The entities penalised by SEBI are: Rituraj Sharma, Krishnna Joshi, Gayatri Rinwa, Yotta Agro Venture Pvt Ltd, Farm Silo Tech LLP, ZF Project 1 LLP, ZF Project 2 LLP, ZF Project 3 LLP, Toshan Seeds Private Limited, Gopal Vasharambhai Kuchhadiya, Girishkumar Ishvarlal Makvana, MSVO Ventures Pvt Ltd, Rahul Meena, Divya Soni, Ashutosh Tiwari, Rahul Saini, Anandkumar Sriram Mahto, Ttoys Bazar Private Limited, Manoj Maru, Vikram Singh Rathore, Unique Projects (Proprietorship of Sukh Tanwar), Mateshwari Trading Company (Proprietorship of Ratan Singh Bhati), Vishnu Balaji Farmer Producer Company Limited, Anjali Khandelwal, Monika Tewar, Poonam Khandelwal and Sujata Devi.
The final order, passed by Kamlesh C Varshney, SEBI whole-time member (WTM), follows an investigation covering 1 April 2020 to 31 January 2024. SEBI said the investigation found that the entities associated with Growpital had raised ₹192.88 crore from 5,208 unique investors through three LLPs ZF Project 1 LLP, ZF Project 2 LLP and ZF Project 3 LLP. Investors were admitted as partners, allotted units and offered assured returns from purported agricultural projects.
According to SEBI, the arrangement satisfied the four conditions for a CIS under Section 11AA (2) of the SEBI Act. The regulator found that investors’ contributions were pooled and used for the stated scheme. Investors contributed with the expectation of receiving profits or returns; the investments were managed on their behalf, and investors did not have day-to-day control over management and operations. SEBI also noted that the scheme had mobilised more than ₹100 crore.
SEBI observed that Growpital offered multiple investment plans, with investments ranging from ₹5,000 to ₹15 lakh per unit, and promised assured tax-free returns of around 10%pa (per annum) to 17%pa under plans such as Baby Farming and Leafy Eleven. The order records that the platform had offered 18 investment plans and that investors were brought into the LLPs through agreements and consent letters.
The regulator also examined the agricultural operations and revenue claimed by the entities. Growpital had claimed total revenue of ₹73.78 crore from farming activities, including ₹61.68 crore from the sale of jeera seeds allegedly produced on 75 acres in Barmer, Rajasthan. SEBI found the claim unsupported by convincing evidence. Based on agricultural yield and price data considered in the order, it estimated that the maximum revenue that could practically have been generated from the 75-acre farm was about ₹30 lakh, substantially below the claimed ₹61.68 crore.
SEBI further found that around ₹95.60 crore was transferred from the ZF LLPs to Yotta Agro Venture Pvt Ltd, directly or through other entities, without underlying business activity. The regulator said supplier and revenue entities were used as conduits in the transfer of funds. It also found that the LLPs spent ₹8.53 crore on the acquisition of Grobanana in the name of Yotta.
In its findings, SEBI said most transactions involving the supplier and revenue entities had little time lag and were largely among the entities themselves and the ZF LLPs/Yotta. The regulator cited, among other factors, a lack of evidence of transactions with farmers, mismatches between invoices and bank transfers, an absence of transportation or warehouse records, and inadequate supporting documentation. SEBI concluded that around ₹95.60 crore had been transferred through these entities without any underlying business activity.
SEBI concluded that Rituraj Sharma, Krishnna Joshi, Gayatri Rinwa, Yotta Agro Venture, Farm Silo Tech LLP, ZF Project 1 LLP, ZF Project 2 LLP and ZF Project 3 LLP had run a CIS and fraudulently dealt in securities in violation of the SEBI Act, CIS Regulations and PFUTP Regulations. It also held that the other involved entities had aided and abetted the scheme.
Based on these findings, SEBI restrained the eight principal noticees from collecting money from investors or launching or operating any CIS. They have also been barred from buying, selling, or otherwise dealing in securities, or from accessing the capital markets, for five years from the date of the order or until completion of the refund, whichever is later. The other noticees covered by the order have been restrained from accessing the securities market for three years.
SEBI has directed that the outstanding money collected under the schemes be refunded to investors with 12% interest per annum from 29 January 2024 until the date of refund. “A nodal refund officer will oversee the process. The amount lying in escrow and with Cashfree Payments India Pvt Ltd is to be transferred to an interest-bearing SEBI account for the first round of refunds. Refunds will be made proportionately based on the amount outstanding to each investor,” SEBI said.
The entities have been directed to provide SEBI with details of all existing investors and their outstanding amounts within 21 days. They must also provide details of their assets, including land and lease rights, and trade or other receivables within 30 days. Such assets can be liquidated to meet the outstanding refund obligation. If the entire amount cannot be recovered through this process, SEBI has directed that recovery may be made from the personal assets of the eight principal noticees.
The eight principal noticees have also been made jointly and severally liable for any shortfall in the refund payable to investors. SEBI said that the three individuals and the five entities acted in concert and that their actions were not distinct from each other. The regulator, however, did not impose similar refund liability on the Supplier and Revenue Entities, noting that the money collected from investors had been transferred through them rather than remaining with them.
The monetary penalties include ₹2 crore each on Rituraj Sharma, Krishnna Joshi, Gayatri Rinwa, Yotta Agro Venture Pvt Ltd, Farm Silo Tech LLP, ZF Project 1 LLP, ZF Project 2 LLP and ZF Project 3 LLP. Toshan Seeds Pvt Ltd, Gopal Vasharambhai Kuchhadiya, Girishkumar Ishvarlal Makvana, MSVO Ventures Pvt Ltd, Rahul Meena, Divya Soni and several other noticees have been penalised ₹50 lakh each, while Ashutosh Tiwari, Rahul Saini and Anandkumar Sriram Mahto have been penalised ₹20 lakh each. The aggregate penalty under the order works out to ₹25.10 crore.
Separate Settlement Involving Nutrikosh and Alok Chaudhary
According to the settlement order dated 28 September 2026, SEBI alleged that Nutrikosh India aided and abetted the fraudulent activities of other co-noticees and served as a conduit for the transfer of ₹7.03 crore. SEBI further alleged that Nutrikosh India played an active role in a scheme in which investor funds were collected by promising assured tax-free returns and then used, among other purposes, to show purported revenues and to acquire properties or assets.
The proceedings against Nutrikosh India and Mr Chaudhary were settled without admission or denial of the facts and conclusions of law. Following a meeting of SEBI's internal committee (IC) on 3 February 2026, the committee recommended settlement, with each applicant to pay ₹40.56 lakh. The high-powered advisory committee (HPAC) subsequently endorsed the recommendation, which was approved by SEBI's panel of whole-time members (WTMs) on 26 May 2026.
SEBI issued notices of demand on 1 June 2026, requiring the settlement amounts to be remitted within 30 calendar days. Both applicants informed SEBI on 30 June 2026 that the amounts had been remitted, and the concerned department confirmed receipt of the settlement payments. Thus, Nutrikosh India and Mr Chaudhary paid ₹40.56 lakh each, to settle the proceedings.
Through the settlement order, SEBI directed that it would not initiate any other enforcement action against the two applicants for the violations alleged in the 3 March 2025 SCN, subject to the terms of the settlement. SEBI retained the right to restore or initiate proceedings if representations made during the settlement process were subsequently found to be untrue, settlement undertakings were breached or a discrepancy was found in arriving at the settlement terms.
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