Market regulator Securities and Exchange Board of India (SEBI) has imposed a total penalty of ₹2.80 crore on 18 entities and barred them from the securities market for three to five years. It has also directed Sanjay Arunkumar Choksi and Western Agrotech Innovative Ltd to disgorge unlawful gains of ₹2.94 crore, along with 12% annual interest, in a case involving price manipulation in Retro Green Revolution Ltd.
The other entities penalised include: Viral Kapadia , Vishnu Sharma , Amesh Jaiswal , Vijay Pujara , Sanjay Arunkumar Choksi HUF , Sagar Choksi , Jenita Jain , Trupti Choksi , Umeshkumar Shah , Vraj Shah , Sneh Chokshi , Maama Mia Retailing Private Limited , Rajesh Pandey, Amit Sharma , Ganesh Bodakhe and Jalaj Agarwal
In its order, SEBI found that a group led by Sanjay Choksi orchestrated a coordinated plan to rig the price of RGRL shares, generate artificial trading volumes and offload holdings onto unsuspecting retail investors at inflated prices.
The regulator’s investigation, spanning September 2020 to December 2021, revealed that the otherwise illiquid stock witnessed an abnormal surge in price and volume. The scrip climbed sharply from around ₹10 to ₹33.85 before declining, triggering concerns of manipulation.
SEBI observed that the Choksi-led group, which held a substantial stake in the company, offloaded nearly 39.50% of the total shares and contributed over 20% of the traded volume during the period. This exit was facilitated by price inflation and by the creation of misleading market activity through a network of connected entities.
The scheme involved multiple layers of participation. Certain entities acted as ‘main perpetrators’, executing trades to create a false market appearance, while others supported the operation by routing funds, trading through linked accounts, or enabling transactions via broker networks.
A significant aspect of the manipulation was the use of Telegram channels to circulate stock tips which drew in retail investors. This led to a sharp rise in the number of shareholders from 2,462 to 6,819, providing the necessary liquidity for promoters and associates to offload their holdings.
SEBI also identified ‘top LTP contributors’ who played a key role in driving up the stock price. These entities were responsible for nearly 48.50% of the positive price movement and were found to be trading predominantly in the RGRL scrip, often at a loss, indicating non-genuine trading intent.
The order highlighted several suspicious trading patterns, including the creation of new high prices, execution of small ‘first trades’ to influence price trends, and concentrated trading among connected entities. Fund flow analysis further revealed financial linkages, with money routed through multiple layers to support the manipulative trades.
Rejecting the technical objections raised by the noticees, SEBI underscored that fraudulent intent can be established through circumstantial evidence, such as trading behaviour, interconnections, and overall conduct.
Concluding that the entities had violated provisions of the SEBI Act and the PFUTP Regulations, hereby imposed the following monetary penalty for violations of the SEBI Act and PFUTP Regulations.
The following noticees are barred from accessing the securities market and prohibited from dealing in securities, directly or indirectly, for the period specified in the table, effective from the date of this order.
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