Order in the matter of Radford Global Ltd

8/20/2019 Order in the matter of Radford Global Ltd

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Order in the matter of Radford Global Limited Page 2 of 23

3. Further, during the examination, upon an analysis of the order-log and trade-log the sellingbehaviour/ pattern of 15 sellers (hereinafter collectively referred to as " sellers ") prima facieappeared to be suspicious . It was observed that price of the scrip was influenced by these sellers

while trading in the scrip of Radford by selling either miniscule number of shares per day with

very less quantity vis-à-vis their shareholding or by controlling the trade volume of the scrip. The selling pattern of these sellersis exemplified in the table below:

Table 1: Selling pattern of the sellers .

Sr.No PAN Name Date Trades

SharesSold

Shareholdingbefore placingthe sell order

1 AAKHA8826N ANUP MANILALSHAH (HUF) 10/01/2013 9 2800 3800

2 ATWPK6701D ARTIBEN SKANSARA

16/08/2012 2 2 150017/08/2012 1 1 149821/08/2012 1 1 149724/08/2012 2 2 149627/08/2012 1 1 149430/08/2012 1 1 149331/08/2012 1 1 149206/09/2012 1 1 1491

Total 10 10

3 AGSPS5666E

BHARATKUMAR

JAYANTILALSHAH

09/10/2012 1 250 50010/10/2012 1 50 250

19/11/2012 1 50 20010/01/2013 1 100 150 Total 4 450

4 AAYPM2723JDINASATISHKUMARMEHTA

11/05/2012 1 100 100

5 ACLPK9984A HARI MOHANKHANDELWAL

23/07/2012 1 200 100007/09/2012 1 200 80013/09/2012 1 200 60021/09/2012 1 100 40026/09/2012 1 100 30004/10/2012 1 200 200

Total 6 1000

6 ANIPM9254BHASUMATIGHANSHYAMMANDLIA

04/10/2012 2 200 200

7 ABGPG6544GKANAIYALALMANILALGANDHI

10/09/2012 1 100 50013/09/2012 1 100 40018/09/2012 1 100 30025/09/2012 1 100 20012/10/2012 1 100 100

Total 5 5008 AOBPS1451C 24/05/2012 1 1 1000


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MANISHA JAYESH SHAH

28/05/2012 1 1 99907/06/2012 1 1 99815/06/2012 1 1 99718/06/2012 1 1 99619/06/2012 1 5 99521/06/2012 1 1 99022/06/2012 2 2 98926/06/2012 3 3 98727/06/2012 4 4 98428/06/2012 5 5 98029/06/2012 6 6 97501/08/2012 1 1 96903/08/2012 1 1 96808/08/2012 1 1 967

Total 30 34

9 AALPT9962B MANSUKHBHAI JAGABHAI TANTI 17/10/2015 1 100 100

10 AGWPP5778Q PRAGNA PATEL

16/01/2013 1 10 30017/01/2013 1 15 29018/01/2013 1 15 27522/01/2013 1 10 26024/01/2013 1 10 250

Total 5 60

11 ACJPG8162C RAJEEV GARG

21/09/2012 1 100 60016/11/2012 1 100 50026/11/2012 1 20 40027/11/2012 1 20 40029/11/2012 1 10 38004/12/2012 1 20 35005/12/2012 1 10 35006/12/2012 1 10 33007/12/2012 1 10 32014/12/2012 1 20 30019/12/2012 1 20 28021/12/2012 1 20 26026/12/2012 1 20 240

28/12/2012 1 20 22002/01/2013 1 20 20007/01/2013 1 20 18010/01/2013 2 40 16014/01/2013 1 20 12015/01/2013 1 5 12016/01/2013 1 5 10017/01/2013 1 5 9518/01/2013 1 5 9021/01/2013 1 5 85

22/01/2013 1 5 8023/01/2013 1 5 75


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24/01/2013 1 5 7025/01/2013 1 5 7028/01/2013 1 5 65

Total 29 550

12 AELPG9023L RAMILA GANDHI

28/08/2012 1 100 30003/09/2012 1 100 20005/09/2012 1 100 100

Total 3 300

13 AFXPS1751CREKHABENLAKHABHAISAGPARIA

17/09/2012 1 100 110018/09/2012 1 100 0*

Total 2 200

14 ANFPK3652GSUNILMOHANLALKANSARA

31/12/2012 1 7 96608/01/2013 1 10 95910/01/2013 8 500 949

Total 10 517

15 AHGPV3775J VEENAMOHANDAS VALBHANI

01/11/2012 1 500 500**

Total 111 7321

* Transferred 900 shares to her broker** Got 500 shares dematted in her account

4. The above mentioned selling pattern of the sellers appeared to be even more surprising in lightof the fact that almost on all dates when the above trades were executed, there was a huge

demand for the shares of Radford and buyers had continuously placed large buy orders onupper circuit. It is noted that during Pre-patch Ithe percentage of sell orders in comparison tothe buy orders was miniscule as can be seen in the table below:

Table 2: Month-wise Order book snapshot during the Pre-Patch I period (Large buyorders as compared to miniscule sell orders)

Month

Buy orderquantity(Cumulative)

Orderexecutedquantity

% of executed quantity out of totalbuy order quantity

February 2012 112000 100 0.09%March 2012 880200 0 0.00%

April 2012 1282900 600 0.05%May 2012 1281353 703 0.05%

June 2012 1252478 430 0.03% July 2012 1111890 452 0.04% August 2012 532987 118 0.02%September 2012 654282 1504 0.23%October 2012 673260 1328 0.20%November 2012 475276 820 0.17%December 2012 353053 657 0.19%

January 2013 248479 5238 2.11%Grand Total 8858158 11950 0.13%


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5. It is also noted that during Pre-Patch I,on most of the days, buy orders were placed on the stockexchange platform as soon as the trading session began, whereas the sell orders by the sellers

were placed much later on the respective days. Few instances of placement of such buy orders

at the beginning of the trading session are mentioned below:

Table 3: Instances of early placement of buy orders.

ORDERDATE ORDERTIME

PRICE AT WHICH THE ORDER WAS

PLACED QTYORDER TYPE

29/02/2012 09:15:00 3.35 5000 Buy07/03/2012 09:15:00 3.35 1000 Buy10/04/2012 09:15:00 3.68 200 Buy24/05/2012 09:15:00 4.91 5000 Buy07/06/2012 09:15:00 5.67 5000 Buy25/07/2012 09:15:00 12.88 10000 Buy06/08/2012 09:15:00 14.89 1500 Buy05/09/2012 09:15:00 24.14 1000 Buy04/10/2012 09:15:00 43 150 Buy19/11/2012 09:15:00 68.45 100 Buy05/12/2012 09:15:00 111.2 500 Buy28/01/2013 09:15:00 241.34 2400 Buy

6. From the above description and tables, the following was observed with respect to the sellers :

a. Despite there being a huge demand for the shares of Radford and the sellers : holding largenumber of shares of Radford, some of the sellers sold shares in miniscule quantities on

various occasions and thereby controlled the supply of shares.b. During Pre-Patch I (having 121 trading days) the sellers traded on 72 trading days and

executed 84 trades. Out of these 72 days, on 64 days the sellers contributed to 100% of thedaily traded volume.

c. Some of the sellers sold shares only to maintain the average daily volume. For instance, on17 trading days (when the average trading volume was 98 shares) the sellers sold 100 sharesonly despite holding large number of shares and there being large number of buy orders.

d. The selling behaviour of the sellers also exhibited a suspicious sequential pattern i.e. in spiteof a huge demand for the shares during Pre-Patch I , most of the sellers did not sell theirshares together in one period. In fact, they sequentially sold their shares in such a mannerthat one seller stopped selling when the other started selling its/his/her shares. Thesuspicious trading pattern of the sellers is shown in Annexure A.

7. It prima facieappears from the above observations that the sellers were selling their shares in anabnormal / non-genuine manner and were acting under a pre-determined plan to

fix/manipulate the price of the scrip of Radford.


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8. In addition to the above observations, during the examination, certain discrepancies werenoticed regarding the source of acquisition of the shares by the sellers . In this regard, thefollowing facts are noteworthy:

a)

It is a matter of record that trading in the scrip of Radford was suspended on BombayStock Exchange Limited (“BSE”), the only stock exchange where it is listed, from January14, 2003 to December 19, 2011 for non-compliance of the equity listing agreement.

According to Radford, its current promoters had taken over it in year 2011 and it hadappointed Universal Capital Securities Limited, as Registrar and Transfer Agent (hereinafterreferred as "RTA") in January 2012. At that time, the company handed over the shareholderlist (hereinafter referred as "RTA List") to RTA.

b) It was found that 236 shareholder records were having record name as "abeyance" in RTAList. These 236 abeyance records (amounting to total of 1,38,400 shares) had the same folionumber i.e. 13518.

c) When inquired about the justification for the abeyance records, Radford submitted that“when the current management of Radford received the data from the prior management pertaining to thedetails of the shareholders, they noticed that there were no details such as name, folio nos. etc. for 1,38,400shares. Hence, Radford had put these shares under abeyance and requested RTA not to reject any requestmade by the shareholder whose names are not appearing in the share master data submitted by the companyto RTA ” .

d) Contrary to the aforesaid reason provided by Radford, the list submitted by the old

management to Registrar of Companies ("RoC") in year 2010 had the completeshareholders’ list with details and did not contain any shareholding in “ abeyance” category .

e) RTA, vide its letter to SEBI dated August 14, 2015, stated that the RTA List provided byRadford to it had one record named “abeyance” in different distinctive number ranges andsame folio number. According to the RTA, when it sought the explanation in respect ofthese shares from Radford, it replied that it did not have proper control over theirdistinctive number master. Further, Radford had advised the RTA to point out any suchdiscrepancies before rejecting the request from investor for transfer or demat. Furthermore,the said letter states that only after verification of folio number, number of shares andshareholder's name, Radford or RTA issued new certificate to the shareholder requestingthe transfer or demat. It is strange to note that RTA approved the share transfers, requestsfor demat and issuance of new share certificates without ascertaining the authenticity ofentities from whom the sellers apparently received the shares i.e. without sellers confirmationnotice and without checking the details like folio number, number of shares, name,distinctive numbers, etc.

f) The latest available shareholder list as on January 1, 2012 on MCA website was that of the Annual General Meeting held by Radford in 2010. This list was submitted by Radford to

RoC in the year 2010 (hereinafter referred to as "MCA List"). This MCA list did not containany abeyance records. On a comparison of the MCA list with the shareholders' master list


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provided by Radford to RTA in January 2012, most of shareholders ’ names were notmatching.

g) It is surprising to note that majority of shareholders (1,976 shareholders in total) of Radfordin RTA List in year 2011 were different from those appearing in the MCA list (submitted

to RoC in 2010) especially when the scrip was suspended on BSE.h) The Depositories (CDSL and NSDL) informed that first demat for the scrip of Radford

happened only in January 2012.i) There was no apparent reason for the abeyance records to suddenly appear in the

shareholder’s list submitted by new management of Radford to RTA.j) Certain complaints have also been received by SEBI from shareholders alleging that

Radford had issued duplicate shares in lieu of original certificates held by them to somethird party and is now refusing to transfer shares in their name.

9. Upon noticing the aforesaid discrepancies regarding the source of shares of the sellers , thephysical share certificates of the sellers were also examined. The examination revealed severalfactors which prima facieindicate that the share certificates held by the sellers were not genuine.

The said factors (details whereof are provided in Annexure B) are summarized as under:a. The company/RTA was not able to furnish necessary documentary evidence which was

relied upon by it/them to ascertain the genuineness of shareholding of a few sellers whosename was not there in the MCA list namely, Rajeev Garg, Veena Mohandas Valbhani,Bharatkumar Jayantilal Shah and Ramila Gandhi. However, as per the photocopy of share

certificate submitted by Radford, they were its shareholders since May 1995.b. The names of three entities (Veena Mohandas Valbhani, Bharatkumar Jayantilal Shah and

Ramila Gandhi) were not part of the mailing list of shareholders for communication givenby the new management of Radford to RTA.

c. The physical share certificate of Manisha Jayesh Shah furnished by Radford had a stickerof PS Global Ltd affixed on share certificate of Rossette Resorts Ltd. This is a deviationfrom the practice followed by Radford of issuing new share certificate in lieu of oldcertificate.

d. Company / RTA failed to produce any documentary evidence for establishing genuinenessof the transfer of shares from earlier shareholder to Artiben S Kansara.

e. Contradictory statements were given by RTA with respect to transfer of shares made to Anup Manilal Shah (HUF).

f. Certain sellers namely, Hari Mohan Khandelwal, Kanaiyalal Manilal Gandhi, RekhabenLakhabhai Sagparia, Rekhaben Lakhabhai Sagparia, Mansukhbhai Jagabhai Tanti andPragna Patel were issued shares from abeyance list. Their names did not appear either inthe MCA List or the RTA List. When inquired, Radford /RTA were not able to furnishany documentary evidence to justify how they ascertained the genuineness of these

shareholders. This is also in contradiction with the RTA's policy of verification while


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transferring or dematerializing, wherein such policy, prima facie , does not appear to befollowed.

g. Dina Satishkumar Mehta and Priya Sanghvi held shares with the same folio number inMCA list as well as in RTA list. These two entities did not have any transaction with each

other.h. As per Radford’s board of directors’ resolution dated February 15, 2012, it had authorized

its company secretary and RTA to sign the share certificate of the company. In fewinstances signatures on physical share certificates of the RTA/company's authorizedpersonnel were missing.

10. From the facts and circumstances discussed in the preceding paragraphs, it is prima facie inferredthat the share certificates held by the sellers were not genuine. In this regard, it is pertinent tonote that the stationary of the physical share certificate was controlled by Radford only. Also,as seen from the physical share certificates, Radford did not number the share certificates withconsecutive serial numbers. Thus, it appears that Radford was involved in issuance of non-genuine share certificates held by the sellers . This finding is further strengthened by the factthat Radford did not provide any information to SEBI when it was asked to furnish its IPOallotment list and other relevant details.

11. In this case, it is a matter of record that during Pre-Patch I, the price of the shares of Radfordrose from ₹ 3.20, to ₹ 241.35. From the acts and conduct of the sellers discussed above, I prima

facie find that they played a crucial role in pushing the price of scrip of Radford to such highlevels especially by controlling the supply of shares. Their suspicious acts selling shares inminiscule quantities despite there being a huge demand, contributing to 100% trading volumeon most of the days, placing trades in a manner so as to maintain the daily average volume andnot letting the liquidity dry out by sequentially selling shares clearly show that their sellingpattern was not normal and was prima faciedirected towards pushing up the price of the scripof Radford. The same is further corroborated by the fact that the share certificates held by thesellers were prima facie not genuine. The involvement of Radford in issuance of non-genuinecertificates to these sellers signifies that the sellers carried out the aforesaid acts in collusion with

Radford, its promoters and directors.

12. As noted in the interim order dated December 19, 2014, Radford and other entities named thereinmisused the securities market system to artificially increase price of the scrip for providing longterm capital gain (“LTCG”) benefits to the preferential allottees of Radford. As discussedabove, the sellers played a crucial role in increasing the price of the scrip. I, therefore prima faciefind that the sellers were also a part of the scheme, plan, device and artifice employed in relationto the scrip of Radford and described in the interim order dated December 19, 2014.


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13. Considering the above, I am of the prima facie view that the acts of the sellers discussedhereinabove are ‘fraudulent’ as defined under regulation 2(1)(c) of the Securities and ExchangeBoard of India (Prohibition of Fraudulent and Unfair Trade Practices relating to SecuritiesMarket) Regulations, 2003 (‘the PFUTP Regulations” ) and are in contravention of the

provisions of regulations 3(a), (b), (c) and (d) and 4(1), 4(2)(a), (b) and (e) thereof and section12A(a), (b) and (c) of the Securities and Exchange Board of India Act, 1992. The said provisionsare reproduced hereunder:-

SEBI ACTProhibition of manipulative and deceptive devices, insider trading and substantialacquisition 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 belisted on a recognized stock exchange, any manipulative or deceptive device or contrivance in contraventionof the provisions of this Act or the rules or the regulations made there under;(b) employ any device, scheme or artifice to defraud in connection with issue or dealing in securities which arlisted 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 uponany person, in connection with the issue, dealing in securities which are listed or proposed to be listed on arecognised stock exchange, in contravention of the provisions of this Act or the rules or the regulations madethere under;"

PFUTP Regulations"3. Prohibition of certain dealings in securities

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 ina 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 whicare 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 uponany person in connection with any dealing in or issue of securities which are listed or proposed to be listed ona recognized stock exchange in contravention of the provisions of the Act or the rules and the regulationsmade there under.

4. Prohibition of manipulative, fraudulent and unfair trade practices(1) Without prejudice to the provisions of regulation 3, no person shall indulge in a fraudulent or an unfair

trade practice in securities.


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(2) Dealing in securities shall be deemed to be a fraudulent or an unfair trade practice if it involves fraudand 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;(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 avoidanceof loss;….

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

14. I am of the opinion that the ongoing investigation in the matter should also cover the entirescheme discussed hereinabove to find out the role of any other entity therein including RTA,connection amongst the concerned entities and other related aspects of the matter.

15. SEBI strives to safeguard the interest of genuine investors in the Indian securities market. I amof the opinion that, while investigation in the matter is underway, allowing the sellers who are

prima faciefound to be involved in such fraudulent, unfair and manipulative transactions tocontinue to operate in the market is inimical to the interests of participants in the securitiesmarket and would shake the confidence of the investors in the securities market. Consideringthe facts and circumstances, I deem it a fit case where, pending investigation, effective andexpeditious preventive action is required to be taken by way of ad interim ex-partein order toprotect the interests of investors and preserve the safety and integrity of the market.

16. In view of the foregoing, in order to protect the interest of the investors and the integrity ofthe securities market, I, in exercise of the powers conferred upon me in terms of sections 11(1),11(4) and 11B read with section 19 of the SEBI Act, pending inquiry/investigation and passingof final order in the matter, hereby restrain the following persons from accessing the securitiesmarket and buying, selling or dealing in securities, either directly or indirectly, in any manner,till further directions.

Sr. No PAN Name

1 AAKHA8826N ANUP MANILAL SHAH (HUF)2 ATWPK6701D ARTIBEN S KANSARA3 AGSPS5666E BHARATKUMAR JAYANTILAL SHAH4 AAYPM2723J DINA SATISHKUMAR MEHTA5 ACLPK9984A HARI MOHAN KHANDELWAL6 ANIPM9254B HASUMATI GHANSHYAM MANDLIA7 ABGPG6544G KANAIYALAL MANILAL GANDHI8 AOBPS1451C MANISHA JAYESH SHAH9 AALPT9962B MANSUKHBHAI JAGABHAI TANTI

10 AGWPP5778Q PRAGNA PATEL11 ACJPG8162C RAJEEV GARG


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12 AELPG9023L RAMILA GANDHI13 AFXPS1751C REKHABEN LAKHABHAI SAGPARIA14 ANFPK3652G SUNIL MOHANLAL KANSARA15 AHGPV3775J VEENA MOHANDAS VALBHANI

17. This order is without prejudice to the right of SEBI to take any other action that may be initiatedagainst the aforementioned entities in accordance with law.

18. This order shall come into force with immediate effect. The stock exchanges and thedepositories are directed to ensure that all the above directions are strictly enforced.

19. The persons/entities against whom this Order is passed may file their objections, if any, withintwenty 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 dateand time to be fixed on a specific request, received from the said persons/entities.

Sd/-

DATE: November 9 th, 2015 RAJEEV KUMAR AGARWAL

PLACE: MUMBAI WHOLE TIME MEMBER

SECURITIES AND EXCHANGE BOARD OF INDIA


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Annexure A : Sequential trading pattern of the sellers

Date PAN NameQuanti

ty

Totaldailytrade

volume

Volume

contribute

d

Totalsell

orders

11/05/2012 AAYPM2723JDINA SATISHKUMARMEHTA 100 100 100% 100

24/05/2012 AOBPS1451CMANISHA JAYESHSHAH 1 1 100% 1








26/06/2012 AOBPS1451C

MANISHA JAYESH

SHAH 3 3 100% 327/06/2012 AOBPS1451C

MANISHA JAYESHSHAH 4 4 100% 4



23/07/2012 ACLPK9984AHARI MOHANKHANDELWAL 200 200 100% 200


03/08/2012 AOBPS1451C MANISHA JAYESHSHAH 1 1 100% 1


16/08/2012 ATWPK6701D ARTIBEN S KANSARA 2 2 100% 217/08/2012 ATWPK6701D ARTIBEN S KANSARA 1 1 100% 121/08/2012 ATWPK6701D ARTIBEN S KANSARA 1 1 100% 124/08/2012 ATWPK6701D ARTIBEN S KANSARA 2 2 100% 227/08/2012 ATWPK6701D ARTIBEN S KANSARA 1 1 100% 128/08/2012 AELPG9023L RAMILA GANDHI 100 100 100% 100

30/08/2012 ATWPK6701D ARTIBEN S KANSARA 1 1 100% 131/08/2012 ATWPK6701D ARTIBEN S KANSARA 1 1 100% 1


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03/09/2012 AELPG9023L RAMILA GANDHI 100 100 100% 10005/09/2012 AELPG9023L RAMILA GANDHI 100 100 100% 10006/09/2012 ATWPK6701D ARTIBEN S KANSARA 1 1 100% 1


10/09/2012 ABGPG6544GKANAIYALALMANILAL GANDHI 100 100 100% 100



17/09/2012 AFXPS1751C

REKHABENLAKHABHAISAGPARIA 100 100 100% 100


18/09/2012 AFXPS1751C

REKHABENLAKHABHAISAGPARIA 100 200 50% 200

21/09/2012 ACJPG8162C RAJEEV GARG 100 200 50% 200




04/10/2012 ACLPK9984A HARI MOHANKHANDELWAL 200 400 50% 400

04/10/2012 ANIPM9254B

HASUMATIGHANSHYAMMANDLIA 200 400 50% 400

09/10/2012 AGSPS5666EBHARATKUMAR

JAYANTILAL SHAH 250 251 100% 251




17/10/2012 AALPT9962BMANSUKHBHAI

JAGABHAI TANTI 100 100 100% 250

01/11/2012 AHGPV3775J VEENA MOHANDAS VALBHANI 500 500 100% 650



JAYANTILAL SHAH 50 50 100% 15026/11/2012 ACJPG8162C RAJEEV GARG 20 20 100% 12027/11/2012 ACJPG8162C RAJEEV GARG 20 20 100% 12029/11/2012 ACJPG8162C RAJEEV GARG 10 10 100% 10

04/12/2012 ACJPG8162C RAJEEV GARG 20 20 100% 2005/12/2012 ACJPG8162C RAJEEV GARG 10 10 100% 110


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06/12/2012 ACJPG8162C RAJEEV GARG 10 10 100% 11007/12/2012 ACJPG8162C RAJEEV GARG 10 10 100% 1014/12/2012 ACJPG8162C RAJEEV GARG 20 82 24% 18219/12/2012 ACJPG8162C RAJEEV GARG 20 20 100% 20

21/12/2012 ACJPG8162C RAJEEV GARG 20 20 100% 2026/12/2012 ACJPG8162C RAJEEV GARG 20 20 100% 2028/12/2012 ACJPG8162C RAJEEV GARG 20 20 100% 120

31/12/2012 ANFPK3652GSUNIL MOHANLALKANSARA 7 7 100% 7



10/01/2013 AAKHA8826N ANUP MANILALSHAH (HUF) 2800 4385 64% 4385





14/01/2013 ACJPG8162C RAJEEV GARG 20 20 100% 2015/01/2013 ACJPG8162C RAJEEV GARG 5 5 100% 516/01/2013 ACJPG8162C RAJEEV GARG 5 15 33% 1516/01/2013 AGWPP5778Q PRAGNA PATEL 10 15 67% 1517/01/2013 ACJPG8162C RAJEEV GARG 5 20 25% 2017/01/2013 AGWPP5778Q PRAGNA PATEL 15 20 75% 2018/01/2013 ACJPG8162C RAJEEV GARG 5 40 13% 4018/01/2013 AGWPP5778Q PRAGNA PATEL 15 40 38% 4021/01/2013 ACJPG8162C RAJEEV GARG 5 5 100% 522/01/2013 ACJPG8162C RAJEEV GARG 5 15 33% 1522/01/2013 AGWPP5778Q PRAGNA PATEL 10 15 67% 1523/01/2013 ACJPG8162C RAJEEV GARG 5 605 1% 60524/01/2013 ACJPG8162C RAJEEV GARG 5 40 13% 4024/01/2013 AGWPP5778Q PRAGNA PATEL 10 40 25% 40



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Annexure B: Discrepancies / observations noticed in examination of physical sharecertificate of the sellers

Sr.No

PAN Name Shares sold

% of

totaltrade vol

Discrepancy/Observations

1 ACJPG8162CRAJEEVGARG

550 4.60%

It is observed from the copy of sharecertificate of Rosseto Resorts Limitedsubmitted by the company to SEBI that theentity is a shareholder from May 15, 1995.However, there were no subsequenttransfer(s) of these shares. On the contrary,the name of shareholder and folio number ispresent in RTA list but is not present in MCAlist (which had no Abeyance records).

Also 600 shares were dematerialised by thecompany/RTA on 17.02.2012 out of which550 shares have been sold in 29 trades from21.09.2012 to 28.01.2013. Further, the

company/RTA was unable to furnishnecessary documentary evidence which it hadrelied upon to ascertain the genuineness ofshareholding of the seller i.e. Rajeev Garg.

The remaining 50 shares were there in hisaccount as on 28.01.2013.

The distinctive number range of the shares assubmitted by the RTA in its list were different

vis-a-vis the share certificate's copy furnishedby the company to SEBI.

2 AOBPS1451CMANISHA

JAYESHSHAH

34 0.28%

As submitted by RTA, Sangeetha w/o AjithKumar had transferred 1000 shares toManisha Jayesh Shah on 30.11.2011. Thename of Sangeetha w/o Ajith Kumar (whoseholding was 2000 shares) figures in the MCAlist but does not figure in RTA list. These1000 shares were dematerialised on18.02.2012 out of which 966 shares were


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transferred to Sunil Kansara (entitymentioned at point 6). The remaining 34shares were sold in 30 trades from 24.5.2012to 8.8.2012. Manisha J Shah controlled the

supply of the shares by selling 1 or 2 shares ata time, even though large buy-side orders

were in the system.

The physical share certificate of Manisha Jayesh Shah as furnished by the company isthat of PS Global Ltd (earlier name ofRadford Global Limited). It is also observedthat the sticker of the name i.e. P S Global Ltdhas been affixed on the share certificate ofRossette Resorts Ltd. (P S Global was earlierknown as Rossette Resorts Ltd.). This is adeviation from the process of issuing newshare certificate as submitted by the companyto SEBI vide letter dated Aug 21, 2015, asthere is no mention of affixing sticker of newcompany name (PS Global Ltd.) on old

company name's share certificate (RossetteResorts Ltd.) itself. In this case thegenuineness of the shareholding has not beenestablished by the company / RTA.

It is also further observed that Manisha JayeshShah is related with one of the then directorsof the company i.e. Manish Nareshchandra

Shah (PAN: AELPS8560A) as their address(B-2,Vishwakarma Society, V.P. Road, Andheri West, Mumbai, Maharashtra, India,400058) and phone number (26280622)registered in KYC records are same. It is alsonoted that Manish Nareshchandra Shah hasalready been debarred by SEBI from dealingin securities vide the earlier interim order


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3 ATWPK6701D

ARTIBENSKANSARA

10 0.08%

As per information submitted by the RTA,Sumerji Sethia (holding 4000 shares) hadtransferred 1500 shares to Artiben S Kansara.However, neither the company nor the RTA

could produce necessary documentaryevidence for establishing the genuineness ofthe transfer of shareholding from SumerjiSethia to Artiben S Kansara. Further, name ofSumerji Sethia is present in MCA list. The said1500 shares were dematerialised by Artiben SKansara on 18.02.2012 of which only 10shares have been sold in 10 trades from16.08.2015 to 6.9.2012, that too when largebuy-side orders were there pending forexecution. She controlled the supply of theshares by selling 1 or 2 shares at a time.Remaining 1490 shares were there in heraccount as on 28.01.2013.

It was also observed that she had sameaddress and phone number as that of Sunil

Mohanlal Kansara.

4 ANFPK3652G

SUNILMOHANL

ALKANSARA

517 4.33%

Received 966 shares on 31.08.2012 throughoff market transaction from Manisha JayeshShah (entity at point 2) who is related to thethen director of the company.

He sold 517 shares from 31.12.2012 to10.01.2013 in 10 trades. Remaining 449 shares

were there as on 28.01.2013 in his account.

5 AAKHA8826N

ANUPMANILALSHAH(HUF)

280023.43

%

Sadhana Trivedi (500 shares), Ashok Mistry(1000 shares), Indravadan Shah (500 shares)and Vrajmohan Parikh (1000 shares)transferred 3000 shares to Anup Manilal Shah(HUF) in June 2012.

Further, Anup Manilal Shah also received 200shares from Sureshchandra M Raja on31/3/2012 and 600 shares from Nirupama H.


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Badani and Harish B. Badani (joint holders)on 31/3/2012.

Five share certificates (i.e. 500 shares out of

600 mentioned above) received by AnupManilal Shah from Nirupama Badani/HarishB. Badani (joint holders) did not haveauthorized signature of Company secretary orRTA's authorized personnel on it. Thecompany/RTA was not able to furnishnecessary documentary evidence which it hadrelied upon to

(i) ascertain the genuineness of shareholdingof the Anup Manilal Shah,

(ii) verify the transfer of shareholding fromaforesaid entities to Anup Manilal Shahand

(iii) grant subsequent approval for thedematerialization request of theseunsigned share certificates.

Further, as per MCA list, Indravadan Shahand Vrajmohan Parikh were holding 10,000shares each in single certificate and RTA didsplit the share certificates of any of theseshareholders. RTA transferred 1000 shareseach from Indravadan Shah and VrajmohanParikh to Anup Manilal Shah (HUF) withoutsplitting shareholding of 10,000 shares each

of Indravadan Shah and Vrajmohan Parikh.

Anup Manilal dematerialised Shah 3800shares on 09.08.2012 out of which he sold2800 shares in a single day i.e. on 10.01.2013in 9 trades. Remaining 1000 shares were therein his account as on 28.01.2013.


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The RTA, prima facie , did not seek sellerconfirmation before transfer of shares to

Anup Manilal Shah (HUF).

6 ACLPK9984A

HARIMOHANKHANDELWAL

1000 8.37%

As per the photocopy of share certificates of

Rosseto Resorts Ltd. submitted by thecompany to SEBI, the entity has been ashareholder from May 15, 1995 and there

were no subsequent transfer(s) of theseshares. However, the name of shareholder &folio no. are not present in MCA list as wellas in RTA list. Shares were issued to him from

Abeyance List. The 1000 shares held by him were dematerialised on 21.06.2012 Thecompany/RTA was not able to furnishnecessary documentary evidence which itrelied upon to ascertain the genuineness of hisshareholding. Further, these 1000 shares weresold by him in 6 trades from 23.07.2012 to04.10.2012.

7 ABGPG6544G

KANAIYALALMANILALGANDHI

500 4.18%

His name and folio numbers are not presentin MCA list and RTA list. Shares were issued

to him from abeyance list. The Company hasnot submitted any documentary evidence

which it relied upon to establish thegenuineness of the shares held by him beforeissuance from the abeyance list.

The 500 shares held by him weredematerialised on 24.05.2012. Further, he

sold all 500 shares from 10.09.2012 to12.10.2012 in 5 trades.

8 AHGPV3775J

VEENAMOHAND

AS VALBHANI

500 4.18%

As per the photocopy of share certificates ofRosseto Resorts Ltd. submitted by thecompany to SEBI, the entity is a shareholderfrom May 15, 1995 and there were nosubsequent transfers of these shares.

However, her name and folio no. 11501 arenot present in MCA list and RTA list. 500


20/23


shares were issued to her from the abeyancelist which were dematerialised on 08.10.2012.

In spite of the fact that her name does not

figure in the MCA list and the companyshowed her as a shareholder since 1995 (asper physical share certificate), thecompany/RTA were not able to furnishnecessary documentary evidence which wasrelied upon to ascertain the genuineness ofher shareholding.

She sold 500 shares in a single day i.e. on1.11.2012 to Prem Lata Nahar.

9 AGSPS5666E

BHARATKUMAR

JAYANTIL AL SHAH

450 3.77%

As per the photocopy of share certificates ofRosseto Resorts Ltd. submitted by thecompany to SEBI, he is a shareholder fromMay 15, 1995 onwards and there were nosubsequent transfers for these shares. On thecontrary, the name and folio number of theshareholder are not present in MCA list

(which had no abeyance records in it) as wellas RTA list. He was issued shares fromabeyance list and dematerialised. 500 shareson 8.10.2012. The company/RTA was notable to furnish necessary documentaryevidence which it relied upon to ascertain thegenuineness of his shareholding.

He had sold 450 shares from 9.10.2012 to10.1.2013 to Taran (250 shares), Beacon (100shares), Bharat (50 shares) and Jagruti (50shares). Remaining 50 shares were there in hisaccount as on 28.01.2013.


21/23


10 AELPG9023LRAMILAGANDHI

300 2.51%

Ramila Gandhi has sold 300 shares from28.08.2012 to 05.09.2012 through on markettransactions. 200 shares were dematerialisedon 24.05.2012 and 100 shares were

dematerialised on 17.08.2012. 200 shares wereissued from Abeyance list by RTA.Remaining 100 shares were neither present inRTA list nor in the shares issued from

Abeyance list by RTA. Hence, source of 100shares is not known. Name and folio numberof the entity is not present in MCA list andRTA list.

11 AFXPS1751C

REKHABEN

LAKHABHAISAGPARI

A

200 1.67%

The entities namely Pravin Patel (500 shares),Rekha Sojitra (400 shares), Shobhana Sohitra(200 shares) transferred shares to RekhabenLakhabhai Sagparia. As these three names

were not present in RTA list, hence they wereissued shares from the Abeyance List. Thesaid 1100 shares were dematerialised on16.08.2012. Out of which, 100 shares weresold to Manjulaben on 17.09.2012 and 100

shares were sold to Ankit Kachhara on18.09.2012.

The entity was issued shares from AbeyanceList. Further the entity's name did not featurein MCA List as well as RTA List. Thecompany/RTA was unable to furnishnecessary documentary evidence to ascertain

the genuineness of shareholding of RekhabenLakhabhai Sagparia.

12 ANIPM9254B

HASUMA TIGHANSH

YAMMANDLIA

200 1.67%

The name of the entity is not present in MCAlist and RTA list. Hasumati GhanshyaMandlia was issued 200 shares from the

Abeyance list. The share certificate was issuedin lieu of old certificate. However, wheninquired, the company/RTA could notfurnish old certificate for verification andascertaining the genuineness of shareholding


22/23


of Hasumati Ghanshya Mandlia. The said 200shares were dematerialised by the entity on27.09.2012. The entity has sold 150 shares toNavin Munyal and 50 shares to Prem Lata on

market.

13 AALPT9962B

MANSUK HBHAI

JAGABHAI TANTI

100 0.84%

As per the share certificate, Mr. PurshotamSenjalia had transferred 100 shares toMansukhbhai Jagabhai Tanti on 01.07.1996.However, name of Mansukhbhai Jagabhai

Tanti is not present in RTA list and MCA list.Hence, shares were issued from the abeyancelist. The company/RTA was not able tofurnish necessary documentary evidence toascertain the genuineness of shareholding ofMansukhbhai Jagabhai Tanti.

100 shares were dematerialised on 8.10.2012. All the 100 shares were sold in 1 instance toPooja Agarwal on 17.10.2012 through on-market transaction.

14 AAYPM2723J

DINASATISHK UMAR

MEHTA

100 0.84%

As per MCA list, Folio number 13742

corresponds to Priya Sanghvi and as per RTAlist, it corresponds to Rajendra Popatlal Patel.

As per information furnished by RTA,Rajendra Popatlal Patel had transferred 100shares to Dina Mehta but name of theRajendra Popatlal Patel is not present in theMCA list. Further, Rajesh Popatlal Patel'sshare certificate mentions "issued in lieu of

old certificate". However, when inquired, thecompany/RTA could not furnish oldcertificate for verification and to ascertain thegenuineness of shareholding of the suspectedseller, Dina Satishkumar Mehta. These 100shares were dematerialised on 26.04.2012. Shesold entire 100 shares in 1 trade to Prem LataNahar on 11.05.2012 on-market.


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d h f df d l b l d f

15 AGWPP5778Q

PRAGNAPATEL

60 0.50%

Her name is not present in the MCA list andthe RTA list. The share certificate mentionedthat it was "issued in lieu of old certificate".However, when inquired, the company/RTA

could not furnish old share certificate for verification and to ascertain the genuinenessof her shareholding. The entity was issued 300shares by RTA from the Abeyance list and thesame were dematerialised on 10.01.2013. Outof these 300 shares, 60 shares were sold in 5trades during the period 16.01.2013 to24.01.2013 and the remaining 240 shares werethere in her account on 28.01.2013.

Total 732161.26

%

61.26% of shares, whose source of acquisitionis questionable, were sold on-market duringthe examination period.

Sd/-

DATE: November 9 th, 2015 RAJEEV KUMAR AGARWAL

PLACE: MUMBAI WHOLE TIME MEMBERSECURITIES AND EXCHANGE BOARD OF INDIA

Order in the matter of Radford Global Ltd

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