The action stems from SEBI's investigation into a broader market manipulation scheme involving social media platforms, particularly Telegram channels, during the period between 31 May 2021 and 31 March 2022. According to the regulator, misleading buy recommendations for Moksh Ornaments shares were circulated on 31st January and 1 February 2022 to induce retail investors to purchase the stock.
SEBI's investigation began after search and seizure operations recovered digital evidence from Jalaj Agrawal's devices. Analysis of the extracted data allegedly revealed that Amesh Jaiswal supplied the stock-recommendation messages, which Jalaj Agrawal then forwarded to the Telegram channel operators Arvind Shukla and Aviral Saxena for wider dissemination. The messages contained entry prices, stop-loss levels, target prices and claims of 40% to 50% returns within five to seven days.
During the investigation, Jalaj Agrawal stated that Amesh Jaiswal had approached him to promote the Moksh Ornaments stock and that he, in turn, forwarded the messages to Arvind Shukla and Aviral Saxena for posting across multiple Telegram channels. He also admitted receiving payments from Amesh Jaiswal, while Arvind Shukla acknowledged receiving cash payments for posting recommendations and deleting messages after market close on Jalaj Agrawal's instructions. Aviral Saxena similarly admitted to posting the recommendations received from Jalaj Agrawal and receiving cash payments for doing so.
SEBI also relied on WhatsApp chats, call detail records and statements recorded during the investigation. According to the order, Amesh Jaiswal and Jalaj Agrawal exchanged more than 170 calls over the two days when the recommendations were circulated. The regulator also found frequent communication between Jalaj Agrawal and both Arvind Shukla and Aviral Saxena during the same period.
The regulator observed that the misleading Telegram messages had a significant impact on trading activity in the stock. The closing price of Moksh Ornaments rose by about 9.09% over the two days when the recommendations were circulated, while trading volumes and the number of trades surged sharply. However, after the promotional messages, the stock price declined steadily, falling from ₹36.35 on 1 February 2022 to ₹17.55 on 28 February 2022, a drop of nearly 52% in just 19 trading sessions.
SEBI further noted that the number of public shareholders almost doubled within days of the Telegram campaign, increasing from 11,229 before the recommendations to 22,248 three days later. On a quarterly basis, public shareholders increased from 3,849 as of December 2021 to 23,483 by the end of March 2022.
Based on the evidence, SEBI concluded that Amesh Jaiswal, Jalaj Agrawal, Arvind Shukla and Aviral Saxena had colluded to disseminate misleading buy recommendations through Telegram channels with the objective of inducing investors to buy Moksh Ornaments shares. The regulator held that their conduct violated the provisions of the SEBI Act and the SEBI (Prohibition of Fraudulent and Unfair Trade Practices) Regulations. It also found that Amesh Jaiswal failed to comply with summons issued during the investigation by not appearing before the investigating authority.
Accordingly, SEBI imposed penalties of ₹20 lakh on Amesh Surajlal Jaiswal, ₹15 lakh on Jalaj Agrawal, and ₹10 lakh each on Arvind Shukla and Aviral Saxena, taking the total monetary penalty in the case to ₹55 lakh.
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