suspected Entities

1Trimurthi FinvestLimited

ExclusiveSecurities Ltd.

As per the KYC submitted by the trading member'Exclusive Securities Ltd.' for its clients 'Trimurthi



27/27

(6369) Finvest Limited' and 'Purvi Finvest Limited', boththe company have common address viz, '9, BhojNagar, Annpurna Road, Indore - 452009'

(AAACT6383N)ATS ShareBrokers Pvt. Ltd.(6481)

India InfolineLimited (179)

2

Purvi FinvestLimited

ATS ShareBrokers Pvt. Ltd.(6481)

(AABCP6564C)ExclusiveSecurities Ltd.(6369)

3

East West FinvestIndia Limited Exclusive

Securities Ltd.

(6369)

As per the MCA website and also as per the KYCsubmitted by the trading member 'ExclusiveSecurities Ltd.' for its clients 'Trimurthi FinvestLimited' (S.No 1) and 'East West Finvest IndiaLimited', both the companies have commondirector viz, 'Sharad Kumar Darak'.

(AAACE6834D/AADCE1236G)

4

Jayant Security &Finance Ltd

ExclusiveSecurities Ltd.(6369)

As per the MCA website 'Trimurthi FinvestLimited' (S.No 1) and 'Jayant Security & FinanceLtd', both the companies have common email idviz, '[email protected]'(AAACJ4848G)

ATS ShareBrokers Pvt. Ltd.(6481)

Sd/-

DATE:DECEMBER 19, 2014 RAJEEV KUMAR AGARWAL

PLACE: MUMBAI WHOLE TIME MEMBER


interim order in the matter of radford global ltd

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